`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`BAKER HUGHES, A GE COMPANY, LLC
`and
`BAKER HUGHES OILFIELD OPERATIONS, LLC,
`Petitioners
`
`v.
`
`PACKERS PLUS ENERGY SERVICES, INC.
`Patent Owner
`
`______________
`
`Case IPR2016-005961
`Patent 7,134,505
`______________
`
`
`JOINT LIST OF DEMONSTRATIVE EXHIBIT OBJECTIONS2
`
`
`
`1 This paper addresses RC’s demonstratives for IPR2016-00596 and -01496.
`2 Filed pursuant to Paper 76.
`
`36883429.1
`
`
`
`
`
`The Parties file this listing of Petitioners’ unresolved objections:
`
`Rapid Completions’ Slides 4-6, 9, 11-14, 40-45, 54-56, 58, 73, 75, 86, 92,
`
`97, 100, 103, 108-109, 112, 114-116, 118, and 120
`
`Petitioners’ short statement: The images of witnesses are not in evidence, are
`
`irrelevant, and run the risk of eliciting unconscious or implicit biases3 that should
`
`not be permitted to influence the evaluation or weighting of testimony.
`
`RC’s short statement: Respondent’s counsel has been involved in various trials,
`
`hearings, and IPR proceedings where pictures are used in this way without this
`
`being a problem or even objectionable in the first place.
`
`Rapid Completions’ Slide 13
`
`Petitioners’ short statement: The quoted snippets misleadingly omit the highly-
`
`relevant intervening testimony at 124:1-16 in Ex. 2085 (IPR2016-01506).
`
`RC’s short statement: Respondent is not attempting to be misleading; Petitioners
`
`are free to present clarifying testimony in their rebuttal presentation. Fed. R. Evid.
`
`106.
`
`
`3 Petitioners in no way suggest the Board is improperly or uniquely biased; rather,
`studies show that humans by nature have involuntary emotional responses when
`viewing images of faces with different expressions and/or skin tones. See, e.g.,
`o https://www.nbcnews.com/news/asian-america/new-study-exposes-
`racial-preferences-americans-n413371;
`o https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4158748/;
`o https://www.nature.com/articles/s41598-017-00502-3;
`o https://www.nature.com/articles/srep08478.
`36883429.1
`
`1
`
`
`
`October 31, 2017
`
`
`
`/Mark T. Garrett/
`Mark T. Garrett
`Lead Counsel for Petitioners
`
`/Justin T. Nemunaitis/
`Justin T. Nemunaitis
`Backup Counsel for Rapid Completions LLC
`
`36883429.1
`
`2
`
`
`
`
`
`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on October 31,
`
`2017, a complete copy of JOINT LIST OF DEMONSTRATIVE EXHIBIT
`
`OBJECTIONS was served on Patent Owner’s Exclusive Licensee via email (by
`
`consent), as follows:
`
`hhamad@caldwellcc.com
`bcaldwell@caldwellcc.com
`jnemunaitis@caldwellcc.com
`gonsalves@gonsalveslawfirm.com
`rapid@caldwellcc.com
`
`
`
`/Mark T. Garrett/
`Mark T. Garrett (Reg. No. 44,699)
`
`36883429.1
`
`
`
`
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`
`
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