RAPID COMPLETIONS LLC,
`Plaintiff,
`
`v.
`
`BAKER HUGHES INCORPORATED,
`BAKER HUGHES OILFIELD OPERATIONS,
`INC., WEATHERFORD INTERNATIONAL,
`LLC, WEATHERFORD/LAMB, INC.,
`WEATHERFORD US, LP, WEATHERFORD
`ARTIFICIAL LIFT SYSTEMS, LLC, PEAK
`COMPLETION TECHNOLOGIES, INC.,
`PEGASI ENERGY RESOURCES
`CORPORATION, PEGASI OPERATING,
`INC., AND TR RODESSA, INC.,
`
`
`Defendants,
`v.
`
`PACKERS PLUS ENERGY SERVICES, INC.,
`RAPID COMPLETIONS LLC,
`Counterclaim Defendants.
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
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`Case No. 6:15-cv-724-RWS-KNM
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`DEFENDANTS’ INVALIDITY CONTENTIONS
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`Defendants Weatherford International, LLC, Weatherford/Lamb, Inc., Weatherford US,
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`LP, Weatherford Artificial Lift Systems, LLC (“Weatherford”); Baker Hughes Incorporated and
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`Baker Hughes Oilfield Operations, Inc. ( “Baker Hughes”); Peak Completion Technologies, Inc.
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`(“Peak”) and Pegasi Energy Resources Corporation and Pegasi Operating, Inc. (“Pegasi”)
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`(collectively “Defendants”) hereby disclose to Plaintiff Rapid Completions, LLC and
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`Counterclaim Defendant Packers Plus Energy Services, Inc. (“Plaintiff”) these Invalidity
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`Contentions pursuant to Patent Local Rule 3-3 (“Invalidity Contentions”). The accompanying
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`document production required by Patent Local Rule 3-4(b) is also provided contemporaneously
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`with these Invalidity Contentions. Weatherford, Baker Hughes, Peak, and Pegasi each reserve
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`the right to select and/or rely on different prior art and/or invalidity contentions at trial or
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`otherwise.
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`I.
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`INTRODUCTION
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`Plaintiff has asserted against Defendants claims 14, 17-26 of U.S. Patent No. 6,907,936
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`(“the ’936 Patent”); claims 1-7, 11, 14-27 of U.S. Patent No. 7,134,505 (“the ’505 Patent”);
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`claims 1, 2, 6, 9-17, 19-25 of U.S. Patent No. 7,543,634 (“the ’634 Patent”); claims 1-16 of U.S.
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`Patent No. 7,861,774 (“the ’774 Patent”); claims 1-13 of U.S. Patent No. 8,657,009 (“the ’009
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`patent”); claims 1-8 of U.S. Patent No. 9,074,451 (“the ’451 patent”) (collectively, “Asserted
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`Claims” and “Asserted Patents”). Defendants are only providing Invalidity Contentions for the
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`above identified Asserted Claims of the Asserted Patents. Should Plaintiff later attempt to assert
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`additional claims, Defendants reserve the right to amend these Invalidity Contentions and
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`contend that any additional claims are also invalid. Defendants’ Invalidity Contentions are not
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`an admission of validity as to any other claims of the Asserted Patents.
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`These contentions are based on Defendants’ present understanding of the Asserted
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`Claims, prior to any claim construction proceedings in this case. These Invalidity Contentions
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`may reflect various alternative positions as to claim construction and scope. Defendants do not
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`adopt, advocate, or acquiesce in any particular claim construction position by these Invalidity
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`Contentions. Furthermore, these Invalidity Contentions are not an admission by Defendants that
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`any accused products, including any current or past versions of these products, are covered by, or
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`infringe the Asserted Claims, particularly when the Asserted Claims are properly construed.
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`Defendants’ discovery and investigations in connection with this matter are continuing
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`and thus, these Invalidity Contentions are based on information obtained to date and are
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`necessarily preliminary in nature. In particular, these Invalidity Contentions are based in whole
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`or in part on Defendants’ present understanding of Plaintiff’s positions concerning the scope and
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`construction of the asserted claims to the extent those positions can be deduced from Plaintiff’s
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`Infringement Contentions served on November 23, 2015. Defendants note that Plaintiff’s
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`Infringement Contentions as to each Defendant were severely deficient, which has hindered
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`Defendants’ ability to collect prior art and develop invalidity theories. Defendants also note that
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`Plaintiff has taken the position that it need not provide any specificity with regard to its
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`allegations of infringement until the discovery process plays out. Thus, Defendants expressly
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`reserve the right to amend their invalidity contentions at such time as Plaintiff provides more
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`specificity with regard to its allegations of infringement. Defendants further reserve the right to
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`seek to modify, supplement, and/or amend these Invalidity Contentions and associated document
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`production based on further
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`investigation, analysis, and discovery, results of patent
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`reexaminations, Defendants’ consultation with experts and others, Plaintiff’s contentions, and/ or
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`Court rulings (including rulings in this and/or related cases) on relevant issues such as claim
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`construction, validity, and priority dates. Because Defendants are continuing its search for and
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`analyze relevant prior art, Defendants reserve the right to seek to revise, amend, and/or
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`supplement the information provided herein, including identifying, charting, and/or relying upon
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`additional prior art references, relevant disclosures, and bases for invalidity contentions.
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`Additional prior art, disclosures, and invalidity defenses, whether or not cited in this disclosure
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`and whether known or not known to Defendants, may become relevant as investigation, analysis,
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`and discovery continue.
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`Defendants are aware that Plaintiff has asserted a foreign counterpart patent against other
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`defendants and some Defendants in other lawsuits. Defendants hereby rely on and incorporate
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`by reference and expressly reserve the right to rely upon all invalidity contentions, including all
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`invalidity positions and all prior art cited therein, that have been or will be served by other
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`defendants in cases pending in other courts in which Plaintiff asserts related patents.
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`Defendants are currently unaware of the extent, if any, to which Plaintiff will contend
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`that limitations of the Asserted Claims are not disclosed in the prior art identified by Defendants.
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`To the extent that Plaintiff makes such contentions, Defendants reserve the right to identify and
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`rely upon other references or portions of identified or unidentified references regarding the
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`allegedly missing limitation(s).
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`Additionally, because discovery has only recently commenced and third-party discovery
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`has not yet begun, Defendants reserve the right to present additional prior art references and/or
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`disclosures under 35 U.S.C. §§ 102(a), (b), (e), (f), and/or (g), and/or § 103, located during the
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`course of such discovery or further investigation, and to assert invalidity under 35 U.S.C. §§ 102
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`and/or 103 to the extent that such discovery or investigation yields information forming the basis
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`for such invalidity. Further, Defendants have included anticipatory and obviousness prior art
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`references based on Plaintiff’s asserted priority dates. Accordingly, Defendants reserve the right,
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`as permitted, to modify, amend, and/or supplement these Invalidity Contentions as additional
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`information regarding the proper priority dates become available, and as their discovery and
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`investigations proceed. Each disclosed item of prior art is evidence of a prior invention by
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`another under 35 U.S.C. § 102(g), as evidenced by the named inventors, authors, organizations,
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`and publishers involved with each such reference.
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`II.
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`P.R. 3-3(A) – IDENTIFICATION OF PRIOR ART REFERENCES.
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`In addition to the references cited on the face of the Asserted Patents, the admitted prior
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`art references in the Asserted Patent specifications, the prosecution histories of the Asserted
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`Patents, the references cited in any reexaminations or inter partes reviews of the Asserted
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`Patents, and the references cited in any invalidity contentions in any action or proceeding or in a
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`future action or proceeding involving the Asserted Patents, Defendants identify the prior art
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`listed below.
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`Defendants contend that at least some of the systems, services, and products disclosed in
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`one or more of the prior art references identified below are prior art under 25 U.S.C. §§ 102(a),
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`(b), and/or (g), and/or 103. Defendants may not have complete information regarding the dates
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`by which some of the systems, services, and products described in the prior art references were
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`publicly disclosed, used, made, sold, or offered for sale, the circumstances under which the
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`research, design, development activities were conducted, and the identities of the particular
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`individuals involved in such activities through publicly available patents, publications, and
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`product literature. Defendants anticipate that the actual dates, circumstances, and identities of
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`individuals will be the subject of discovery, including third-party discovery, during this case.
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`To the extent the inventions identified in the patents, publications, systems, and other
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`prior art to the Asserted Patents identified in these Invalidity Contentions were conceived by
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`another and diligently reduced to practice before the alleged conception and reduction to practice
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`of the Asserted Claims of the Asserted Patents by the named inventors of those patents,
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`Defendants allege that such prior art inventions invalidate the Plaintiff’s Asserted Patents under
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`35 U.S.C § 102(g).
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`The following patents and publications are prior art under one or more of pre-AIA 35 U.S.C.
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`§§ 102(a), (b), and/or (e) or pre-AIA 35 U.S.C. § 103.
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`Prior Art Patents/Published Applications
`U.S. Patent No. 4,279,306 (“Weitz ’306 Patent”)(filed August 10, 1979)(issued July 21,
`1.
`1981) is prior art under §§ 102(a), 102(b), and/or 102(e).
`2. U.S. Patent No. 4,484,625 (“Barbee ’625 Patent”)(filed April 20, 1982)(issued
`November 27, 1984) is prior art under §§ 102(a), 102(b), and/or 102(e).
`3. U.S. Patent No. 3,122,205 (“Brown, et al, ’205 Patent”)(filed November 4, 1960)(issued
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`Prior Art Patents/Published Applications
`February 25, 1964) is prior art under §§ 102(a), 102(b), and/or 102(e).
`4. U.S. Patent No. 2,227,539 (“Dorton ’539 Patent”)(filed October 24, 1939)(issued
`January 7, 1941) is prior art under §§ 102(a), 102(b), and/or 102(e).
`5. U.S. Patent No. 2,715,444 (“Fewel ’444 Patent”)(filed March 17, 1950)(issued August
`16, 1955) is prior art under §§ 102(a), 102(b), and/or 102(e).
`6. U.S. Patent No. 6,006,838 (“Whiteley, et al, ’838 Patent”)(filed October 12,
`1998)(issued December 28, 1999) is prior art under §§ 102(a), 102(b), and/or 102(e).
`7. U.S. Patent No. 6,315,041 (“Carlisle et al, ’041 Patent”)(filed April 15, 1999)(issued
`November 13, 2001) is prior art under §§ 102(a), 102(b), and/or 102(e).
`8. U.S. Patent Publication No. 2001/0018977 (“Kilgore ’8977 Published App”)(filed April
`9, 2001)(published September 6, 2001) is prior art under §§ 102(a), 102(b), and/or
`102(e).
`9. U.S. Patent No. 5,375,662 (“Echols ’662 Patent”)(filed June 30, 1993)(issued December
`27, 1994) is prior art under §§ 102(a), 102(b), and/or 102(e).
`10. U.S. Patent No. 5,449,039 (“Hartley et al, ’039 Patent”)(filed February 7, 1994)(issued
`September 12, 1995) is prior art under §§ 102(a), 102(b), and/or 102(e).
`11. U.S. Patent No. 3,062,291 (“Brown ’291 Patent”)(filed May 11, 1959)(issued November
`6, 1962) is prior art under §§ 102(a), 102(b), and/or 102(e).
`12. U.S. Patent No. 8,215,411 (“Flores, et al, ’411 Patent”)(filed November 6, 2009)(issued
`July 10, 2012). To the extent that RC asserts that the ’009 and ’451 patents are entitled
`to a priority date based on the filing of the continuation-in-part patent application which
`led to the ‘047 patent, the Flores ’411 patent is prior art under §§ 102(a), 102(b), and/or
`102(e).1
`13. U.S. Patent No. 8,291,980 (“Fay ’980 Patent”)(filed August 13, 2009)(issued October
`23, 2012). To the extent that RC asserts that the ’009 and ’451 patents are entitled to a
`priority date based on the filing of the continuation-in-part patent application which led
`to the ‘047 patent, the Fay ’980 patent is prior art under §§ 102(a), 102(b), and/or
`102(e).
`14. U.S. Patent No. 3,054,415 (“Baker et al, ’415 Patent”)(filed August 3, 1959)(issued
`September 18, 1962) is prior art under §§ 102(a), 102(b), and/or 102(e).
`15. U.S. Patent No. 4,893,678 (“Stokley et al, ’678 Patent”)(filed December 30,
`1988)(issued January 16, 1990) is prior art under §§ 102(a), 102(b), and/or 102(e).
`16. U.S. Patent No. 6,491,103 (“Allamon et al, ’103 Patent”)(filed April 9, 2001)(issued
`December 10, 2002) is prior art under §§ 102(a), 102(b), and/or 102(e).
`17. U.S. Patent No. 5,715,891 (“Graham ’891 Patent”)(filed September 27, 1995)(issued
`February 10, 1998) is prior art under §§ 102(a), 102(b), and/or 102(e).
`18. U.S. Patent No. 6,009,944 (“Gudmestad ’944 Patent”)(filed December 6, 1996)(issued
`January 4, 2000) is prior art under §§ 102(a), 102(b), and/or 102(e).
`19. U.S. Patent No. 6,220,353 (“Foster et al, ’353 Patent”)(filed April 30, 1999)(issued
`April 24, 2001) is prior art under §§ 102(a), 102(b), and/or 102(e).
`20. U.S. Patent No. 6,241,013 (“Martin ’013 Patent”)(filed August 25, 1998)(issued June 5,
`2001) is prior art under §§ 102(a), 102(b), and/or 102(e).
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`1 Weatherford does not rely on Flores at this time.
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`Prior Art Patents/Published Applications
`21. U.S. Patent No. 3,730,267 (“Scott ’267 Patent”)(filed March 25, 1971)(issued May 1,
`1973) is prior art under §§ 102(a), 102(b), and/or 102(e).
`22. U.S. Patent No. 6,220,360 (“Connell et al, ’360 Patent”)(filed March 9, 2000)(issued
`April 24, 2001) is prior art under §§ 102(a), 102(b), and/or 102(e).
`23. U.S. Patent No. 6,253,861 (“Carmichael et al, ’861 Patent”)(filed February 25,
`1999)(issued July 3, 2001) is prior art under §§ 102(a), 102(b), and/or 102(e).
`24. U.S. Patent No. 6,302,199 (“Hawkins et al, ’199 Patent”)(filed April 26, 2000)(issued
`October 16, 2001) is prior art under §§ 102(a), 102(b), and/or 102(e).
`25. U.S. Patent No. 6,390,200 (“Allamon et al, ’200 Patent”)(filed March 17, 2000)(issued
`May 21, 2002) is prior art under §§ 102(a), 102(b), and/or 102(e).
`26. U.S. Patent No. 4,519,456 (“Cochran ’456 Patent”)(filed August 13, 1984)(issued May
`28, 1985) is prior art under §§ 102(a), 102(b), and/or 102(e).
`27. U.S. Patent No. 4,099,563 (“Hutchison ’563 Patent”)(filed March 31, 1977)(issued July
`11, 1978) is prior art under §§ 102(a), 102(b), and/or 102(e).
`28. U.S. Patent No. 2,618,340 (“Lynd ’340 Patent”)(filed May 23, 1947)(issued November
`8, 1952) is prior art under §§ 102(a), 102(b), and/or 102(e).
`29. U.S. Patent No. 4,569,396 (“Brisco ’396 Patent”)(filed October 12, 1984)(issued
`February 11, 1986) is prior art under §§ 102(a), 102(b), and/or 102(e).
`30. U.S. Patent No. 4,903,777 (“Jordan, Jr. et al (Baugh), ’777 Patent”)(filed August 26,
`1987)(issued February 27, 1990) is prior art under §§ 102(a), 102(b), and/or 102(e).
`31. U.S. Patent No. 5,103,901 (“Greenlee ’891 Patent”)(filed October 12, 1990)(issued
`April 14, 1992) is prior art under §§ 102(a), 102(b), and/or 102(e).
`32. U.S. Patent No. 2,737,244 (“Baker et al, ’244 Patent”)(filed April 25, 1952)(issued
`March 6, 1956) is prior art under §§ 102(a), 102(b), and/or 102(e).
`33. U.S. Patent No. 3,148,731 (“Holden ’731 Patent”)(filed August 2, 1961)(issued
`September 15, 1964) is prior art under §§ 102(a), 102(b), and/or 102(e).
`34. U.S. Patent No. 3,289,762 (“Schell ’762 Patent”)(filed December 26, 1963)(issued
`December 6, 1966) is prior art under §§ 102(a), 102(b), and/or 102(e).
`35. U.S. Patent No. 4,967,841 (“Murray ’841 Patent”)(filed February 9, 1989)(issued
`November 6, 1990) is prior art under §§ 102(a), 102(b), and/or 102(e).
`36. U.S. Patent No. 6,467,546 (“Allamon ’546 Patent”)(filed March 14, 2001)(issued
`October 22, 2002) is prior art under §§ 102(a), 102(b), and/or 102(e).
`37. WO 01/06086 (“Churchill ’086 Patent”)(filed July 14, 2000)(publication date January
`25, 2001) is prior art under §§ 102(a), 102(b), and/or 102(e).
`38. WO 01/69036 (“Giroux et al, ’036 Patent”)(filed March 12, 2001)(publication date
`September 20, 2001) is prior art under §§ 102(a), 102(b), and/or 102(e).
`39. U.S. Patent No. 1,956,694 (“Parrish ’694 Patent”)(filed May 14, 1932)(issued May 1,
`1934) is prior art under §§ 102(a), 102(b), and/or 102(e).
`40. U.S. Patent No. 2,860,489 (“Townsend ’489 Patent”)(filed September 8, 1953)(issued
`November 18, 1958) is prior art under §§ 102(a), 102(b), and/or 102(e).
`41. U.S. Patent No. 4,714,117 (“Dech ’117 Patent”)(filed April 20, 1987)(issued December
`22, 1987) is prior art under §§ 102(a), 102(b), and/or 102(e).
`42. U.S. Patent No. 4,791,992 (“Greenlee et al, ’992 Patent”)(filed August 18, 1987)(issued
`December 20, 1988) is prior art under §§ 102(a), 102(b), and/or 102(e).
`43. U.S. Patent No. 3,007,523 (“Vincent ’523 Patent”)(filed October 8, 1958)(issued
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`Prior Art Patents/Published Applications
`November 7, 1961) is prior art under §§ 102(a), 102(b), and/or 102(e).
`44. U.S. Patent No. 5,174,379 (“Whiteley et al, ’379 Patent”)(filed February 11,
`1991)(issued December 29, 1992) is prior art under §§ 102(a), 102(b), and/or 102(e).
`45. U.S. Patent No. 5,048,611 (“Cochran ’611 Patent”)(filed June 4, 1990)(issued
`September 17, 1991) is prior art under §§ 102(a), 102(b), and/or 102(e).
`46. U.S. Patent No. 4,498,536 (“Ross et al ’611 Patent”)(filed October 3, 1983)(issued
`February 12, 1985) is prior art under §§ 102(a), 102(b), and/or 102(e).
`47. U.S. Patent No. 5,533,571 (“Surjaatmadja et al, ’571 Patent”)(filed May 27,
`1994)(issued July 9, 1996) is prior art under §§ 102(a), 102(b), and/or 102(e).
`48. U.S. Patent No. 958,100 (“Decker ’100 Patent”)(filed September 25, 1906)(issued May
`17, 1910) is prior art under §§ 102(a), 102(b), and/or 102(e).
`49. U.S. Patent No. 2,287,076 (“Zachry ’076 Patent”)(filed December 26, 1940)(issued June
`23, 1942) is prior art under §§ 102(a), 102(b), and/or 102(e).
`50. U.S. Patent No. 4,299,287 (“Vann et al, ’287 Patent”)(filed May 19, 1980)(issued
`November 10, 1981) is prior art under §§ 102(a), 102(b), and/or 102(e).
`51. GB 2311315A (“Smith ’315 Patent”) (filed on March 24, 1997) (publication date
`September 24, 1997) is prior art under §§ 102(a), 102(b), and/or 102(e).
`52. WO 1997036089 (“Appleton ’089 Patent”)(filed March 24, 1997)(publication date
`October 2, 1997) is prior art under §§ 102(a), 102(b), and/or 102(e).
`53. U.S. Patent No. 3,587,736 (“Brown ’736 Patent”)(filed April 9, 1970)(issued June 28,
`1971) is prior art under §§ 102(a), 102(b), and/or 102(e).
`54. EP 0724065A2 (“Crow, et al, ’065 Patent”) (filed January 29, 1996)(published July 31,
`1996) is prior art under §§ 102(a), 102(b), and/or 102(e).
`55. EP 0950794A2 (“Mullen, et al, ’794 Patent”) (filed April 14, 1999)(published October
`20, 1999) is prior art under §§ 102(a), 102(b), and/or 102(e).
`56. U.S. Patent No. 5,337,808 (“Graham ’808 Patent”)(filed November 20, 1992)(issued
`August 16, 1994) is prior art under §§ 102(a), 102(b), and/or 102(e).
`57. U.S. Patent No. 5,954,133 (“Ross ’133 Patent”)(filed September 12, 1996)(issued
`September 21, 1999) is prior art under §§ 102(a), 102(b), and/or 102(e).
`58. U.S. Patent No. 6,059,033 (“Ross et al, ’033 Patent”)(filed August 11, 1999)(issued
`May 9, 2000) is prior art under §§ 102(a), 102(b), and/or 102(e).
`59. U.S. Patent No. 6,186,236 (“Cox ’236 Patent”)(filed September 21, 1999)(issued
`February 13, 2001) is prior art under §§ 102(a), 102(b), and/or 102(e).
`60. U.S. Patent Publication No. 2001/050170A1 (“Woie et al, ’0170 Published App”)(filed
`January 5, 2001)(published December 13, 2001) is prior art under §§ 102(a), 102(b),
`and/or 102(e).
`61. U.S. Patent Publication No. 2002/096328A1 (“Echols et al, ’6328 Published App”)(filed
`January 23, 2001)(published July 25, 2002) is prior art under §§ 102(a), 102(b), and/or
`102(e).
`62. U.S. Patent Publication No. 2002/0117301A1 (“Womble, ’7301 Published App”)(filed
`February 26, 2001)(published August 29, 2002) is prior art under §§ 102(a), 102(b),
`and/or 102(e).
`63. EP 0094170A2 (“Harris, et al, ’170 Patent”) (filed April 25, 1983)(published November
`16, 1983) is prior art under §§ 102(a), 102(b), and/or 102(e).
`64. EP 0802303A1 (“Echols, et al, ’303 Patent”) (filed April 11, 1997)(published October
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`Prior Art Patents/Published Applications
`22, 1997) is prior art under §§ 102(a), 102(b), and/or 102(e).
`65. EP 00985799A2 (“Webb, ’799 Patent”) (filed September 1, 1999)(published March 15,
`2000) is prior art under §§ 102(a), 102(b), and/or 102(e).
`66. U.S. Patent No. 3,659,648 (“Cobbs, ’648 Patent”)(filed December 10, 1970)(issued May
`2, 1972) is prior art under §§ 102(a), 102(b), and/or 102(e).
`67. U.S. Patent No. 4,605,062 (“Klumpyan et al, ’062 Patent”)(filed June 10, 1985)(issued
`August 12, 1986) is prior art under §§ 102(a), 102(b), and/or 102(e).
`68. U.S. Patent No. 5,335,732 (“McIntyre, ’033 Patent”)(filed December 29, 1992)(issued
`August 9, 1994) is prior art under §§ 102(a), 102(b), and/or 102(e).
`69. U.S. Patent Publication No. 2001/015275A1 (“van Petgem et al, ’5275 Published
`App”)(filed January 4, 2001)(published August 23, 2001) is prior art under §§ 102(a),
`102(b), and/or 102(e).
`70. U.S. Patent Publication No. 2006/048950A1 (“Dybevik et al, ’8950 Published
`App”)(filed October 17, 2003)(published March 9, 2006) is prior art under §§ 102(a),
`102(b), and/or 102(e).
`71. U.S. Patent Publication No. 2008/017373A1 (“Jones et al, ’7373 Published App”)(filed
`October 3, 2007)(published January 24, 2008) is prior art under §§ 102(a), 102(b),
`and/or 102(e).
`72. EP 0823538A2 (“Ross, et al, ’538 Patent”) (filed August 8, 1997)(published February
`11, 1998) is prior art under §§ 102(a), 102(b), and/or 102(e).
`73. U.S. Patent No. 2,212,087 (“Thornhill, ’087 Patent”)(filed November 27, 1939)(issued
`August 20, 1940) is prior art under §§ 102(a), 102(b), and/or 102(e).
`74. U.S. Patent No. 2,947,363 (“Sackett, et al, ’363 Patent”)(filed November 21,
`1955)(issued August 2, 1960) is prior art under §§ 102(a), 102(b), and/or 102(e).
`75. U.S. Patent No. 3,263,752 (“Conrad, ’752 Patent”)(filed May 14, 1962)(issued August
`2, 1966) is prior art under §§ 102(a), 102(b), and/or 102(e).
`76. U.S. Patent No. 5,479,989 (“Shy, et al, ’989 Patent”)(filed July 12, 1994)(issued January
`2, 1996) is prior art under §§ 102(a), 102(b), and/or 102(e).
`77. U.S. Patent Publication No. 2002/0007949A1 (“Tolman et al, ’7949 Published
`App”)(filed June 25, 2001)(published January 24, 2002) is prior art under §§ 102(a),
`102(b), and/or 102(e).
`78. U.S. Patent No. 2,153,034 (“Baker, ’034 Patent”)(filed October 10, 1936)(issued April
`4, 1939) is prior art under §§ 102(a), 102(b), and/or 102(e).
`79. U.S. Patent No. 2,659,438 (“Schnitter, ’989 Patent”)(filed August 16, 1946)(issued
`November 17, 1953) is prior art under §§ 102(a), 102(b), and/or 102(e).
`80. U.S. Patent No. 2,869,645 (“Chamberlain, et al, ’645 Patent”)(filed December 8,
`1954)(issued January 20, 1959) is prior art under §§ 102(a), 102(b), and/or 102(e).
`81. U.S. Patent No. 3,291,219 (“Nutter, ’219 Patent”)(filed November 6, 1964)(issued
`December 13, 1966) is prior art under §§ 102(a), 102(b), and/or 102(e).
`82. U.S. Patent No. 3,645,335 (“Current, ’335 Patent”)(filed November 27, 1970) (issued
`February 29, 1972) is prior art under §§ 102(a), 102(b), and/or 102(e).
`83. U.S. Patent No. 3,661,207 (“Current, et al, ’207 Patent”)(filed November 27,
`1970)(issued May 9, 1972) is prior art under §§ 102(a), 102(b), and/or 102(e).
`84. U.S. Patent No. 3,687,202 (“Young, et al, ’202 Patent”)(filed December 28,
`1970)(issued August 29, 1972) is prior art under §§ 102(a), 102(b), and/or 102(e).
`
`9
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`9 of 84
`
`Exhibit 2022
`IPR2016-01517
`
`

`
`
`
`
`
`Prior Art Patents/Published Applications
`85. U.S. Patent No. 4,161,216 (“Amancharla, ’216 Patent”)(filed September 27,
`1978)(issued July 17, 1979) is prior art under §§ 102(a), 102(b), and/or 102(e).
`86. U.S. Patent No. 4,423,777 (“Mullins, et al, ’777 Patent”)(filed October 2, 1981)(issued
`January 3, 1984) is prior art under §§ 102(a), 102(b), and/or 102(e).
`87. U.S. Patent No. 5,146,992 (“Baugh, ’992 Patent”)(filed August 8, 1991)(issued
`September 15, 1992) is prior art under §§ 102(a), 102(b), and/or 102(e).
`88. U.S. Patent No. 5,242,022 (“Burton, et al, ’022 Patent”)(filed August 5, 1991)(issued
`September 7, 1993) is prior art under §§ 102(a), 102(b), and/or 102(e).
`89. U.S. Patent No. 5,261,492 (“Duell, et al, ’492 Patent”)(filed March 31, 1992)(issued
`November 16, 1993) is prior art under §§ 102(a), 102(b), and/or 102(e).
`90. U.S. Patent No. 5,332,038 (“Tapp, et al, ’038 Patent”)(filed August 6, 1992)(issued July
`26, 1994) is prior art under §§ 102(a), 102(b), and/or 102(e).
`91. U.S. Patent No. 5,413,180 (“Ross, et al, ’180 Patent”)(filed July 30, 1993)(issued May
`9, 1995) is prior art under §§ 102(a), 102(b), and/or 102(e).
`92. U.S. Patent No. 5,425,423 (“Dobson, et al, ’423 Patent”)(filed March 22, 1994)(issued
`June 20, 1995) is prior art under §§ 102(a), 102(b), and/or 102(e).
`93. U.S. Patent No. 5,464,062 (“Blizzard, Jr, ’062 Patent”)(filed October 12, 1994)(issued
`November 7, 1995) is prior art under §§ 102(a), 102(b), and/or 102(e).
`94. U.S. Patent No. 5,558,153 (“Holcombe, et al, ’153 Patent”)(filed October 20,
`1994)(issued September 24, 1996) is prior art under §§ 102(a), 102(b), and/or 102(e).
`95. U.S. Patent No. 5,641,023 (“Ross, et al, ’023 Patent”)(filed August 3, 1995)(issued June
`24, 1997) is prior art under §§ 102(a), 102(b), and/or 102(e).
`96. U.S. Patent No. 6,257,338 (“Kilgore, ’338 Patent”)(filed November 2, 1998)(issued July
`10, 2001) is prior art under §§ 102(a), 102(b), and/or 102(e).
`97. U.S. Patent No. 6,305,470 (“Woie, ’470 Patent”)(filed April 6, 1998)(issued October 23,
`2001) is prior art under §§ 102(a), 102(b), and/or 102(e).
`98. U.S. Patent No. 2,593,520 (“Baker, et al, ’520 Patent”)(filed October 11, 1945)(issued
`April 22, 1952) is prior art under §§ 102(a), 102(b), and/or 102(e).
`99. U.S. Patent No. 3,361,209 (“Edwards, Jr, ’209 Patent”)(filed February 23, 1966)(issued
`January 2, 1968) is prior art under §§ 102(a), 102(b), and/or 102(e).
`100. U.S. Patent No. 4,979,561(“Szarka, ’561 Patent”)(filed November 8, 1989)(issued
`December 25, 1990) is prior art under §§ 102(a), 102(b), and/or 102(e).
`101. U.S. Patent No. 4,991,654 (“Brandell, et al, ’654 Patent”)(filed November 8,
`1989)(issued February 12, 1991) is prior art under §§ 102(a), 102(b), and/or 102(e).
`102. U.S. Patent No. 5,355,953 (“Shy, et al, ’953 Patent”)(filed February 9, 1994)(issued
`October 18, 1994) is prior art under §§ 102(a), 102(b), and/or 102(e).
`103. U.S. Patent No. 5,394,941 (“Venditto, et al, ’941 Patent”)(filed June 21, 1993)(issued
`March 7, 1995) is prior art under §§ 102(a), 102(b), and/or 102(e).
`104. U.S. Patent No. 5,921,318 (“Ross, ’318 Patent”)(filed April 21, 1997)(issued July 13,
`1999) is prior art under §§ 102(a), 102(b), and/or 102(e).
`105. U.S. Patent No. 6,003,607 (“Hagen, et al, ’607 Patent”)(filed September 12,
`1996)(issued December 21, 1999) is prior art under §§ 102(a), 102(b), and/or 102(e).
`106. U.S. Patent No. 6,155,350 (“Melenyzer, ’350 Patent”)(filed May 3, 1999)(issued
`December 5, 2000) is prior art under §§ 102(a), 102(b), and/or 102(e).
`107. U.S. Patent No. 6,394,184 (“Tolman, et al, ’184 Patent”)(filed February 21,
`10
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`10 of 84
`
`Exhibit 2022
`IPR2016-01517
`
`

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`
`
`Prior Art Patents/Published Applications
`2001)(issued May 28, 2002) is prior art under §§ 102(a), 102(b), and/or 102(e).
`108. U.S. Patent No. 6,543,538 (“Tolman, et al, ’538 Patent”)(filed June 25, 2001)(issued
`April 8, 2003) is prior art under §§ 102(a), 102(b), and/or 102(e).
`109. U.S. Patent No. 3,068,942 (“Brown, ’942 Patent”)(filed December 7, 1959)(issued
`December 18, 1962) is prior art under §§ 102(a), 102(b), and/or 102(e).
`110. U.S. Patent No. 4,590,995 (“Evans, ’995 Patent”)(filed March 26, 1985)(issued May 27,
`1986) is prior art under §§ 102(a), 102(b), and/or 102(e).
`111. U.S. Patent No. 2,764,244 (“Page, ’244 Patent”)(filed April 14, 1952)(issued September
`25, 1956) is prior art under §§ 102(a), 102(b), and/or 102(e).
`112. U.S. Patent No. 3,860,068 (“Abney, ’068 Patent”)(filed Nov. 1, 1973)(issued Jan. 14,
`1975) is prior art under §§ 102(a), 102(b), and/or 102(e).
`113. U.S. Patent No. 3,517,743 (“Pumpelly, ’743 Patent”)(filed Dec. 13, 1968)(issued June
`30, 1970) is prior art under §§ 102(a), 102(b), and/or 102(e).
`114. U.S. Patent No. 2,493,650 (“Baker, ’650 Patent”)(filed March 1, 1945)(issued Jan 3,
`1950) is prior art under §§ 102(a), 102(b), and/or 102(e).
`115. U.S. Patent No. 2,121,002 (filed Oct. 10, 1936)(issued Jun. 21, 1938) is prior art under
`§§ 102(a), 102(b), and/or 102(e).
`116. U.S. Patent No. 2,330,267 (filed Apr. 3, 1942)(issued Sept. 28, 1943) is prior art under
`§§ 102(a), 102(b), and/or 102(e).
`117. U.S. Patent No. 2,836,250 (filed Dec. 24, 1952)(issued May 27, 1958) is prior art under
`§§ 102(a), 102(b), and/or 102(e).
`118. U.S. Patent No. 3,059,699 (filed Apr. 17, 1958)(issued Oct. 23, 1962) is prior art under
`§§ 102(a), 102(b), and/or 102(e).
`119. U.S. Patent No. 4,044,826 (filed May 17, 1976)(issued Aug. 30, 1977) is prior art under
`§§ 102(a), 102(b), and/or 102(e).
`120. U.S. Patent No. 4,552,218 (filed Sept. 26, 1983)(issued Nov. 12, 1985) is prior art under
`§§ 102(a), 102(b), and/or 102(e).
`121. U.S. Patent No. 4,657,084 (filed Sept. 17, 1985)(issued Apr. 14, 1987) is prior art under
`§§ 102(a), 102(b), and/or 102(e).
`122. U.S. Patent No. 4,754,812 (filed Mar. 23, 1987)(issued Jul. 5, 1988) is prior art under §§
`102(a), 102(b), and/or 102(e).
`123. U.S. Patent No. 5,454,430 (filed Jan. 26, 1994)(issued Oct. 3, 1995) is prior art under §§
`102(a), 102(b), and/or 102(e).
`124. U.S. Patent No. 5,472,048 (filed Jan. 26, 1994)(issued Dec. 5, 1995) is prior art under §§
`102(a), 102(b), and/or 102(e).
`125. U.S. Patent No. 5,526,880 (filed Sept. 15, 1994)(issued Jun. 18, 1996) is prior art under
`§§ 102(a), 102(b), and/or 102(e).
`126. U.S. Patent No. 5,533,573 (filed Mar. 2, 1995)(issued Jul. 9, 1996) is prior art under §§
`102(a), 102(b), and/or 102(e).
`127. U.S. Patent No. 5,609,178 (filed Sept. 28, 1995)(issued Mar. 11, 1997) is prior art under
`§§ 102(a), 102(b), and/or 102(e).
`128. U.S. Patent No. 5,810,082 (filed Aug. 30, 1996)(issued Sept. 22, 1998) is prior art under
`§§ 102(a), 102(b), and/or 102(e).
`129. U.S. Patent No. 6,131,663 (filed Jun. 10, 1998)(issued Oct. 17, 2000) is prior art under
`§§ 102(a), 102(b), and/or 102(e).
`
`11
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`11 of 84
`
`Exhibit 2022
`IPR2016-01517
`
`

`
`
`
`
`
`Prior Art Patents/Published Applications
`130. U.S. Patent No. 7,152,678 (filed Feb. 27, 2004)(issued Dec. 26, 2006) is prior art under
`§§ 102(a), 102(b), and/or 102(e).
`131. U.S. Patent No. 5,020,600 (filed Apr. 28, 1989)(issued Jun. 4, 1991) is prior art under
`§§ 102(a), 102(b), and/or 102(e).
`132. U.S. Patent No. 4,640,355 (filed March 26, 1985) (issued February 3, 1987) is prior art
`under §§ 102(a), 102(b), and/or 102(e).
`
`133. U.S. Patent No. 4,893,678 (filed December 30, 1988) (issued January 16, 1990) is prior
`art under §§ 102(a), 102(b), and/or 102(e).
`134. U.S. Patent No. 4,823,882 (filed June 8, 1988) (issued April 25, 1989) is prior art under
`§§ 102(a), 102(b), and/or 102(e).
`135. U.S. Patent No. 6,634,428 (filed May 3, 2001) (issued October, 21, 2003) is prior art
`under §§ 102(a), 102(b), and/or 102(e).
`136. U.S. Patent No. 4,655,286 (filed February 19, 1985) (issued April 7, 1987) is prior art
`under §§ 102(a), 102(b), and/or 102(e).
`137. U.S. Patent No. 4,338,999 (filed February 19, 1980) (issued July 13, 2982) is prior art
`under §§ 102(a), 102(b), and/or 102(e).
`138. U.S. Patent No. 3,427,653 (filed July 28, 1967) (issued February 11, 1969) is prior art
`under §§ 102(a), 102(b), and/or 102(e).
`139. U.S. Patent No. 4,229,397 (filed January 9, 1981) (issued November 10, 1981) is prior
`art under §§ 102(a), 102(b), and/or 102(e).
`140. U.S. Patent No. 4,421,165 (filed July 15, 1980) (issued December 20, 1983) i