`
`Paper No. 60
`
`BEFORE THE PATENT TRIAL AND APPEAL
`BOARD
`
`WEATHERFORD INTERNATIONAL, LLC;
`WEATHERFORD/LAMB, INC.;
`WEATHERFORD US, LP; and
`WEATHERFORD ARTIFICIAL LIFT
`SYSTEMS, LLC
`Petitioners
`
`v.
`
`PACKERS PLUS ENERGY SERVICES, INC.,
`
`Patent Owner
`
`Inter Partes Review No. IPR2016-01509
`Patent 7,861,774
`
`OBJECTIONS TO ORAL HEARING DEMONSTRATIVES
`
`
`
`IPR2016-01509
`Patent 7,861,774
`The parties met and conferred to address objections to their respective oral
`
`hearing demonstratives. PO withdrew its objections in response Petitioner's
`
`changes. No agreement was reached regarding Petitioners' following objections:
`
`Slides 6, 52, 83 raise new arguments and cite portions of Ex. 2101 not in
`
`PO's motion for observation. Slides 49-51 raise new arguments. Slides 10, 16, 25,
`
`30, 32, 33, 34, 35 raise new arguments, present new evidence not in the record and
`
`are incomplete. Slides 42, 43, 53-56, 58-66, 69-76, 85-87, 137, 138 include
`
`evidence not in the record and raise new arguments. Slides 67, 77-80, 88-89, 107,
`
`120 should be excluded for the reasons in Petitioner’s motion to exclude and
`
`because the slides raise new arguments. Slides 4, 5, 40, 95 and 121 raise new
`
`arguments not relied upon in the papers. Slide 9 raises new arguments, and the
`
`cited portion of Ex. 1002 (page 3) was not was not relied upon in the papers (see,
`
`e.g., Ex. 2081 at 15; POR at 45). Slides 11 and 12 raise new arguments, and cite
`
`portions of the references not relied upon in the papers. Slide 18 raises new
`
`arguments, and the cited portion of Ex. 1002 (page 7) was not relied upon in the
`
`papers (see, e.g., Ex. 2081 at 15-16; POR at 45, 59). Slides 20, 22 raise new
`
`arguments as the cited portions of Ex. 1036 (pages 65, 67) were not relied upon in
`
`the papers (see, e.g., Ex. 2081 at 15-16; POR at 45, 59). Slides 58-66, 69-76, 85-
`
`87 include evidence not in the record and raise new arguments. Slides 48, 81-83,
`
`90-92, 104-106, 108, 116-118, 119, 122, 131, 136 raise new arguments.
`
`1
`
`
`
`Dated: October 31, 2017
`
`IPR2016-01509
`Patent 7,861,774
`Respectfully submitted,
`
`Counsel for Petitioners
`/Jason Shapiro/
`Jason Shapiro
`Reg. No. 35,354
`
`2
`
`
`
`IPR2016-01509
`Patent 7,861,774
`
`CERTIFICATE OF SERVICE
`I certify that the foregoing OBJECTIONS TO ORAL HEARING
`
`DEMONSTRATIVES were served October 31, 2017 via electronic mail, as
`
`previously consented to by Patent Owner, upon the following counsel of record:
`
`HAMAD M. HAMAD (LEAD COUNSEL)
`BRADLEY W. CALDWELL (BACK-UP COUNSEL)
`JUSTIN NEMUNAITIS (BACK-UP COUNSEL)
`CALDWELL CASSADY CURRY P.C.
`
`hhamad@caldwellcc.com
`bcaldwell@caldwellcc.com
`jnemunaitis@caldwellcc.com
`rapid@caldwellcc.com
`
`DR. GREGORY J. GONSALVES (BACK-UP COUNSEL)
`GONSALVES LAW FIRM
`
`gonsalves@gonsalveslawfirm.com
`
`Dated: October 31, 2017
`EDELL, SHAPIRO & FINNAN, LLC
`9801 Washingtonian Blvd., Suite 750
`Gaithersburg, MD 20878
`Customer No. 27896
`
`Respectfully submitted:
`/Mark J. DeBoy/
`Mark J. DeBoy, Reg. No. 66,983
`Telephone: 301.424.3640
`
`3
`
`
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