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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`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 IPR2016-01496 (Patent 7,134,505)
`Case IPR2016-01505 (Patent 7,543,634)
`Case IPR2016-01506 (Patent 7,861,774)
`___________________
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`PATENT OWNER’S NOTICE TO THE BOARD
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`On March 9, 2017 the Board requested that Rapid Completions LLC inform
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`the Board as to whether 1) it desires live testimony in cases IPR2016-00596,
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`IPR2016-00597, IPR2016-00598, IPR2016-00650, IPR2016-00656, and IPR2016-
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`00657; and 2) it wishes to withdraw its opposition to Petitioner’s joinder motion.
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`Rapid Completions sets forth its positions below:
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`(1) Rapid Completions requests an opportunity to present live testimony in
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`IPR2016-00596, IPR2016-00597, and IPR2016-00598. To the extent the Board
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`maintains the May 18th trial date, Rapid Completions specifically requests that each
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`side be permitted an opportunity to call its expert declarant.
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`(2) Rapid Completions withdraws its opposition to Baker Hughes’ joinder
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`motions, provided that joinder would result in a single trial for all currently pending
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`IPRs related to the ’505, ’634, and ’774 patents. If joinder would result in multiple
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`trials for these patents, Rapid Completions remains opposed to joinder. In addition,
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`Rapid Completions remains opposed to joinder if the Board grants its motions for
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`reconsideration with regard to the institution decisions in IPR2016-01509, IPR2016-
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`01514, and IPR2016-01517 (the “Weatherford IPRs”), but denies its motions for
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`reconsideration with regard to IPR2016-01496, IPR2016-01505, and IPR2016-01506
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`(the “Baker Follow-On IPRs”).1
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`1 Rapid Completions maintains that the Baker Follow-On IPRs are improper serial
`petitions that would need to be terminated pursuant 35 U.S.C. § 315(e)(1) if the
`Board were to reach a final decision in IPR2016-00596, IPR2016-00597, and
`IPR2016-00598. Accordingly, if the Board terminates the Weatherford IPRs, but
`1
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`Dated: March 14, 2017
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` Respectfully submitted,
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`Rapid Completions LLC
`
`
`By /Hamad M. Hamad/
`Hamad M. Hamad, Reg. No. 64,641
`Bradley W. Caldwell (pro hac vice)
`Justin T. Nemunaitis (pro hac vice)
`CALDWELL CASSADY CURRY, P.C.
`2101 Cedar Springs Road, Suite 1000
`Dallas, Texas 75201
`Telephone: 214.888.4848
`Facsimile: 214.888.4849
`hhamad@caldwellcc.com
`bcaldwell@caldwellcc.com
`jnemunaitis@caldwellcc.com
`rapid@caldwellcc.com
`
`Dr. Gregory Gonsalves, Reg. No. 43,639
`GONSALVES LAW FIRM
`2216 Beacon Lane
`Falls Church, Virginia 22043
`Telephone: 571.419.7252
`gonsalves@gonsalveslawfirm.com
`
`
`
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`
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`maintains the Baker Follow-On IPRs, then Rapid Completions requests that the
`Board maintain the May 18th trial date in IPR2016-00596, IPR2016-00597, and
`IPR2016-00598. Once the Board reaches a final decision in those proceedings, it
`may then terminate the Baker Follow-On IPRs pursuant to § 315(e)(1) without the
`burden and expense of a trial in those proceedings.
`2
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`CERTIFICATION OF SERVICE
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` The undersigned hereby certifies that the foregoing document was
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`served electronically via e-mail in its entirety on the following counsel of
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`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
`
`
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`Date: March 14, 2017
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`/Hamad M. Hamad/
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`Hamad M. Hamad, Reg. No. 64,641
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`3
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