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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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`WEATHERFORD INTERNATIONAL, LLC;
`WEATHERFORD/LAMB, INC.;
`WEATHERFORD US, LP; and WEATHERFORD
`ARTIFICIAL LIFT SYSTEMS, LLC
`Petitioners
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`v.
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`PACKERS PLUS ENERGY SERVICES INC.,
`Patent Owner
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`___________________
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`Case IPR2016-01509
`Patent 7,861,774
`___________________
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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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`Case IPR2016-01509
`Patent 7,861,774
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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 1007—Declaration of Vikram Rao
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`Rapid Completions objects to this document under FRE 702 as Rapid
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`Completions has not yet had an opportunity to depose Mr. Rao to properly assess
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`his opinions under the Daubert standard.
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`Exhibit 1008—Transcript of Daniel Themig – 01/08/2007
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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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`2
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`Case IPR2016-01509
`Patent 7,861,774
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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 1011—Affidavit of Ken Trahan
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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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`
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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 1012—Expert Report of Kevin Trahan
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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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`3
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`publication), Rapid Completions objects to such contents as inadmissible hearsay
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`Case IPR2016-01509
`Patent 7,861,774
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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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`
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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 1013—First Supplemental Report of Kevin Trahan
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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 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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`4
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`Case IPR2016-01509
`Patent 7,861,774
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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 1014—Supplemental Engineering Report Prepared By Ronald
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`Britton, P.E.
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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 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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`
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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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`Dated: March 8, 2017
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`Respectfully submitted,
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`Rapid Completions LLC
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`5
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`Case IPR2016-01509
`Patent 7,861,774
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`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, Re. No.
`43,639
`GONSALVES LAW FIRM
`2216 Beacon Lane
`Falls Church, Virginia 22043
`Telephone: 571.419.7252
`gonsalves@gonsalveslawfirm.com
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
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`The undersigned hereby certifies that the foregoing document was served
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`via electronic mail, as previously consented to by Petitioner upon the following
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`counsel of record:
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`Jason Shapiro (Lead Counsel)
`Patrick Finnan (Back-up Counsel)
`EDELL,SHAPIRO & FINNAN, LLC
`js@usiplaw.com
`pjf@usiplaw.com
`epatent@usiplaw.com
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`Date: March 8, 2017
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` /Hamad M. Hamad/
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`Hamad M. Hamad, Reg. No. 64,641
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`Case IPR2016-01509
`Patent 7,861,774
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