SUPPLEMENTAL
`
`SUPPLEMENTAL
`EXHIBIT D-6
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`EXHIBIT D-6
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`1 of 158
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`Exhibit 2033
`Exhibit 2033
`IPR2016-01517
`0000000000 17
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`

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`U.S. Patent 7,861,774 – Invalidity in view of Lane Wells Products
`
`
`Lane Wells Documentary and Product Art, showing combinations of packers and sliding sleeves by Lane Wells (“Lane Wells
`Products”), qualifies as prior art under at least 35 U.S.C. §§ 102(a), (b), (f), and (g)(2) as sold, publicly used, publicly known, invented
`by others, and shown in printed publications. See, e.g., Composite Catalog from 1956 at DEFINV00007411 (“1956 Composite
`Catalog”), Lane Wells Tubing Port Valve Brochure at DEFINV00008171 (“Tubing Port Valve Brochure”), Lane Wells Packer
`Handbook at DEFINV00007955 (“Packers Handbook”), Lane Wells Packers Brochure from 1956 at DEFINV00007890 (“Packers
`Brochure”), Lane Wells’ pamphlet on “The Use of Packers In Acidizing Operations” at DEFINV00008194 (“Acidizing Pamphlet”),
`US Pat. No. 2,387,003 (“Barnes”) at DEFINV00008293, US Pat. No. 2,618,340 (“Lynd”) at RC_RAP00003173, and US Pat. No.
`2,005,955 (“Renouf”). The Lane Wells Products anticipate and/or render obvious the asserted claims of the 774 Patent, alone or in
`combination with other prior art as identified in Defendant’s Invalidity Contentions, including:
`
`
`- RockSeal and RockSeal II Packers, as well as the RockSeal System, by Packers Plus, as sold, publicly used, and shown in
`printed publications. See, e.g., July 23, 2008 Declaration of Daniel J Themig (“Themig Declaration”); “5.1 RockSeal™ II
`Open Hole Packer Series” advertisement from Packers Plus’ website available at Dkt. 59-2 (“Website”); RC_PAC00021933,
`RC_PAC00063156, RC_PAC00018079, and RC_PAC00002017.
`- Wizard Packer and Sliding Sleeve System by Guiberson / Halliburton (“Wizard System”), as sold, publicly used, and shown in
`printed publications. See, e.g., Halliburton Completions Products guide from July 1999 (“Wizard Brochure”); see also Wizard
`II Hydraulic Set Retrievable Packer, Tech Manual, April 1998 (“Tech Manual”); “Multilateral and Horizontal Completions,
`Wizard Packer - A Revolution in Open Hole Packers, The Wizard Packer Provides Outstanding Performance in Open Hole,”
`Dresser Oil Tools (“Wizard Marketing”).
`- Polar Bearfoot Packer, as sold, publicly used, and shown in printed publications. See, e.g., Bearfoot Packer 652-0000
`Datasheet; Polar Completions Engineering Inc. Technical Manual, July 5, 2001, Rev. 1; Polar Completions Engineering Inc.
`Technical Manual, July 5, 2001, Rev. 2; Article entitled “Polar is the Completions Company,” pp. 18-22.
`- U.S. Patent No. 6,006,838 (“Whiteley”), issued Dec. 28, 1999.
`- U.S. Patent No. 6,315,041 (“Carlisle”), which was filed April 15, 1999 and issued November 13, 2001.
`- “Design and Installation of a Cost Effective Completion System For Horizontal Chalk Wells Where Multiple Zones Require
`Acid Stimulation”, D.W. Thomson and M.F. Nazroo, Offshore Technology Conference, May 5-8, 1997, Pages 323-335, OTC
`8472 and related publications1 (“Halliburton,” “Halliburton II,” and “Halliburton III”).
`
`1 Note, for purposes of determining limits on prior art, the charted reference, and the similar articles: (1) “Design and Installation of a Cost Effective Completion
`System For Horizontal Chalk Wells Where Multiple Zones Require Acid Stimulation”, D.W. Thomson and M.F. Nazroo, SPE Drilling & Completion September
`1998, pages 151-156; SPE 51177 (“Halliburton II”) and (2) “Design and Installation of a Cost Effective Completion System For Horizontal Chalk Wells Where
`Multiple Zones Require Acid Stimulation”, D.W. Thomson and M.F. Nazroo, 1997 SPE Production Operations Symposium, March 9-11, 1997, pages 97-108,
`1
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`- U.S. Patent 2,537,066 (“Lewis”), issued Jan. 9, 1951.
`- The multi-stage fracture performed at the RET #1 well in Wayne County, West Virginia and the related publications that
`describe that completion such as “Production and Stimulation Analysis of Multiple Hydraulic Fracturing of a 2,000-ft
`Horizontal Well”, A.B. Yost II, Gas Technology Symposium, June 7–9, 1989, SPE 19090 (“Yost”).
`- “Innovative Acid Fracturing Operations Used to Successfully Stimulate Central North Sea Reservoir”, A.N. Martin, SPE
`Annual Technical Conference, Oct. 6-9, 1996, Pages 479-486, 36620 (“Martin”).
`- Production Control of Horizontal Wells in a Carbonate Reef Structure, Bill Ellsworth et al., 1999 CIM Horizontal Well
`Conference (“Ellsworth”), published by 1999.
`- US Pat. No. 3,062,291 to “Brown,” filed May 11, 1959 and issued Nov. 6, 1962.
`- 2001 MPas Packer documents (RC_PAC00056250-272; RC_PAC00056275-279) (“MPas”).
`
`
`
`These invalidity contentions are not an admission by Defendants that the accused products, including any current or past versions of
`these products, are covered by or infringe any claim, particularly when the claim is properly construed. Nor shall these invalidity
`contentions be construed as an admission that Defendant agrees with any claim construction promoted by Rapid Completions to
`support its infringement contentions. The citations herein are exemplary, and should not be viewed as a limitation on Defendants’
`invalidity positions; Defendants reserve the right to further edit these invalidity contentions should the need arise (e.g., when
`additional evidence becomes available).
`
`
`
`774 Patent
`[1pre] A method for fracturing a
`hydrocarbon-containing formation
`accessible through a wellbore, the
`method comprising:
`
`Lane Wells Products
`The Lane Wells Products, alone or in combination with other analogous art, embody a method
`for fracturing a hydrocarbon-containing formation accessible through a wellbore.
`
`The Lane Wells Products were intentionally placed into wellbores through hydrocarbon-
`containing formations for the production of hydrocarbons. The Lane Wells Products include a
`Tubing Port Valve and packers that were used to increase the production of hydrocarbons from
`the hydrocarbon-containing formations, for example, by acidizing zones, a procedure that may
`be used to fracture a hydrocarbon-containing formation accessible through a wellbore.
`
`
`The Lane-Wells Tubing Port Valve is used primarily to displace fluids in the
`
`SPE 37482 (“Halliburton III”) count as a single prior art reference under General Order GO-13-20, Footnote 2 because they are the “closely related work of a
`single prior artist.”
`
`
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`774 Patent
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`Lane Wells Products
`annulus above a packer. When formation pressures are such that heavy fluids in
`the well cannot be displaced prior to setting a packer, the installation of the
`Tubing Port Valve is needed. After Tubing Port Valve is placed in tubing string
`above packer and run in, the packer is set and the well head closed in. With the
`well secure, a ball is dropped through the tubing to seat in the Tubing Port Valve.
`Flow through the tubing is stopped and pump pressure build-up causes spring to
`compress which opens side ports. This inside out circulation allows safe
`displacement of fluids in the annulus.
`
`The Tubing Port Valve also provides a means of acidizing two zones with packer
`setting in either open-hole or cased hole completions. Three zone acidizing is
`possible with a three packer set-up and two different sized Tubing Port Valves.
`
`1956 Composite Catalog at 2854.
`
`
`Lane-Wells Tubing Port Valve has been known by various names including
`acidizing valve, flow diversion valve, and drop ball circulation valve. Perhaps the
`reason for these names can be found in the fact that the tool has been so versatile
`in solving sundry oil field situations, that the many application names were
`associated with the tool.
`
`However well these names describe the tool in relation to an application, they still
`tend to limit the tool to that application, which is contrary to fact. The fact is that
`the Tubing Port Valve is a diversified and versatile tool applicable to many oil
`field situations.
`
`Tubing Port Valve Brochure at 2.
`
`Stage Acidizing
`
`Frequently limestone producing horizons respond much better to stage treatments
`of acid instead of single treatments. This type of acidizing operation may be more
`readily accomplished when a Tubing Port Valve is used in the string above a
`
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`774 Patent
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`Lane Wells Products
`packer or between two packers. The advantage lies in the ability to remove the
`spent acid and products of reaction between stage treatments without having to
`disturb packer settings.
`
`In cased hole acidizing through perforation, this flexible arrangement permits a
`variety of completion and testing operations without tubing manipulation.
`However, the bigger advantage is noted in open hole selective stage acidizing
`because when a satisfactory pack-off is obtained, it is particularly desirable to
`maintain this seal until all treatments have been finished, and the well is ready to
`produce.
`
`Tubing Port Valve Brochure at 3.
`
`
`USE OF THE LANE-WELLS DROP BALL
`CIRCULATION SUB
`(Acidizing Valve)
`
`The Lane-Wells Drop Ball Circulation Sub (better known as the acidizing valve)
`was de- signed to provide a means of acidizing two zones with one packer setting
`in either open-hole or cased-hole completion. The zone below the packer is
`acidized in the normal manner, and the upper zone above the packer is acidized
`through ports in a special acidizing valve.
`
`The essential part of the circulation sub are the outer body, in which are located
`the ports or circulation channels, the inner piston held in place closing the ports
`by a coiled spring, and a ball of sufficient diameter to close the throat section
`through the piston. A snap locking ring may or may not be included around the
`piston to hold it in the “open-port” position after the ball has been dropped.
`
`Procedure: The acidizing valve is placed in the tubing string above the packer.
`After the tubing is run and the packer set, the zone below the packer is acidized.
`During the acidizing of the lower zone, the acidizing valve remains in the closed
`port position permitting fluid flow through the throat of the piston. (Figure 3.1-10)
`
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`774 Patent
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`Lane Wells Products
`Upon completion of lower zone acidization and reaction product removal, the ball
`is dropped. When the ball is seated on the piston, pump pressure is applied to
`open, the ports. Sufficient pump pressure to overcome the effect of the coiled
`spring is necessary to force the piston down below the ports. The upper zone can
`now be acidized and reaction products circulated out. (Figure 3.1-11) This
`procedure does not require the snap locking ring, Ports are kept open by pump
`pressure during all steps of the upper zone acidization.
`
`Acidizing Pamphlet 3.1-7–3.1-9.
`
`Use of Packers in Acidizing Operations:
`
`Of all the possible variations in well conditions, there are only a few in which a
`packer would not be an effective aid in the acidizing operation.
`
`The main objective in acidizing a well is to enlarge the drainage channels of the
`reservoir formation, clean these channels of obstructions, open new channels or
`lines of flow to the well bore, which in turn increases gas or oil production.
`
`Because acid tends to follow the path of least resistance, packers are used to direct
`the course of the acid to the desired place and at the same time keep it from
`entering zones where it would be harmful. With this in mind, it is easy to
`visualize how single packer or dual packer arrangements to form a straddle tool
`can restrict the acid to its proper area of work. In the acidizing operation it is also
`necessary to have a sealing element that will maintain the seal against extreme
`pressures as acid is forced into the formation. The Lane-Wells packing element is
`designed to resist the corrosive effect of acid and maintain a positive pack-off
`under all acidizing operations.
`
`Packers Brochure at 9.
`
`Under the term FORMATION BREAK-DOWN OPERATIONS we aim to
`include under one heading all operations such as acidizing, hydra-frac, sand-frac,
`
`
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`774 Patent
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`Lane Wells Products
`etc., when it is necessary to put up sufficient pressure inside the casing to
`overcome the formation pressure and force different liquids, some carrying solids,
`into the spaces existing in the formation.
`
`Such operations are invariably accomplished through the use of one or more
`packers, possibly other special tools and the tubing string on which they are run.
`
`Packers Handbook at 85.
`
`This preamble is literally present in the Lane Wells products. Additionally, to the extent Lane
`Wells is not deemed to literally teach a method for fracturing a hydrocarbon-containing
`formation accessible through a wellbore, it would have been obvious to one skilled in the art that
`the methods and tools taught by the Lane Wells Products may be used to fracture a hydrocarbon-
`containing formation accessible through a wellbore. This preamble is also taught in other,
`similar references that one skilled in the art could combine with the Lane Wells Products to
`achieve predictable results.
`
`For example, Halliburton teaches a method for fracturing a hydrocarbon-containing formation
`accessible through a wellbore. Like the Lane Wells Products, Halliburton is directed to the
`completion of oil and gas wells, including stimulation. The wells described in the Halliburton
`reference are intentionally placed into hydrocarbon-containing formations for the production of
`hydrocarbons. The purpose of the stimulations described in Halliburton is to increase the
`production of hydrocarbons from the hydrocarbon-containing formations (e.g., reservoirs) in
`which the wells are placed. It would have been obvious to one skilled in the art that the Lane
`Wells Products and Halliburton can be combined to teach a method for fracturing a hydrocarbon-
`containing formation accessible through a wellbore.
`
`
`Design and Installation of a Cost-Effective Completion System for Horizontal
`Chalk Wells Where Multiple Zones Require Acid Stimulation.
`
`Halliburton at Title. See also Halliburton II at Title; Halliburton III at Title.
`
`
`Summary – An innovative completion design that allows multiple acid fracs to be
`
`
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`774 Patent
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`Lane Wells Products
`performed in horizontal subsea chalk-formation wells with a single trip into the
`wellbore has recently been codeveloped by a major North Sea operator and an
`oilfield engineering/manufacturing/service company. The project was initiated to
`develop a system that would allow multiple acid stimulations to be efficiently
`performed in the shortest possible time in the North Sea Joanne field. The system
`ultimately developed allows acid stimulation of up to 10 different zones in a
`single trip with no through-tubing intervention.
`
`Halliburton at 323. See also Halliburton II at 151; Halliburton III at 97.
`
`
`By limiting the number of perforations in each group, it was expected that the
`pressure drop across the perforations would be sufficiently high to ensure that
`fractures would be initiated from each group of perforations. This would ensure
`that all the promising areas in the wells would be stimulated.
`
`Halliburton at 325.
`
`
`Summary – This technique provided a substantial reduction in the operation time
`normally required to stimulate multiple zones and allowed the stimulations to be
`precisely targeted within the reservoir. . . . Additionally, this completion method
`allowed the stimulations to be designed and matched to the requirements of each
`reservoir zone, which provided the most cost efficient treatments possible.
`
`
`Halliburton at 323. See also Halliburton II at 151; Halliburton III at 97.
`
`
`Additionally, it was felt that stimulation programs would be necessary to achieve
`the necessary production potentials.
`
`Halliburton at 323. See also Halliburton II at 151; Halliburton III at 97.
`
`
`This ensured that the most cost efficient treatments possible. Were applied and
`that there would be no compromise to the effectiveness of the procedures to
`
`
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`774 Patent
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`enhance production.
`
`Lane Wells Products
`
`Halliburton at 327. See also Halliburton II at 156; Halliburton III at 101.
`
`Other well-known art that one skilled in the art could combine with the Lane Wells Products to
`achieve predictable results includes, for example, U.S. Patent No. 6,315,041 (“Carlisle”), which
`was filed April 15, 1999 and issued November 13, 2001. Like the Lane Wells Products, Carlisle
`is directed to the completion of oil and gas wells, including stimulation. (Carlisle at “Field of the
`Invention”). Carlisle describes a similar method to that described in relation to the Lane Wells
`Products. (See Carlisle at 1:5-22). Carlisle also discloses the use of Wizard Packers for isolation
`(Carlisle at 1:43-47). Thus, it would have been obvious to a POSITA to combine the Carlisle
`and the Lane Wells Products to yield the predictable result of sealing off the annulus of the open
`wellbore to isolate zones of the formation for fracturing a hydrocarbon-containing formation in
`open hole.
`
`
`The field of oil and gas well stimulation sometimes involves wells with multiple
`horizontal laterals in a vertical well that are drilled to facilitate production from a
`formation. Some of the well laterals are substantially long, up to several thousand
`feet, and it is desirable to stimulate these horizontal well sections to increase their
`production. There are a number of stimulation methods, such as acidizing and
`fracturing.
`
`Carlisle at 1:15-22.
`
`
`There is another tool, the Wizard Packer from Dresser, that allows isolation of a
`horizontal well into preset lengths to facilitate stimulation of the formation, but it
`requires sending darts into the sections to open sliding sleeves which allow the
`treating fluid to enter into the isolated section.
`
`Carlisle at 1:43-47.
`
`Other well-known art that one skilled in the art could combine with the Lane Wells Products to
`achieve predictable results includes the Yost reference. It would have been obvious to a person
`
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`774 Patent
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`Lane Wells Products
`of ordinary skill in the art to combine the Lane Wells Products with Yost to achieve the
`predictable result of fracturing a hydrocarbon-containing formation accessible through a
`wellbore.
`
`Yost discloses that “The performance of multiple hydraulic fracturing treatments along a 2000-
`foot horizontal wellbore was completed in a gas bearing, naturally-fractured shale gas reservoir
`in Wayne County, West Virginia.” Yost at 321. Yost further notes:
`
`
`An alternative approach is zone isolation accomplished by the installation of
`external casing packers and port collars as an integral part of a casing string in the
`horizontal section. Such a completion arrangement provided stimulation intervals
`with ready-made perforations for injecting fracturing fluids in an open hole
`fracturing condition behind pipe. This was the method of completion used in this
`2000 foot horizontal well to avoid the problems of formation damage associated
`with cementing and to eliminate the need for tubing-conveyed perforating of
`numerous treatment intervals.
`
`SPE 19090 at 321.
`
`
`A series of stimulations were designed to open and propagate the many known
`natural fractures that existed along the 2000 foot length of horizontal wellbore.
`The stimulations were also designed to induce fractures in the formation as well
`as propagate natural fractures by manipulating pressure and injection rates.
`
`SPE 19090 at 322.
`
`
`[1a] running a tubing string into an
`open hole and uncased, non-
`vertical section of the wellbore,
`the tubing string having a long
`axis and an inner bore and
`comprising:
`
`The Lane Wells Products, alone or in combination with other analogous art, embody running a
`tubing string into an open hole and uncased, non-vertical section of the wellbore.
`
`Lane Wells Products (e.g., packers and Tubing Port Valves) were combined to from a tubing
`string having a long axis and an inner bore that was run into the open-hole and uncased, non-
`vertical section of wellbore.
`
`
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`

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`774 Patent
`
`
`
`Lane Wells Products
`
`The Lane-Wells Tubing Port Valve is used primarily to displace fluids in the
`annulus above a packer. When formation pressures are such that heavy fluids in
`the well cannot be displaced prior to setting a packer, the installation of the
`Tubing Port Valve is needed. After Tubing Port Valve is placed in tubing string
`above packer and run in, the packer is set and the well head closed in. With the
`well secure, a ball is dropped through the tubing to seat in the Tubing Port Valve.
`Flow through the tubing is stopped and pump pressure build-up causes spring to
`compress which opens side ports. This inside out circulation allows safe
`displacement of fluids in the annulus.
`
`The Tubing Port Valve also provides a means of acidizing two zones with packer
`setting in either open-hole or cased hole completions. Three zone acidizing is
`possible with a three packer set-up and two different sized Tubing Port Valves.
`
`1956 Composite Catalog at 2854.
`
`
`Under the term FORMATION BREAK-DOWN OPERATIONS we aim to
`include under one heading all operations such as acidizing, hydra-frac, sand-frac,
`etc., when it is necessary to put up sufficient pressure inside the casing to
`overcome the formation pressure and force different liquids, some carrying solids,
`into the spaces existing in the formation.
`
`Such operations are invariably accomplished through the use of one or more
`packers, possibly other special tools and the tubing string on which they are run.
`
`Packers Handbook at 85.
`
`While the Lane Wells Products alone are sufficient to anticipate or at least render obvious this
`limitation, one skilled in the art would understand that additional art may be combined with the
`Lane Wells Products to yield predictable results.
`
`This includes the US Pat. No. 3,062,291 to “Brown,” filed May 11, 1959 and issued Nov. 6,
`
`
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`774 Patent
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`Lane Wells Products
`1962. The Brown patent is prior art to the 774 patent. It would have been obvious to a person of
`ordinary skill in the art to combine the hydraulically-set packer of the Brown reference with the
`Lane Wells Products in open hole to yield the predictable result of sealing off the annulus of the
`wellbore to isolate zones of the formation for fluid treatment.
`
`
`
`
`Brown at Figure 2.
`
`
`Each of the assemblies 15 comprises the following successively arranged
`elements: an annular resilient seal element 17 constructed of rubber or other
`flexible resilient composition material abutting shoulders 11a and 11c; . . .
`
`Brown at 2:37-40.
`
`
`Body 10 has an axial bore 37 into which extends a tubular operating stem or
`mandrel, designated generally by the numeral 38.
`
`Brown at 3:33-34.
`
`
`When piston member 26 has moved downwardly in response to hydraulic
`pressure, as best seen in FIGS. 2 and 3, ball latches 75 will be released for
`movement outwardly of openings 73 into chamber 35 and when so released, it
`will be seen that the mandrel may be drawn upwardly relative to body 10.
`
`
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`774 Patent
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`Lane Wells Products
`
`Brown at 4:67-72.
`
`
`When plug 82 is in place, pumping of pressure fluid into the bore of the tubing
`and the operating mandrel will be conducted to build up fluid pressure interiorly
`of the mandrel. This fluid pressure will pass through openings 53 and 36 into
`chamber 35 to exert pressure between the opposed ends of piston 26 and cylinder
`head 28. This pressure will urge these elements apart and against the adjacent
`ends of slips 20 and when the force thus exerted in the opposite direction upon
`slips 20 exceeds the breaking strength of the smaller end sections 22 of the shear
`screws, these end sections will be sheared along the plane of the exterior surface
`of ‘body 10‘ (FIG. 2), and the continued movement of piston 26 and cylinder head
`28 will then urge slips 20 and expanders 18, which still remain connected by the
`shear screws, in opposite directions producing axial compression of sealing
`elements 17 and consequent radial expansion of the sealing elements into sealing
`engagement with the wall of casing C (FIG. 2).
`
`Brown at 5:59-6:2.
`
`Other well-known packer art that one skilled in the art could combine with the Lane Wells
`Products in open hole to achieve predictable results—such as isolation in an open, non-vertical
`wellbore—includes the RockSeal and RockSeal II Packers, as well as the RockSeal System, sold
`by Packers Plus. The RockSeal Packer was offered for sale at least “as early as April 2000,” see
`July 23, 2008 Declaration of Daniel J Themig (“Themig Declaration”) at 6, and is thus prior art
`to the 774 patent. According to the Themig Declaration, the RockSeal Packer contained the
`“principal elements” of:
`
`
`a hydraulic open hole packer that, in summary, is defined as including:
`an inner mandrel;
`a first compressible packing element disposed around the inner mandrel;
`a second compressible packing element disposed around the inner mandrel and
`spaced from the first compressible packing element; and
`a hydraulic actuation mechanism disposed between the first and second packing
`
`
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`774 Patent
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`Lane Wells Products
`elements, wherein said hydraulic actuation mechanism sets the packer by
`longitudinally compressing the first and second packing elements.
`
`
`Themig Declaration at 2 and 6.
`
`The RockSeal II Packer is prior art to the 774 patent. According to the “5.1 RockSeal™ II Open
`Hole Packer Series” advertisement from Packers Plus’ website available at Dkt. 59-2
`(“Website”), the RockSeal II Packer included the features of the claimed packers.
`
`
`The packer is a double element, solid body packer with Rock-Solid sealing and
`holding power. It combines the sealing strength of a mechanical element along
`with the setting force of a dual-piston setting cylinder and mechanical body-lock
`system. The RockSeal II packer has a specially designed multi-piece elastomer
`with the largest possible cross section to provide excellent expansion ratios to set
`in oversized holes. The packing element also contains a special backup system
`that provides a solid pack-off, even with borehole ovality.
`
`
`Website at 1.
`
`Applications of the RockSeal II Packer include “Formation fracture isolation” and “Isolation of a
`horizontal build section.”
`
`Website at 2.
`
`Other well-known packer art that one skilled in the art could combine with the Lane Wells
`Products in open hole to achieve predictable results—such as isolation in an open, non-vertical
`wellbore—includes Production Control of Horizontal Wells in a Carbonate Reef Structure, Bill
`Ellsworth et al., 1999 CIM Horizontal Well Conference (“Ellsworth”), published by 1999.
`Ellsworth is prior art to the 774 patent. Ellsworth discloses an apparatus that utilizes packers for
`open-hole completions: “This paper presents several well case histories that illustrate the
`application of advancements in establishing isolation in the open hole horizontal completions to
`accomplish various objectives in the successful application of horizontal wells.”
`
`
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`774 Patent
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`
`Ellsworth at 1.
`
`
`Lane Wells Products
`
`
`Ellsworth at Figure 4 (“The solid body packer is hydraulic set instead of inflatable (Guiberson /
`Halliburton Wizard II packer shown)”).
`
`
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`774 Patent
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`Lane Wells Products
`
`
`Ellsworth at Figure 5 (“The Solid Body Packers were used to segment the well, and provide
`isolation of the center portion of the well.”).
`
`“Each isolation point was established using two SBP’s [Solid Body Packers]…”
`
`Ellsworth at 5.
`
`Other well-known packer art that one skilled in the art could combine with the Lane Wells
`Products in open hole to achieve predictable results—such as isolation in an open, non-vertical
`wellbore—include the Wizard Packer and Wizard System by Guiberson / Halliburton. See
`generally Halliburton Completions Products guide from July 1999 (“Wizard Brochure”) at 2-25.
`
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`16 of 158
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`

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`774 Patent
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`Lane Wells Products
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`Multiple elements extrude to seal between the
`apparatus and the wellbore in open hole
`
`
`
`
`Wizard Brochure at 2-25.
`
`
`Halliburton’s Guiberson Wizard Packer provides highly efficient, zonal isolation
`in openhole applications, making it a cost effective alternative to inflatables. This
`innovative approach has demonstrated zonal isolation capabilities in horizontal
`wells that can lead to improved reservoir management and increased wellbore life.
`
`
`Wizard Brochure at 2-25.
`
`
`The Wizard isolation system is designed for running and setting in open or cased
`hole. Production control of water or gas can be achieved in either horizontal or
`vertical wellbores. Any number of sections of the wellbore can be isolated by
`running and setting tandem systems.
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`16
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`17 of 158
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`IPR2016-01517
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`

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`774 Patent
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`Lane Wells Products
`
`
`Wizard Brochure at 2-25.
`
`
`The Wizard isolation system contains elastomers with high expansion ratios to
`conform to openhole irregularities. The durable design features a small OD to
`allow running and placement. A positive internal lock is also included for a
`reliable, long-term pack-off. The system is hydraulically set and may be used in
`tandem with other completions tools as required.
`
`
`Wizard Brochure at 2-25.
`
`
`Applications
`• zonal isolation in cased or open hole
`• has or water shut off
`• stimulation
`• production testing
`•
`formation fracture isolation
`• selective production
`•
`individual interval stimulation and cleanup…
`
`
`Wizard Brochure at 2-25.
`
`
`
`Tech Manual at 9.
`
`Others packer art that one skilled in the art could combine with the Lane Wells Products in open
`hole to achieve predictable results—such as isolation in an open, non-vertical wellbore—include
`the Polar Bearfoot Packer. See generally Bearfoot Packer 652-0000 Datasheet (“Polar
`
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`17
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`

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`774 Patent
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`Lane Wells Products
`Datasheet”); Polar Completions Engineering Inc. Technical Manual, July 5, 2001, Rev. 1 (“Polar
`Tech Manual, Rev. 1”); Polar Completions Engineering Inc. Technical Manual, July 5, 2001,
`Rev. 2 (“Polar Tech Manual, Rev. 2”); Article entitled “Polar is the Completions Company,” pp.
`18-22 (“Polar Article”).
`
`
`The Polar Bearfoot Packer is a dual element, solid body packer specifically
`designed for use in well consolidated open hole formations. The applications for
`the Bearfoot Packer may include water shut-off, production control, formation
`fracture isolation, and build section isolation in both vertical or horizontal open
`hole completions. Since no mandrel movement occurs during setting, the Bearfoot
`Packer may be used in either single or multiple packer installation.
`
`
`Polar Datasheet at 1.
`
`
`The Bearfoot Packer has a dual-multi-durometer system which offers excellent
`expansion ratios for setting in oversized and oval boreholes. The hydraulic setting
`trigger and releasing system is fully adjustable by selecting the quantity of shear
`screws for the desired setting pressure and releasing force. During the deployment
`of the system, the packer is locked to prevent premature setting.
`
`
`Polar Datasheet at 1.
`
`
`
`Polar Datasheet at 1.
`
`
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`18
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`774 Patent
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`Lane Wells Products
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`Polar Tech Manual, Rev. 2 at 4.
`
`
`
`
`Since no mandrel movement occurs during setting, the Bearfoot may be used in
`either single packer installations, or as the lower packer in multiple zone dual
`completions.
`
`
`Polar Tech Manual, Rev. 2 at 1.
`
`
`Note: It is recommended to run a profile nipple above the packer to facilitate well
`control after unsetting the packer. ALSO, THIS PACKER DOES NOT HAVE
`ANY SLIPS.
`
`
`Polar Tech Manual, Rev. 2 at 1.
`
`Further, the “non-vertical” environment of this claim limitation