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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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`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 IPR2016-01506
`Patent 7,861,774
`___________________
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`
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`EXCLUSIVE LICENSEE RAPID COMPLETIONS LLC’S
`OBJECTIONS TO PETITIONERS’ EVIDENCE PURSUANT
`TO 37 C.F.R. § 42.64(b)(1)
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`Under the Federal Rules of Evidence and 37 C.F.R. § 42.64, Exclusive
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`Licensee Rapid Completions LLC timely objects to evidence submitted with the
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`Petitioners’ Petition for Inter Partes Review. Rapid Completions serves Petitioners
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`with these objections to provide notice that Rapid Completions may move to
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`exclude the challenged exhibits under 37 C.F.R. § 42.64(c) unless Petitioners cure
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`the defects associated with the challenged exhibits identified below.
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`Exhibit 1002—Kieckhefer Affidavit
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`To the extent Petitioners rely on the contents of this document for the truth
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`of the matter asserted (for example, to establish public accessibility as a printed
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`publication), Rapid Completions objects to such contents as inadmissible hearsay
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`under FRE 801 and 802. And Rapid Completions objects to this document as
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`irrelevant under FRE 401 and thus inadmissible under FRE 402, or as confusing or
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`a waste of time under FRE 403 because this document is inadmissible under FRE
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`801, 802, and 901 as explained above.
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`Exhibit 1003—Ellsworth
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`To the extent Petitioners rely on the contents of this document for the truth
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`of the matter asserted (for example, to establish public accessibility as a printed
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`publication), Rapid Completions objects to such contents as inadmissible hearsay
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`under FRE 801 and 802.
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`Rapid Completions also objects to this document as not properly
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`authenticated under FRE 901 because Petitioners have not presented sufficient
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`evidence that the document is authentic nor that the document is self-authenticating
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`under FRE 902.
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`And Rapid Completions objects to this document as irrelevant under FRE
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`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
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`FRE 403 because this document is inadmissible under FRE 801, 802, and 901 as
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`explained above.
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`Exhibit 1005 - Daneshy Declaration
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`Rapid Completions objects to the Daneshy Declaration under FRE 702 and
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`703 as Petitioners have failed to show that Dr. Daneshy is qualified to offer each of
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`the opinions in the declaration or that he was apprised of the relevant legal
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`standards. See, e.g., IPR2016-00598, Paper 26 at 48-51.
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`Exhibit 1006—Kate Van Dyke, Fundamentals of Petroleum Engineering
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`To the extent Petitioners rely on the contents of this document for the truth
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`of the matter asserted (for example, to establish public accessibility as a printed
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`publication), Rapid Completions objects to such contents as inadmissible hearsay
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`under FRE 801 and 802.
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`
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`And Rapid Completions objects to this document as irrelevant under FRE
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`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
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`FRE 403 because this document is inadmissible under FRE 801, 802, and 602 as
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`explained above.
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`Exhibit 1007—Ron Baker, A Primer of Oil Well Drilling
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`To the extent Petitioners rely on the contents of this document for the truth
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`of the matter asserted (for example, to establish public accessibility as a printed
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`publication), Rapid Completions objects to such contents as inadmissible hearsay
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`under FRE 801 and 802.
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`
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`And Rapid Completions objects to this document as irrelevant under FRE
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`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
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`FRE 403 because this document is inadmissible under FRE 801, 802, and 602 as
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`explained above.
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`Exhibit 1014—Declaration of Christopher Hawkes and Horizontal Well
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`Technology Conference Materials
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`To the extent Petitioners rely on the contents of this document for the truth
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`of the matter asserted (for example, to establish public accessibility as a printed
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`publication), Rapid Completions objects to such contents as inadmissible hearsay
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`under FRE 801 and 802.
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`Rapid Completions further objects to the document for lack of foundation.
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`Petitioner has not shown that the declarant has personal knowledge of the subject
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`matter of the testimony as required by FRE 602.
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`And Rapid Completions objects to this document as irrelevant under FRE
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`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
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`FRE 403 because this document is inadmissible under FRE 801, 802, and 602 as
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`explained above.
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`Exhibit 1015—Eberhard Article
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`To the extent Petitioners rely on the contents of this document for the truth
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`of the matter asserted (for example, to establish public accessibility as a printed
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`publication), Rapid Completions objects to such contents as inadmissible hearsay
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`under FRE 801 and 802.
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`
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`And Rapid Completions objects to this document as irrelevant under FRE
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`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
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`FRE 403 because this document is inadmissible under FRE 801, 802, and 602 as
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`explained above.
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`Exhibit 1016—Declaration of Nancy Chaffin Hunter
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`To the extent Petitioners rely on the contents of this document for the truth
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`of the matter asserted (for example, to establish public accessibility as a printed
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`publication), Rapid Completions objects to such contents as inadmissible hearsay
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`under FRE 801 and 802.
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`
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`Rapid Completions further objects to the document for lack of foundation.
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`Petitioner has not shown that the declarant has personal knowledge of the subject
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`matter of the testimony as required by FRE 602.
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`
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`And Rapid Completions objects to this document as irrelevant under FRE
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`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
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`FRE 403 because this document is inadmissible under FRE 801, 802, and 602 as
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`explained above.
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`Exhibit 1017—Declaration of Nancy Chaffin Hunter
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`To the extent Petitioners rely on the contents of this document for the truth
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`of the matter asserted (for example, to establish public accessibility as a printed
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`publication), Rapid Completions objects to such contents as inadmissible hearsay
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`under FRE 801 and 802.
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`Rapid Completions further objects to the document for lack of foundation.
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`Petitioner has not shown that the declarant has personal knowledge of the subject
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`matter of the testimony as required by FRE 602.
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`
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`And Rapid Completions objects to this document as irrelevant under FRE
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`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
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`FRE 403 because this document is inadmissible under FRE 801, 802, and 602 as
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`explained above.
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`Exhibit 1018—Howard and Fast, Hydraulic Fracturing
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`To the extent Petitioners rely on the contents of this document for the truth
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`of the matter asserted (for example, to establish public accessibility as a printed
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`publication), Rapid Completions objects to such contents as inadmissible hearsay
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`under FRE 801 and 802.
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`
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`And Rapid Completions objects to this document as irrelevant under FRE
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`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
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`FRE 403 because this document is inadmissible under FRE 801, 802, and 602 as
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`explained above.
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`Exhibit 1019—Hyne, Dictionary of Petroleum Exploration, Drilling, &
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`Production
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`To the extent Petitioners rely on the contents of this document for the truth
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`of the matter asserted (for example, to establish public accessibility as a printed
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`publication), Rapid Completions objects to such contents as inadmissible hearsay
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`under FRE 801 and 802.
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`
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`And Rapid Completions objects to this document as irrelevant under FRE
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`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
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`FRE 403 because this document is inadmissible under FRE 801, 802, and 602 as
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`explained above.
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`Exhibit 1022—Lagrone Paper
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`To the extent Petitioners rely on the contents of this document for the truth
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`of the matter asserted (for example, to establish public accessibility as a printed
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`publication), Rapid Completions objects to such contents as inadmissible hearsay
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`under FRE 801 and 802.
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`
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`And Rapid Completions objects to this document as irrelevant under FRE
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`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
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`FRE 403 because this document is inadmissible under FRE 801, 802, and 602 as
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`explained above.
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`Dated: February 16, 2017
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` Respectfully submitted,
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`Rapid Completions LLC
`
`
`By /Justin T. Nemunaitis/
`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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`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 record
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`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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`
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`Date: February 16, 2017
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` /Hamad M. Hamad/
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`Hamad M. Hamad, Reg. No. 64,641
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