`___________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`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 MOTION FOR
`OBSERVATION ON THE CROSS EXAMINATION
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`According to Petitioners, “multi-stage open-hole fracturing [“OHMS”] was
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`prevalent by 2001.” Reply at 1. Dr. Rao testified:
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`Q. Well, what I'm asking is this hypothetical person of skill in the art,
`would they have thought it was obvious prior to 2001 to do open hole
`multistage fracturing?
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`A. The -- the obvious part throws me because I don't what you mean by
`it was obvious. If somebody wished to do multistage fracturing, then -
`- then they could read Thomson. And Thomson did -- Thomson did
`multistage fracturing. So there was literature available to the
`POSITA to do such a thing, but the motivation by and large was
`not there.
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`Ex. 2101 at 13:11-24 (emphasis added).
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`Dated: October 20, 2017
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`Respectfully submitted,
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`Rapid Completions LLC
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`By /Justin T. Nemunaitis/
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`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
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`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
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`js@usiplaw.com
`pjf@usiplaw.com
`epatent@usiplaw.com
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`Date: October 20, 2017
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` /Hamad M. Hamad/
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`Hamad M. Hamad, Reg. No. 64,641
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