`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`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
`
`___________________
`
`Case IPR2016-01517
`Patent 7,134,505
`___________________
`
`
`
`EXCLUSIVE LICENSEE RAPID COMPLETIONS LLC’S
`OBJECTIONS TO PETITIONERS’ EVIDENCE PURSUANT
`TO 37 C.F.R. § 42.64(b)(1)
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`
`
`
`
`Case IPR2016-001517
`Patent 7,134,505
`
`
`Under the Federal Rules of Evidence and 37 C.F.R. § 42.64, Exclusive Licensee
`
`Rapid Completions LLC timely objects to evidence submitted with the Petitioners’
`
`Petition for Inter Partes Review. Rapid Completions serves Petitioners with these
`
`objections to provide notice that Rapid Completions may move to exclude the
`
`challenged exhibits under 37 C.F.R. § 42.64(c) unless Petitioners cure the defects
`
`associated with the challenged exhibits identified below.
`
`Exhibit 1007—Declaration of Vikram Rao
`
`
`
`Rapid Completions objects to this document under FRE 702 as Rapid
`
`Completions has not yet had an opportunity to depose Mr. Rao to properly assess
`
`his opinions under the Daubert standard.
`
`Exhibit 1008—Transcript of Daniel Themig – 01/08/2007
`
`
`
`To the extent Petitioners rely on the contents of this document for the truth
`
`of the matter asserted (for example, to establish public accessibility as a printed
`
`publication), Rapid Completions objects to such contents as inadmissible hearsay
`
`under FRE 801 and 802.
`
`
`
`Rapid Completions also objects to this document as not properly
`
`authenticated under FRE 901 because Petitioners have not presented sufficient
`
`evidence that the document is authentic nor that the document is self-authenticating
`
`under FRE 902.
`
`
`
`2
`
`
`
`Case IPR2016-001517
`Patent 7,134,505
`
`
`
`
`And Rapid Completions objects to this document as irrelevant under FRE
`
`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
`
`FRE 403 because this document is inadmissible under FRE 801, 802, and 901 as
`
`explained above.
`
`Exhibit 1011—Affidavit of Ken Trahan
`
`
`
`To the extent Petitioners rely on the contents of this document for the truth
`
`of the matter asserted (for example, to establish public accessibility as a printed
`
`publication), Rapid Completions objects to such contents as inadmissible hearsay
`
`under FRE 801 and 802.
`
`
`
`Rapid Completions also objects to this document as not properly
`
`authenticated under FRE 901 because Petitioners have not presented sufficient
`
`evidence that the document is authentic nor that the document is self-authenticating
`
`under FRE 902.
`
`
`
`And Rapid Completions objects to this document as irrelevant under FRE
`
`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
`
`FRE 403 because this document is inadmissible under FRE 801, 802, and 901 as
`
`explained above.
`
`Exhibit 1012—Expert Report of Kevin Trahan
`
`
`
`To the extent Petitioners rely on the contents of this document for the truth
`
`of the matter asserted (for example, to establish public accessibility as a printed
`
`
`
`3
`
`
`
`
`publication), Rapid Completions objects to such contents as inadmissible hearsay
`
`Case IPR2016-001517
`Patent 7,134,505
`
`under FRE 801 and 802.
`
`
`
`Rapid Completions also objects to this document as not properly
`
`authenticated under FRE 901 because Petitioners have not presented sufficient
`
`evidence that the document is authentic nor that the document is self-authenticating
`
`under FRE 902.
`
`
`
`And Rapid Completions objects to this document as irrelevant under FRE
`
`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
`
`FRE 403 because this document is inadmissible under FRE 801, 802, and 901 as
`
`explained above.
`
`Exhibit 1013—First Supplemental Report of Kevin Trahan
`
`
`
`To the extent Petitioners rely on the contents of this document for the truth
`
`of the matter asserted (for example, to establish public accessibility as a printed
`
`publication), Rapid Completions objects to such contents as inadmissible hearsay
`
`under FRE 801 and 802.
`
`
`
`Rapid Completions also objects to this document as not properly
`
`authenticated under FRE 901 because Petitioners have not presented sufficient
`
`evidence that the document is authentic nor that the document is self-authenticating
`
`under FRE 902.
`
`
`
`4
`
`
`
`Case IPR2016-001517
`Patent 7,134,505
`
`
`
`
`And Rapid Completions objects to this document as irrelevant under FRE
`
`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
`
`FRE 403 because this document is inadmissible under FRE 801, 802, and 901 as
`
`explained above.
`
`Exhibit 1014—Supplemental Engineering Report Prepared By Ronald
`
`Britton, P.E.
`
`
`
`To the extent Petitioners rely on the contents of this document for the truth
`
`of the matter asserted (for example, to establish public accessibility as a printed
`
`publication), Rapid Completions objects to such contents as inadmissible hearsay
`
`under FRE 801 and 802.
`
`
`
`Rapid Completions also objects to this document as not properly
`
`authenticated under FRE 901 because Petitioners have not presented sufficient
`
`evidence that the document is authentic nor that the document is self-authenticating
`
`under FRE 902.
`
`
`
`And Rapid Completions objects to this document as irrelevant under FRE
`
`401 and thus inadmissible under FRE 402, or as confusing or a waste of time under
`
`FRE 403 because this document is inadmissible under FRE 801, 802, and 901 as
`
`5
`
`explained above.
`
`
`
`
`
`
`
`
`Dated: March 8, 2017
`
`
`
`
`
`
`
`Respectfully submitted,
`
`Case IPR2016-001517
`Patent 7,134,505
`
`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, Re. No.
`43,639
`GONSALVES LAW FIRM
`2216 Beacon Lane
`Falls Church, Virginia 22043
`Telephone: 571.419.7252
`gonsalves@gonsalveslawfirm.com
`
`
`
`
`
`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
`
`The undersigned hereby certifies that the foregoing document was served
`
`via electronic mail, as previously consented to by Petitioner upon the following
`
`counsel of record:
`
`Jason Shapiro (Lead Counsel)
`Patrick Finnan (Back-up Counsel)
`EDELL,SHAPIRO & FINNAN, LLC
`
`6
`
`
`
`Case IPR2016-001517
`Patent 7,134,505
`
`js@usiplaw.com
`pjf@usiplaw.com
`epatent@usiplaw.com
`
`Date: March 8, 2017
`
`
`
`
`
` /Hamad M. Hamad/
`
`Hamad M. Hamad, Reg. No. 64,641
`
`7
`
`
`
`
`
`
`
`
`
`
`
`
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