`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
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`
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`BAKER HUGHES INCORPORATED and
`BAKER HUGHES OILFIELD OPERATIONS, INC.,
`Petitioners
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`v.
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`PACKERS PLUS ENERGY SERVICES INC.,
`Patent Owner
`
`___________________
`
`Case IPR2016-00598
`Patent 7,861,774
`___________________
`
`
`EXCLUSIVE LICENSEE RAPID COMPLETIONS LLC’S MOTION
`TO WITHDRAW AS COUNSEL AND SUBSTITUTE NEW COUNSEL
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`I. RELIEF REQUESTED
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`Pursuant to 37 C.F.R. § 42.10(e), and as authorized by the Board in an e-mail
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`dated October 5, 2016, current counsel for Exclusive Licensee Rapid Completions
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`LLC respectfully requests authorization to withdraw Michael B. Ray, Lori A.
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`Gordon, and Kyle Conklin as counsel, and substitute Hamad M. Hamad as lead
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`counsel and Dr. Gregory J. Gonsalves, Bradley W. Caldwell (subject to pro hac vice
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`admission), and Justin T. Nemunaitis (subject to pro hac vice admission) as back-up
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`counsel in this proceeding.
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`Patent Owner has conferred with Petitioners’ counsel. Petitioners do not
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`oppose this motion.
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`II.
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`STATEMENT OF REASONS FOR SUBSTITUTION OF COUNSEL
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`Rapid Completions wishes to designate new lead counsel, Hamad M. Hamad
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`(Registration No. 64,641) and to designate new back up counsel Dr. Gregory J.
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`Gonsalves (Registration No. 43,639), Bradley W. Caldwell (motion for pro hac vice
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`admission to be filed), and Justin T. Nemunaitis (motion for pro hac vice admission
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`to be filed) to represent Rapid Completions going forward in this proceeding.
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`Rapid Completions’ new lead counsel and back up counsel Mr. Gonsalves
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`meet the requirements of 37 C.F.R. § 42.10(c) as registered practitioners. Motions
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`for pro hac vice admission of Mr. Caldwell and Mr. Nemunaitis will be filed shortly
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`after this motion. Mr. Caldwell and Mr. Nemunaitis are attorneys representing Rapid
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`
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`Completions in pending district court litigation concerning the infringement of the
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`’774 patent. Mr. Caldwell’s and Mr. Nemunaitis’s qualifications, as required for pro
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`hac vice admission, will be stated in the forthcoming motions for pro hac vice
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`admission and supporting declarations.
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`It is believed that granting this Motion will not hinder the economy, the
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`integrity of the patent system, the efficient administration of the Office, or the ability
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`of the Office to timely complete this proceeding. See 35 U.S.C. § 316(b).
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`A new executed Power of Attorney is being filed concurrently.
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`Updated Mandatory Notices Under 37 C.F.R. § 42.8(b)(3) and (b)(4) will be
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`filed upon grant of the present motion.
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`Respectfully submitted,
` STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`/Michael B. Ray/
`
`Michael B. Ray
`Registration No. 33,997
`Attorney for Exclusive Licensee
`
`
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`
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`Date: October 6, 2016
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`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`(202) 371-2600
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`
`
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`CERTIFICATION OF SERVICE
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`
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`The undersigned hereby certifies that the foregoing EXCLUSIVE
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`LICENSEE RAPID COMPLETIONS LLC’S MOTION TO WITHDRAW AS
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`COUNSEL AND SUBSTITUTE NEW COUNSEL and accompanying Power of
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`Attorney were served electronically via e-mail on October 6, 2016, in their entirety
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`on the following counsel of record for Petitioner:
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`Mark T. Garrett (Lead Counsel)
`Eagle H. Robinson (Back-up Counsel)
`NORTON ROSE FULBRIGHT US LLP
`mark.garrett@nortonrosefulbright.com
`eagle.robinson@nortonrosefulbright.com
`
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`
`
`/Michael B. Ray/
`
`Michael B. Ray
`Registration No. 33,997
`Attorney for Exclusive Licensee
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`Date: October 6, 2016
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`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`(202) 371-2600
`
`
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`4819329_1.doc