`
`BAKER HUGHES INCORPORATED and
`
`BAKER HUGHES OILFIELD OPERATIONS, INC., Petitioners
`
`V.
`
`PACKERS PLUS ENERGY SERVICES INC.,
`Patent Owner
`
`Case IPR2016—01517
`
`Patent 7,134,505
`
`DECLARATION OF MICHAEL P. DELANEY
`
`Mail Stop PA TENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`
`P.O. Box 1450
`
`Alexandria, VA 22313-1450
`
`1 of 4
`1 of 4
`
`Exhibit 2043
`Exhibit 2043
`IPR2016-01517
`IPR2016-01517
`
`
`
`I, the below-named Declarant, state as follows:
`
`1. My name is Michael P. Delaney, and I reside in Dallas, Texas.
`
`2.
`
`I am a paralegal at the law firm of Caldwell, Cassady and Curry
`P.C.
`
`3. Attached as Exhibit 2021 is a true and correct copy of
`Complaint, Rapid Completions LLC V. Baker Hughes, et al.,
`filed July 31, 2015
`
`4. Attached as Exhibit 2022 is a true and correct copy of
`Defendants’ Invalidity Contentions cover document, served
`January 19, 2016.
`
`5. Attached as Exhibit 2023 is a true and correct copy of Thomson
`
`invalidity contention chart, U.S. Patent 7,861,774.
`
`6. Attached as Exhibit 2024 is a true and correct copy of an email
`to defense counsel transmitting Plaintiff’ s Infringement
`Contentions on November 23, 2015.
`
`7. Attached as Exhibit 2025 is a true and correct bates—stamped
`
`copy of D. W. Thomson, “Design and Installation of a Cost
`
`Effective Completion System for Horizontal Chalk Wells
`
`Where Mulitiple Zones Require Acid Stimulation”, (1997) as
`
`served on defendants on November 23, 2015.
`
`8. Attached as Exhibit 2026 is a true and correct bates—stamped
`copy of A.B. Yost, “Production and Stimulation Analysis of
`Multiple Hydraulic Fracturing of a 2,000—ft Horizontal Well”
`(1989) as served on defendants on November 23, 2015.
`
`9. Attached as Exhibit 2027 is a true and correct screenshot of the
`
`metadata for Defendants’ initial invalidity contentions, dated
`
`January 19, 2016.
`
`2 of 4
`2 of 4
`
`Exhibit 2043
`Exhibit 2043
`IPR2016-01517
`IPR2016-01517
`
`
`
`10.
`
`Attached as Exhibit 2028 is a true and correct copy of a list of
`
`attorneys docket sheet from Case No. 6:15—cv—00724; Rapid
`
`Completions V. Baker Hughes et al.
`
`11.
`
`Attached as Exhibit 2030 is a true and correct copy of
`Defendants’ Second Amended Invalidity Contentions, served
`August 11, 2016.
`
`12.
`
`Attached as Exhibit 2031 is a true and correct screenshot of the
`
`metadata for the Yost Invalidity Charts attached to Defendants’
`amended invalidity contentions, dated August 11, 2016.
`
`13.
`
`Attached as Exhibit 2032 is a true and correct copy of U.S.
`
`Patent 7,861,774 - Yost invalidity chart, served August 11,
`
`2016
`
`14.
`
`15.
`
`16.
`
`17.
`
`Attached as Exhibit 2033 is a true and correct copy of U.S.
`Patent 7,861,774 - Lane-Wells invalidity chart, served August
`1 1, 2016.
`
`Attached as Exhibit 2034 is a true and correct copy of an email
`from counsel for Baker Hughes Eric Green email to Justin
`Nemunaitis, dated July 11, 2016.
`
`Attached as Exhibit 2035 is a true and correct copy of
`Weatherford’s letter brief regarding Motion for Summary
`Judgment of Indefiniteness, dated September 20, 2016.
`
`Attached as Exhibit 2036 is a true and correct copy of Baker
`Hughes’ letter brief regarding Motion for Summary Judgment
`of Indefiniteness, dated September 20, 2016.
`
`18.
`
`Attached as Exhibit 2037 is a true and correct copy of an email
`
`from Justin Nemunaitis to counsel for Weatherford Leslie
`
`Payne, dated September 19, 2016.
`
`19.
`
`Attached as Exhibit 2038 is a true and correct copy of
`Weatherford’s Expedited Motion to Stay Pending Inter Partes
`Review Proceedings, filed September 13, 2016
`
`3 of 4
`3of4
`
`Exhibit 2043
`Exhibit 2043
`IPR2016-01517
`IPR2016-01517
`
`
`
`Further, Declarant sayeth not.
`
`I, the above-named Declarant, hereby declare that all statements made
`
`herein of my own knowledge are true and that all statements made on
`
`information and belief are believed to be true; and further that these statements
`
`were made with the knowledge that willful false statements and the like so
`
`made are punishable by fine or imprisonment, or both, under Section 1001 of
`Title 18 of the United States.
`\
`
`Date: November 25, 2016
`
`
`
`Signature of Declarant
`Michael P. Delaney
`
`4 of 4
`40f4
`
`Exhibit 2043
`Exhibit 2043 ._
`IPR2016-01517
`IPR2016-01517
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