`___________________
`
`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 MOTION
`TO WITHDRAW AS COUNSEL AND SUBSTITUTE NEW COUNSEL
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`I. RELIEF REQUESTED
`
`
`
`Pursuant to 37 C.F.R. § 42.10(e), and as authorized by the Board in an e-mail
`
`dated October 5, 2016, current counsel for Exclusive Licensee Rapid Completions
`
`LLC respectfully requests authorization to withdraw Michael B. Ray, Lori A.
`
`Gordon, Kyle Conklin, and Steven Peters as counsel, and substitute Hamad M.
`
`Hamad as lead counsel and Dr. Gregory J. Gonsalves, Bradley W. Caldwell (subject
`
`to pro hac vice admission), and Justin T. Nemunaitis (subject to pro hac vice
`
`admission) as back-up counsel in this proceeding.
`
`
`
`Patent Owner has conferred with Petitioners’ counsel. Petitioners do not
`
`oppose this motion.
`
`II.
`
`STATEMENT OF REASONS FOR SUBSTITUTION OF COUNSEL
`
`Rapid Completions wishes to designate new lead counsel, Hamad M. Hamad
`
`(Registration No. 64,641) and to designate new back up counsel Dr. Gregory J.
`
`Gonsalves (Registration No. 43,639), Bradley W. Caldwell (motion for pro hac vice
`
`admission to be filed), and Justin T. Nemunaitis (motion for pro hac vice admission
`
`to be filed) to represent Rapid Completions going forward in this proceeding.
`
`Rapid Completions’ new lead counsel and back up counsel Mr. Gonsalves
`
`meet the requirements of 37 C.F.R. § 42.10(c) as registered practitioners. Motions
`
`for pro hac vice admission of Mr. Caldwell and Mr. Nemunaitis will be filed shortly
`
`after this motion. Mr. Caldwell and Mr. Nemunaitis are attorneys representing Rapid
`
`
`
`Completions in pending district court litigation concerning the infringement of the
`
`’505 patent. Mr. Caldwell’s and Mr. Nemunaitis’s qualifications, as required for pro
`
`hac vice admission, will be stated in the forthcoming motions for pro hac vice
`
`admission and supporting declarations.
`
`A decision on whether to institute this inter partes review has not yet issued,
`
`and no extensions of time will be needed upon grant of this Motion. Furthermore, it
`
`is believed that granting this Motion will not hinder the economy, the integrity of the
`
`patent system, the efficient administration of the Office, or the ability of the Office
`
`to timely complete this proceeding. See 35 U.S.C. § 316(b).
`
`A new executed Power of Attorney is being filed concurrently.
`
`Updated Mandatory Notices Under 37 C.F.R. § 42.8(b)(3) and (b)(4) will be
`
`filed upon grant of the present motion.
`
`Respectfully submitted,
` STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`/Michael B. Ray/
`
`Michael B. Ray
`Registration No. 33,997
`Attorney for Exclusive Licensee
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Date: October 6, 2016
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`(202) 371-2600
`
`
`
`
`CERTIFICATION OF SERVICE
`
`
`
`The undersigned hereby certifies that the foregoing EXCLUSIVE
`
`LICENSEE RAPID COMPLETIONS LLC’S MOTION TO WITHDRAW AS
`
`COUNSEL AND SUBSTITUTE NEW COUNSEL and accompanying Power of
`
`Attorney were served electronically via e-mail on October 6, 2016, in their entirety
`
`on the following counsel of record for Petitioner:
`
`Jason Shapiro (Lead Counsel)
`Patrick Finnan (Back-up Counsel)
`EDELL, SHAPIRO & FINNAN, LLC
`js@usiplaw.com
`pjf@usiplaw.com
`epatent@usiplaw.com
`
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`
`
`/Michael B. Ray/
`
`Michael B. Ray
`Registration No. 33,997
`Attorney for Exclusive Licensee
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Date: October 6, 2016
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`(202) 371-2600
`
`
`
`4786635_1.doc
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