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
`________________________
`
`PETITIONER’S REPLY TO PATENT OWNER’S OBJECTIONS TO
`EVIDENCE AND PETITIONER’S SUPPLEMENTARY EVIDENCE
`PURSUANT TO 37 C.F.R. § 42.64(b)(2)
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 1 of 20
`
`
`________________________
`
`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
`________________________
`
`PETITIONER’S REPLY TO PATENT OWNER’S OBJECTIONS TO
`EVIDENCE AND PETITIONER’S SUPPLEMENTARY EVIDENCE
`PURSUANT TO 37 C.F.R. § 42.64(b)(2)
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 1 of 20
`
`
`
`Case IPR2016-01517
`Patent No. 7,134,505
`
`Under 37 C.F.R. § 42.64(b)(2), Petitioners Weatherford International LLC, et
`
`al. (hereinafter “Petitioner”), reply to the evidentiary objections submitted by
`
`Exclusive Licensee Rapid Completions (hereinafter “Patent Owner”). Petitioner
`
`also serves supplementary evidence as Exhibits 1032 and 1033, also pursuant to 37
`
`C.F.R. § 42.64(b)(2).
`
`Exhibit 1007 – Declaration of Vikram Rao
`
`Patent Owner objects to Petitioner’s Ex. 1007 because Patent Owner has not
`
`yet had the opportunity to depose the declarant. Petitioner respectfully directs Patent
`
`Owner to 37 C.F.R. § 42.53(d) for the procedure by which deposition testimony may
`
`be taken.
`
`Exhibit 1008 – Transcript of Daniel Themig
`
`Patent Owner objects to Ex. 1008 as being inadmissible hearsay under Fed.
`
`R. Evid. 801 and 802. Ex. 1008 is not hearsay pursuant to Fed. R. Evid. 801(d).
`
`Specifically, Ex. 1008 contains a transcript of a deposition of Daniel Themig in the
`
`litigation styled Halliburton Energy Services, Inc. et al. v. Packers Plus Energy
`
`Services, Inc., et al., No. CV-44,964 in the 238th Judicial District Court of Midland
`
`County, Texas (“the ‘964 action”) in which Mr. Themig provides testimony as a
`
`representative for real party in interest Packers Plus Energy Services Inc. See, e.g.,
`
`Ex. 1032; see also Ex. 1008 at 2 (internal page 444). The testimony contained in
`
`1
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 2 of 20
`
`
`
`Case IPR2016-01517
`Patent No. 7,134,505
`
`Ex. 1008 is being used against Packers Plus Energy Services Inc. in the current
`
`proceeding. See, e.g., IPR2016-01517, Petition for Inter Partes Review, Paper 1
`
`(hereinafter “Petition”) at 17-18. Furthermore, the testimony was made by the party
`
`in an individual or representative capacity; is testimony that the party manifested
`
`that it adopted or believed to be true; was made by a person authorized to make a
`
`statement on the subject; and/or was made by the party’s agent or employee on a
`
`matter within the scope of the relationship while it existed.
`
`For example, as illustrated on pages 1-3 of Ex. 1032, real party in interest
`
`Packers Plus Energy Services Inc. was served with a Notice of Deposition in the
`
`‘964 action. As noted on page 1 of Ex. 1032 and page 2 (internal page 444) of Ex.
`
`1008, Mr. Themig served as the designated representative for real party in interest
`
`Packers Plus Energy Services Inc. in the deposition taken in response to the Notice
`
`of Deposition of Ex. 1032 and as memorialized in the deposition transcript of Ex.
`
`1008. Furthermore, Mr. Themig was designated by real party in interest Packers
`
`Plus Energy Services Inc. to address the subject matter for which Petitioner relies on
`
`Ex. 1008. See, e.g., Ex. 1032 at 5-6; see also, e.g., Ex. 1008 at 2 (internal page 444);
`
`see also, e.g., Petition at 17-18. Therefore, Ex. 1008 is not hearsay pursuant to Fed.
`
`R. Evid. 801(d). Ex. 1008 also falls within one or more of the hearsay exceptions of
`
`Fed. R. Evid. 803 and 807.
`
`2
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 3 of 20
`
`
`
`Case IPR2016-01517
`Patent No. 7,134,505
`
`Additionally, Patent Owner has not specifically identified any of the
`
`statements in Ex. 1008 that constitute hearsay, as is required under 37 C.F.R. §
`
`42.64(b)(1). Liberty Mutual Insurance Co. v. Progressive Casualty Insurance Co.,
`
`CBM2012-00010, Paper 59, at 36 (rejecting hearsay objections in motion to exclude
`
`where movant failed to specifically identify the textual portions of the exhibits that
`
`allegedly were offered for the truth of the matter asserted and instead moved to
`
`exclude the entire exhibits).
`
`Patent Owner also objects to Ex. 1008 as being inadmissible under Fed. R.
`
`Evid. 901 as not being properly authenticated. Patent Owner is directed to Petitioner
`
`Ex. 1027, the Declaration of Carrie Anderson, which provides evidence sufficient to
`
`support a finding that Ex. 1008 is what Petitioner claims it is. Patent Owner also
`
`submits herewith Ex. 1033, a Second Declaration of Carrie Anderson, which also
`
`provides evidence sufficient to support a finding that Ex. 1008 is what Petitioner
`
`claims it is.
`
`Finally, Patent Owner objects to Ex. 1008 as being inadmissible under Fed.
`
`R. Evid. 402 as being irrelevant or as being confusing or a waste of time under Fed.
`
`R. Evid. 403 because it is allegedly inadmissible under Fed. R. Evid. 801, 802 and
`
`901. First, as noted above, the submission of Ex. 1008 is admissible under Fed. R.
`
`3
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 4 of 20
`
`
`
`Case IPR2016-01517
`Patent No. 7,134,505
`
`Evid. 801, 803, 807 and/or and 901. Second, Petitioner notes that Ex. 1008 is clearly
`
`relevant to the issues in the present proceeding. See, e.g., Petition at 17-18.
`
`Exhibit 1011 – Affidavit of Kevin Trahan
`
`Patent Owner objects to Ex. 1011 as being inadmissible hearsay under Fed.
`
`R. Evid. 801 and 802. Ex. 1011 is not hearsay pursuant to Fed. R. Evid. 801(d). For
`
`example, Kevin Trahan served as an expert in the ‘964 action for real party in interest
`
`Packers Plus Energy Services Inc., and the affidavit was made pursuant to Mr.
`
`Trahan’s role as an expert for Packers Plus Energy Services Inc. in the ‘964 action.
`
`See, e.g., Ex. 1011 at 1. The testimony contained in Ex. 1011 is being used against
`
`Packers Plus Energy Services Inc. in the present proceeding. See, e.g., Petition at
`
`19. Furthermore, the testimony contained in Ex. 1011 was made by the party in an
`
`individual or representative capacity; is testimony that the party manifested that it
`
`adopted or believed to be true; was made by a person authorized to make a statement
`
`on the subject; and/or was made by the party’s agent or employee on a matter within
`
`the scope of the relationship while it existed. Therefore, Ex. 1011 is not hearsay
`
`pursuant to Fed. R. Evid. 801(d)(2). See, e.g., CBM2015-00130, Final Written
`
`Decision, paper 33 at 40 (Real party in interest expert report in a prior proceeding
`
`found to be non-hearsay evidence pursuant to Fed. R. Evid. 801(d)(2)). Ex. 1011
`
`also falls within one or more of the hearsay exceptions of Fed. R. Evid. 803 and 807.
`
`4
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 5 of 20
`
`
`
`Case IPR2016-01517
`Patent No. 7,134,505
`
`Finally, Patent Owner has not specifically identified any of the statements in Ex.
`
`1011 that constitute hearsay, as is required under 37 C.F.R. § 42.64(b)(1). Liberty
`
`Mutual Insurance Co. v. Progressive Casualty Insurance Co., CBM2012-00010,
`
`Paper 59, at 36 (rejecting hearsay objections in motion to exclude where movant
`
`failed to specifically identify the textual portions of the exhibits that allegedly were
`
`offered for the truth of the matter asserted and instead moved to exclude the entire
`
`exhibits).
`
`Patent Owner objects to Ex. 1011 as being inadmissible under Fed. R. Evid.
`
`901 as not being properly authenticated. Patent Owner is directed to Petitioner Ex.
`
`1027, the Declaration of Carrie Anderson, which provides evidence sufficient to
`
`support a finding that Ex. 1011 is what Petitioner claims it is. Patent Owner also
`
`submits herewith Ex. 1033, a Second Declaration of Carrie Anderson, which
`
`provides evidence sufficient to support a finding that Ex. 1011 is what Petitioner
`
`claims it is.
`
`Finally, Patent Owner objects to Ex. 1011 as being inadmissible under Fed.
`
`R. Evid. 402 as being irrelevant or as being confusing or a waste of time under Fed.
`
`R. Evid. 403 because it is allegedly inadmissible under Fed. R. Evid. 801, 802 and
`
`901. First, as noted above, Ex. 1011 is admissible pursuant to Fed. R. Evid. 801,
`
`5
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 6 of 20
`
`
`
`Case IPR2016-01517
`Patent No. 7,134,505
`
`802, 803, 807 and/or 901. Second, Petitioner notes that Ex. 1011 is clearly relevant
`
`to the issues in the present proceeding. See, e.g., Petition at 19.
`
`Exhibit 1012 – Expert Report of Kevin Trahan
`
`Patent Owner objects to Ex. 1012 as being inadmissible hearsay under Fed.
`
`R. Evid. 801 and 802. Ex. 1012 is not hearsay pursuant to Fed. R. Evid. 801(d). For
`
`example, Mr. Trahan served as an expert in the ‘964 action for real party in interest
`
`Packers Plus Energy Services Inc., and the report contained in Ex. 1012 was
`
`provided pursuant to Mr. Trahan’s role as an expert for Packers Plus Energy Services
`
`Inc. in the ‘964 action. See, e.g., Ex. 1012 at 4. The statements contained in Ex.
`
`1012 are being used against Packers Plus Energy Services Inc. in the present
`
`proceeding. See, e.g., Petition at 19-20, 28. Furthermore, the report contained in
`
`Ex. 1012 was made by the party in an individual or representative capacity; is
`
`testimony that the party manifested that it adopted or believed to be true; was made
`
`by a person authorized to make a statement on the subject; and/or was made by the
`
`party’s agent or employee on a matter within the scope of the relationship while it
`
`existed. Accordingly, Ex. 1012 is not hearsay pursuant to Fed. R. Evid. 801(d)(2).
`
`See, e.g., CBM2015-00130, Final Written Decision, paper 33 at 40 (Real party in
`
`interest expert report in a prior proceeding found to be non-hearsay evidence
`
`pursuant to Fed. R. Evid. 801(d)(2)). Ex. 1012 also falls within one or more of the
`
`6
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 7 of 20
`
`
`
`Case IPR2016-01517
`Patent No. 7,134,505
`
`hearsay exceptions of Fed. R. Evid. 803 and 807. Finally, Patent Owner has not
`
`specifically identified any of the statements in Ex. 1012 that constitute hearsay, as is
`
`required under 37 C.F.R. § 42.64(b)(1).
`
`Liberty Mutual Insurance Co. v.
`
`Progressive Casualty Insurance Co., CBM2012-00010, Paper 59, at 36 (rejecting
`
`hearsay objections in motion to exclude where movant failed to specifically identify
`
`the textual portions of the exhibits that allegedly were offered for the truth of the
`
`matter asserted and instead moved to exclude the entire exhibits).
`
`Patent Owner objects to Ex. 1012 as being inadmissible under Fed. R. Evid.
`
`901 as not being properly authenticated. Patent Owner is directed to Petitioner Ex.
`
`1027, the Declaration of Carrie Anderson, which provides evidence sufficient to
`
`support a finding that Ex. 1012 is what Petitioner claims it is. Patent Owner also
`
`submits herewith Ex. 1033, a Second Declaration of Carrie Anderson, which
`
`provides evidence sufficient to support a finding that Ex. 1012 is what Petitioner
`
`claims it is.
`
`Finally, Patent Owner objects to Ex. 1012 as being inadmissible under Fed.
`
`R. Evid. 402 as being irrelevant or as being confusing or a waste of time under Fed.
`
`R. Evid. 403 because it is allegedly inadmissible under Fed. R. Evid. 801, 802 and
`
`901. First, as noted above, Ex. 1012 is admissible pursuant to Fed. R. Evid. 801,
`
`7
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 8 of 20
`
`
`
`Case IPR2016-01517
`Patent No. 7,134,505
`
`802, 803, 807 and/or 901. Second, Petitioner notes that Ex. 1012 is clearly relevant
`
`to the issues in the present proceeding. See, e.g., Petition at 19-20, 28.
`
`Exhibit 1013 – First Supplemental Report of Kevin Trahan
`
`Patent Owner objects to Ex. 1013 as being inadmissible hearsay under Fed.
`
`R. Evid. 801 and 802. Ex. 1013 is not hearsay pursuant to Fed. R. Evid. 801(d). For
`
`example, Mr. Trahan served as an expert in the ‘964 action for real party in interest
`
`Packers Plus Energy Services Inc., and the report contained in Ex. 1013 was made
`
`pursuant to Mr. Trahan’s role as an expert for Packers Plus Energy Services Inc.
`
`See, e.g., Ex. 1013 at 3. The statements contained in Ex. 1013 are being used against
`
`Packers Plus Energy Services Inc. in the present proceeding. See, e.g., Petition at
`
`20. Furthermore, the report contained in Ex. 1013 was made by the party in an
`
`individual or representative capacity; is testimony that the party manifested that it
`
`adopted or believed to be true; was made by a person authorized to make a statement
`
`on the subject; and/or was made by the party’s agent or employee on a matter within
`
`the scope of the relationship while it existed. Accordingly, Ex. 1013 is not hearsay
`
`pursuant to Fed. R. Evid. 801(d)(2). See, e.g., CBM2015-00130, Final Written
`
`Decision, paper 33 at 40 (Real party in interest expert report in a prior proceeding
`
`found to be non-hearsay evidence pursuant to Fed. R. Evid. 801(d)(2)). Ex. 1013
`
`also falls within one or more of the hearsay exceptions of Fed. R. Evid. 803 and 807.
`
`8
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 9 of 20
`
`
`
`Case IPR2016-01517
`Patent No. 7,134,505
`
`Finally, Patent Owner has not specifically identified any of the statements in Ex.
`
`1013 that constitute hearsay, as is required under 37 C.F.R. § 42.64(b)(1). Liberty
`
`Mutual Insurance Co. v. Progressive Casualty Insurance Co., CBM2012-00010,
`
`Paper 59, at 36 (rejecting hearsay objections in motion to exclude where movant
`
`failed to specifically identify the textual portions of the exhibits that allegedly were
`
`offered for the truth of the matter asserted and instead moved to exclude the entire
`
`exhibits).
`
`Patent Owner objects to Ex. 1013 as being inadmissible under Fed. R. Evid.
`
`901 as not being properly authenticated. Patent Owner is directed to Petitioner Ex.
`
`1027, the Declaration of Carrie Anderson, which provides evidence sufficient to
`
`support a finding that Ex. 1013 is what Petitioner claims it is. Patent Owner also
`
`submits herewith Ex. 1033, a Second Declaration of Carrie Anderson, which
`
`provides evidence sufficient to support a finding that Ex. 1013 is what Petitioner
`
`claims it is.
`
`Finally, Patent Owner objects to Ex. 1013 as being inadmissible under Fed.
`
`R. Evid. 402 as being irrelevant or as being confusing or a waste of time under Fed.
`
`R. Evid. 403 because it is allegedly inadmissible under Fed. R. Evid. 801, 802 and
`
`901. First, as noted above, Ex. 1013 is admissible pursuant to Fed. R. Evid. 801,
`
`9
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 10 of 20
`
`
`
`Case IPR2016-01517
`Patent No. 7,134,505
`
`802, 803, 807 and/or 901. Second, Petitioner notes that Ex. 1013 is clearly relevant
`
`to the issues in the present proceeding. See, e.g., Petition at 20.
`
`Exhibit 1014 – Supplemental Engineering Report Prepared by Ronald
`
`Britton, P.E.
`
`Patent Owner objects to Ex. 1014 as being inadmissible hearsay under Fed.
`
`R. Evid. 801 and 802. Ex. 1014 is not hearsay pursuant to Fed. R. Evid. 801(d). For
`
`example, Ronald Britton served as an expert in the ‘964 action for real party in
`
`interest Packers Plus Energy Services Inc., and the report in Ex. 1014 was made
`
`pursuant to Mr. Britton’s role as an expert for Packers Plus Energy Services, Inc.
`
`See, e.g., Ex. 1014 at 1-3. The report contained in Ex. 1014 is being used against
`
`Packers Plus Energy Services Inc. in the present proceeding. See, e.g., Petition at
`
`20-21. Furthermore, the report contained in Ex. 1014 was made by the party in an
`
`individual or representative capacity; is testimony that the party manifested that it
`
`adopted or believed to be true; was made by a person authorized to make a statement
`
`on the subject; and/or was made by the party’s agent or employee on a matter within
`
`the scope of the relationship while it existed. Accordingly, Ex. 1014 is not hearsay
`
`pursuant to Fed. R. Evid. 801(d)(2). See, e.g., CBM2015-00130, Final Written
`
`Decision, paper 33 at 40 (Real party in interest expert report in a prior proceeding
`
`found to be non-hearsay evidence pursuant to Fed. R. Evid. 801(d)(2)). Ex. 1014
`
`10
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 11 of 20
`
`
`
`Case IPR2016-01517
`Patent No. 7,134,505
`
`also falls within one or more of the hearsay exceptions of Fed. R. Evid. 803 and 807.
`
`Finally, Patent Owner has not specifically identified any of the statements in Ex.
`
`1014 that constitute hearsay, as is required under 37 C.F.R. § 42.64(b)(1). Liberty
`
`Mutual Insurance Co. v. Progressive Casualty Insurance Co., CBM2012-00010,
`
`Paper 59, at 36 (rejecting hearsay objections in motion to exclude where movant
`
`failed to specifically identify the textual portions of the exhibits that allegedly were
`
`offered for the truth of the matter asserted and instead moved to exclude the entire
`
`exhibits).
`
`Patent Owner objects to Ex. 1014 as being inadmissible under Fed. R. Evid.
`
`901 as not being properly authenticated. Patent Owner is directed to Petitioner Ex.
`
`1027, the Declaration of Carrie Anderson, which provides evidence sufficient to
`
`support a finding that Ex. 1014 is what Petitioner claims it is. Patent Owner also
`
`submits herewith Ex. 1033, a Second Declaration of Carrie Anderson, which
`
`provides evidence sufficient to support a finding that Ex. 1014 is what Petitioner
`
`claims it is.
`
`Finally, Patent Owner objects to Ex. 1014 as being inadmissible under Fed.
`
`R. Evid. 402 as being irrelevant or as being confusing or a waste of time under Fed.
`
`R. Evid. 403 because it is allegedly inadmissible under Fed. R. Evid. 801, 802 and
`
`901. First, as noted above, Ex. 1014 is admissible pursuant to Fed. R. Evid. 801,
`
`11
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 12 of 20
`
`
`
`Case IPR2016-01517
`Patent No. 7,134,505
`
`802, 803, 807 and/or 901. Second, Petitioner notes that Ex. 1014 is clearly relevant
`
`to the issues in the present proceeding. See, e.g., Petition at 20-21.
`
`Conclusion
`
`In light of the above, Petitioner respectfully asserts that each of the above-
`
`referenced documents are admissible evidence pursuant to the Federal Rules of
`
`Evidence, and any objection thereto should be withdrawn.
`
`If Patent Owner
`
`maintains its objections for items authored by third parties, Petitioner plans to
`
`request that the Board allow Petitioner to seek discovery from those third parties.
`
`These responses and supplemental evidence have been timely served within 10
`
`business days of the service of Patent Owner’s Objections.
`
`Dated: March 22, 2017
`
`Respectfully submitted,
`/Jason Shapiro/
`Jason Shapiro, Counsel for Petitioners
`
`12
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 13 of 20
`
`
`
`Case IPR2016-01517
`Patent No. 7,134,505
`
`CERTIFICATE OF SERVICE
`
`the foregoing PETITIONER’S REPLY TO PATENT
`I certify that
`OWNER’S OBJECTIONS TO EVIDENCE AND PETITIONER’S
`SUPPLEMENTARY EVIDENCE PURSUANT TO 37 C.F.R. § 42.64(b)(2),
`ACCOMPANYING EXHIBITS and UPDATED EXHIBIT LIST were served
`March 22, 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
`
`DR. GREGORY J. GONSALVES (BACK-UP COUNSEL)
`GONSALVES LAW FIRM
`
`gonsalves@gonsalveslawfirm.com
`
`Dated: March 22, 2017
`EDELL, SHAPIRO & FINNAN, LLC
`9801 Washingtonian Blvd., Suite 750
`Gaithersburg, MD 20878
`
`Respectfully submitted:
`/Mark J. DeBoy/
`Mark J. DeBoy, Reg. No. 66,983
`Telephone: 301.424.3640
`Customer No. 27896
`
`13
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 14 of 20
`
`
`
`Weatherford International LLC et al.
`Exhibit 1032
`Weatherford International LLC et al. v. Packers Plus Energy Services, Inc.
`IPR2016-01517
`Page 1
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 15 of 20
`
`
`
`Weatherford International LLC et al.
`Exhibit 1032
`Weatherford International LLC et al. v. Packers Plus Energy Services, Inc.
`IPR2016-01517
`Page 2
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 16 of 20
`
`
`
`Weatherford International LLC et al.
`Exhibit 1032
`Weatherford International LLC et al. v. Packers Plus Energy Services, Inc.
`IPR2016-01517
`Page 3
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 17 of 20
`
`
`
`Weatherford International LLC et al.
`Exhibit 1032
`Weatherford International LLC et al. v. Packers Plus Energy Services, Inc.
`IPR2016-01517
`Page 4
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 18 of 20
`
`
`
`Weatherford International LLC et al.
`Exhibit 1032
`Weatherford International LLC et al. v. Packers Plus Energy Services, Inc.
`IPR2016-01517
`Page 5
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 19 of 20
`
`
`
`Weatherford International LLC et al.
`Exhibit 1032
`Weatherford International LLC et al. v. Packers Plus Energy Services, Inc.
`IPR2016-01517
`Page 6
`
`IPR2016-01517
`Weatherford International LLC et al.
`Ex. 1047
`Page 20 of 20
`
`
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