BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`BAKER HUGHES INCORPORATED and
`
`BAKER HUGHES OILFIELD OPERATIONS, INC., Petitioners
`
`PACKERS PLUS ENERGY SERVICES INC.,
`,
`Patent Owner
`
`Case IPR2016-00597
`
`Patent 7,543,634
`
`DECLARATION OF MICHAEL P. DELANEY
`
`Mail Stop PA TENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`
`P.O. Box 1450
`
`Alexandria, VA 22313-1450
`
`Ex. 2045
`
`IPR2016-00597
`1 of 6
`
`
`
`BAKER HUGHES INCORPORATED and
`
`BAKER HUGHES OILFIELD OPERATIONS, INC., Petitioners
`
`PACKERS PLUS ENERGY SERVICES INC.,
`,
`Patent Owner
`
`Case IPR2016-00597
`
`Patent 7,543,634
`
`DECLARATION OF MICHAEL P. DELANEY
`
`Mail Stop PA TENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`
`P.O. Box 1450
`
`Alexandria, VA 22313-1450
`
`Ex. 2045
`
`IPR2016-00597
`1 of 6
`
`
`
`I, the below-named Declarant, state as follows:
`
`My name is Michael P. Delaney, and I reside in Dallas, Texas.
`
`I am a paralegal at the law firm of Caldwell, Cassady and Curry
`P.C.
`
`Exhibit 2001 already on file is a true and correct copy of A.
`Casero, Open Hole Multi—Stage Completion System in
`Unconventional Plays: Efiiciency, Eflectiveness and
`Economics, SPE 164009 (2013).
`
`Exhibit 2002 already on file is a true and correct copy of
`Encyclopedia ofHydrocarbons, Chapter 3.1: Upstream
`technologies.
`
`Exhibit 2003 already on file is a true and correct copy of D.
`Lohoefer, Comparative Study of Cemented versus Uncemented
`Multi-Stage Fractured Wells in the Barnett Shale, SPE 135386,
`Society of Petroleum Engineers (2010).
`
`Exhibit 2004 already on file is a true and correct copy of R.
`Seale et al., Eflective Stimulation ofHorizontal Wells—A New
`Completion Method, SPE 106357, Society of Petroleum
`Engineers (2006).
`
`Exhibit 2005 already on file is a true and correct copy of
`Exploration and Development, Alberta Oil Magazine.
`
`Exhibit 2006 already on file is a true and correct copy of
`Leading the Way: Multistage fracking pioneer Packers Plus
`plays major role in cracking the tight oil code, Canadian
`OilPatch Technology Guidebook (2012).
`
`Exhibit 2007 already on file is a true and correct copy of
`Financial Post, “Entrepreneur of the Year: National Winner”.
`
`10.
`
`Exhibit 2008 already on file is a true and correct copy of
`Innovation—Groundbreaking Innovation in Calgary, Calgary
`Herald (Feb. 12, 1014).
`
`Ex. 2045
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`IPR2016-00597
`2 of 6
`
`
`
`11.
`
`12.
`
`13.
`
`14.
`
`15.
`
`16.
`
`17.
`
`18.
`
`Exhibit 2009 already on file is a true and correct copy of J.
`Chury, Packers Plus Technology Becoming the Industry
`Standard, The Oil Patch Report (Dec. 2010/J an. 2011).
`
`Exhibit 2010 already on file is a tme and correct copy of P.
`Roche, 0pen—Hole or Cased and Cemented, New Technology
`Magazine (Nov. 2011).
`
`Exhibit 2011 already on file is a true and correct copy of P.
`Roche, Open-Hole or Cased and Cemented, New Technology
`Magazine (Nov. 2011).
`
`Exhibit 2012 already on file is a true and correct copy of Van
`Dyke, Kate, “Fundamentals ofPetroleum,” Fourth Ed. (1997).
`
`Exhibit 2013 already on file is a true and correct copy of
`“Proven Performance: Read how Packers Plus systems and
`solutions have delivered results around the world,” Packers Plus
`Energy Services Inc., accessed May 24, 2016.
`
`Attached as Exhibit 2017 is a true and correct copy of Packers
`Plus advertising brochure (2010).
`
`Attached as Exhibit 2018 is a true and correct copy of Baker
`
`Hughes, “FracPoint Completion System Isolated Openhole
`
`Horizontal Well in Lower Huron Shale” (2011).
`
`Attached as Exhibit 2019 is a true and correct copy of Baker
`Hughes, “Enhancing Well Performance Through Innovative
`Completion Technologies,” presentation, (Sept. 10-12, 2012).
`
`19.
`
`Attached as Exhibit 2020 is a true and correct copy of Canadian
`
`Society for Unconventional Resources, Press Release,
`
`“Unconventional Industry Awards Innovative Thinking” (Oct.
`
`3, 2012).
`
`20.
`
`Attached as Exhibit 2021 is a true and correct bates-stamped
`copy of BH00364675, CONFIDENTIAL Ball activated sliding
`sleeves report.
`
`Ex. 2045
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`IPR2016-00597
`3 of 6
`
`
`
`21.
`
`Attached as Exhibit 2022 is a true and correct copy of Rigzone,
`Schlumberger Acquires Stake in Packers Plus (Nov. 22, 2005).
`
`22.
`
`Attached as Exhibit 2023 is a true and correct copy of Britt, L.
`
`and Smith, M., Horizontal Well Completion, Stimulation
`
`Optimization, and Risk Mitigation, SPE 125526 (2009).
`
`23.
`
`24.
`
`Attached as Exhibit 2024 is a true and correct copy of
`BH003 63 808, CONFIDENTIAL Baker Hughes Engineering
`Materials.
`
`Attached as Exhibit 2025 is a true and correct copy of
`RC_PAC0001943 4, CONFIDENTIAL Packers Plus
`Engineering Drawing.
`
`25.
`
`Attached as Exhibit 2026 is a true and correct copy of Baker
`
`Hughes 2008 10-K Shareholder Report.
`
`26.
`
`27.
`
`28.
`
`29.
`
`Attached as Exhibit 2027 is a true and correct copy of Baker
`Hughes 2010 10—K Shareholder Report.
`
`Attached as Exhibit 2028 is a true and correct copy of Baker
`Hughes 2013 10—K Shareholder Report.
`
`Attached as Exhibit 2029 is a true and correct copy of Packers
`Plus case study, StackFRAC system provides superior
`production economics.
`
`Attached as Exhibit 2030 is a true and correct copy of Packers
`Plus Case Study, StackFRAC HD system enables high
`stimulation rates.
`
`30.
`
`Attached as Exhibit 2031 is a true and correct copy of Packers
`
`Plus StackFRAC Video,
`
`http ://packersplus .com/solution/stackfrac-hd-system/.
`
`Ex. 2045
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`IPR2016-00597
`4 of 6
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`
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`31. Attached as Exhibit 2032 is a true and correct copy of Baker
`Hughes FracPoint Video,
`https://www.youtube.com/watch?v=s5ZQCRRZzXE.
`
`32. Attached as Exhibit 2033 is a true and correct copy of a
`Business News Network Packers Plus Feature video.
`
`33. Attached as Exhibit 2038 is a true and correct copy of Ingersoll,
`C, “BP and the Deepwater Horizon Disaster of 2010” (Apr. 3,
`2012).
`
`34. Attached as Exhibit 2039 is a true and correct copy of Crosby,
`D.G., “Methodology to Predict the Initiation of Multiple
`Transverse Fractures from Horizontal Wellbores” (2001).
`
`35. Attached as Exhibit 2040 is a true and correct copy of Kaiser,
`P., “Hydraulic Fracturing Mine Back Trials — Design Rationale
`and Project Status” (2013).
`
`36. Attached as Exhibit 2041 is a true and correct copy of Stoltz,
`L.R., “Probabilistic Reserves Assessment Using A Filtered
`Monte Carlo Method In a Fractured Limestone Reservoir” SPE
`
`39714 (1998).
`
`37. Attached as Exhibit 2042 is a true and correct copy of
`Emanuele, M. A., “A Case History: Completion and
`Stimulation of Horizontal Wells with Multiple Transverse
`Hydraulic Fractures in the Lost Hills Diatomite” SPE 39941
`(1998).
`
`38. Attached as Exhibit 2043 is a true and correct copy of Gaynor,
`Tom M., “Tortuosity Versus Micro—Tortuosity — Why Little
`Things Mean a Lot” SPE/IADC 67818 (2001).
`
`39. Attached as Exhibit 2044 is a true and correct copy of Cramer,
`David, “Stimulating Unconventional Reserviors: Lessons
`Learned, Successful Practices, Areas for Improvement” SPE
`114172 (2008).
`
`Ex. 2045
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`IPR2016-00597
`5 of 6
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`
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`Further, Declarant sayeth not.
`
`I, the aboVe—named Declarant, hereby declare that all statements made
`
`herein of my own knowledge are true and that all statements made on
`
`information and belief are believed to be true; and further that these statements
`
`were made with the knowledge that willful false statements and the like so
`
`made are punishable by fine or imprisonment, or both, under Section 1001 of
`
`Title 18 of the United States.
`
`Date: December 2, 2016
`
`
`
`
`Signature of DGC.l.':1l‘Ell
`Michael P. Delaney
`
`Ex. 2045
`
`IPR2016-00597
`6 of 6
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