`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`KERR MACHINE COMPANY
`Petitioner,
`v.
`S.P.M. FLOW CONTROL, INC.,
`Patent Owner
`____________
`
`Patent No. 9,879,659
`____________
`
`DECLARATION OF STEVEN M. TIPTON, PH.D, P.E.
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`Page 1 of 136
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`TABLE OF CONTENTS
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`I.
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`Introduction ...................................................................................................... 4
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`II. Background and Qualifications ........................................................................ 4
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`III. Bases for Opinions ........................................................................................... 6
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`IV. Legal Standards ................................................................................................ 7
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`A. Patentability ................................................................................................... 7
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`B. Prior Art ....................................................................................................... 12
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`C.
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`Inherency ...................................................................................................... 12
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`D. Person of Ordinary Skill In The Art ............................................................ 13
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`E. Claim Construction ...................................................................................... 15
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`V.
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`Summary of Opinions ..................................................................................... 16
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`VI. Technological Background And State Of The Art ......................................... 17
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`A. Basics of Reciprocating Pumps ................................................................... 18
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`B. High-Pressure Pump Assemblies ................................................................. 20
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`C. Power End Crankshaft Bearing Journals and Support Components ........... 21
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`D. Pump Skids and Structural Elements ........................................................... 25
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`E. Pump Mounting and Shaft Alignment ......................................................... 33
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`VII. Level of Ordinary Skill in the Art .................................................................. 39
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`VIII. Claim Construction ......................................................................................... 40
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`IX. Detailed Opinions of Unpatentability ............................................................. 40
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`A. The Prior Art References are Analogous to the Claimed Invention. ........... 41
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`Page 2 of 136
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`1. Maverick is Analogous Prior Art ............................................................. 42
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`2. Rambin is Analogous Prior Art ................................................................ 43
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`3. Marran is Analogous Prior Art ................................................................. 44
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`4. Ojalvo is Analogous Prior Art .................................................................. 45
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`B. The Asserted Grounds Render the Challenged Claims Unpatentable ......... 46
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`C. Secondary Considerations Of Non-Obviousness ........................................ 91
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`X. Conclusion ...................................................................................................... 91
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`Page 3 of 136
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`I, Steven M. Tipton, declare as follows:
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`I.
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`INTRODUCTION
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`1.
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`I have been retained as a technical expert by Kerr Machine Co.
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`(“Kerr”).
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`2.
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`I have been asked to study and provide my opinions concerning U.S.
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`Patent No. 9,879,659 (“the ‘659 Patent”) and the patentability of its claimed
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`inventions in view of certain prior art references, the state of the art at the time of
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`the claimed inventions, and the knowledge of a person of ordinary skill in the art at
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`the time of the claimed inventions.
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`3. My opinions and views set forth in this declaration are based on my
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`education, training, and experience in the field of positive displacement pumps, their
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`internal components, and related technical areas, as well Petitioner’s Exhibits 1001-
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`1030, and other materials that are cited and discussed herein.
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`II. BACKGROUND AND QUALIFICATIONS
`4. My curriculum vitae is attached to this declaration as Appendix A.
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`5.
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`I have a Ph.D. in Mechanical Engineering from Stanford University. I
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`have taught Mechanical Design and Senior Design Projects, along with other
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`undergraduate and graduate mechanics and materials courses at The University of
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`Tulsa for 38 years. I am a fellow of the American Society of Mechanical Engineering
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`and the American Society for Materials. I was a 2010 Distinguished Lecturer for the
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`Page 4 of 136
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`Society of Petroleum Engineers and received the H.R. Worthington Medal from the
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`ASME Petroleum Division in 2013. I have been an active industry consultant and
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`hold 9 patents with another pending.
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`6. My work as a researcher and consultant has included high-pressure
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`equipment used in the oilfield, including work on both the power and fluid ends of
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`positive displacement pumps. I conducted a comprehensive multiaxial fatigue life
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`analysis on crankshafts in the power end of positive displacement pumps in 1993 for
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`a company called Twentieth Century Manufacturing (which was purchased by
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`Gardner Denver in the mid 1990’s). I conducted two major research projects to study
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`and optimize the fatigue behavior of fluid ends in positive displacement pumps. The
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`first was from 1990-95 with Schlumberger and the Oklahoma Center for the
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`Advancement of Science and Technology, and the second from 2011-2014 with
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`Gardner-Denver. Both of these projects focused on optimizing the beneficial
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`influence of autofrettage to maximize the endurance of the crossbore intersections.
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`Many other structural/functional aspects of fluid ends were considered during this
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`research, as autofrettage had the potential to affect other high stress regions, such as
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`o-ring glands, and could distort the overall geometry of the fluid end, affecting its
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`assembly to the power end.
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`7.
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`I conducted a one-year sabbatical leave project with Schlumberger in
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`1991. A major portion of this was developing a design algorithm to properly include
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`Page 5 of 136
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`internal and external O-ring seal glands in Acme threaded connections with
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`prescribed safety factors against yielding due to axial loading and internal/external
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`pressure differentials. I have also designed a number of medium pressure (e.g., 15
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`ksi) end caps for coiled tubing fatigue test samples with internal o-ring glands.
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`8.
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`I have previously testified as an expert witness. A list of those matters
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`within the last four years is attached to this declaration as part of Appendix A.
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`9.
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`I am being compensated for services provided in this matter at a rate of
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`$425.00 per hour. I am also being reimbursed for reasonable expenses, such as travel
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`expenses. My compensation is not contingent on my opinions, on the outcome of
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`any matter, or on any of the technical positions I explain in this declaration.
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`10.
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`I have no financial interest in Kerr, the Patent Owner (whom I
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`understand to be S.P.M. Flow Control, Inc., SPM Oil & Gas Inc., and/or their parent,
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`Caterpillar Inc.), or the ‘659 Patent.
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`III. BASES FOR OPINIONS
`11. The opinions set forth in this declaration are my own. In forming the
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`opinions herein, I have considered the exhibits to the Petition cited herein, as well
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`as any additional materials cited in this declaration, and my education, training, and
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`experience.
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`12. My analysis of the materials relating to this matter is ongoing and I will
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`continue to review any new material that is provided to me. This Declaration
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`Page 6 of 136
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`represents certain opinions that I have formed to date and the bases for those
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`opinions. I reserve the right to revise, supplement, and/or amend my opinions based
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`on new information presented to me and on my continuing analysis of the materials
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`cited herein or later provided to me.
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`IV. LEGAL STANDARDS
`13.
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`I am not an attorney. For purposes of this Declaration, I have been
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`informed about certain aspects of the law that are relevant to my opinions, as set
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`forth below.
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`A. PATENTABILITY
`14.
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`I understand that for an invention claimed in a patent to be valid and
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`patentable, it must be, among other things, new and not obvious in light of what was
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`known and came before it. That which was known or came before the invention
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`claimed is generally referred to as “prior art.”
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`15.
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`I understand that there are two ways in which prior art may render a
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`patent claim unpatentable. First, the prior art can be shown to “anticipate” the claim.
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`Second, the prior art can show that the claim was obvious to a person of ordinary
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`skill in the field of the invention at the time the invention was made.
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`Page 7 of 136
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`16.
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`I understand that, for a patent claim to be “anticipated” by the prior art,
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`each and every element or requirement of the claim must be found, expressly or
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`inherently, in a single prior art reference.
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`17.
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`It is my understanding that whether a claimed invention is obvious is a
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`question of law, with underlying factual inquiries that are determined from the
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`perspective of a person of ordinary skill in the art at the time of the claimed
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`invention.
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`18.
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`It is my understanding that a claimed invention is obvious if the
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`differences between the claimed invention and the prior art are such that the claimed
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`invention as a whole would have been obvious before the effective filing date of the
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`claimed invention to a person having ordinary skill in the art (a “POSITA”).
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`19.
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`It is my understanding that obviousness requires consideration of the
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`following underlying factual inquiries:
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` determining the scope and content of the prior art
` ascertaining the differences between the claimed invention and the
`prior art;
` resolving the level of ordinary skill in the art; and
` evaluating objective evidence or “secondary considerations” of non-
`obviousness, such as commercial success, long-felt but unresolved
`needs, failure of others, industry praise, and unexpected results.
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`Page 8 of 136
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`20.
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`It is my understanding that a reference must be analogous art to the
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`claimed invention in order to be properly considered for use in an obviousness
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`inquiry. It is my understanding that a reference is analogous art to the claimed
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`invention if:
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` the reference is from the same field of endeavor as the claimed
`invention (even if it addresses a different problem); or
` the reference is reasonably pertinent to the problem faced by the
`inventor (even if it is not in the same field of endeavor as the claimed
`invention).
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`21.
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`It is my understanding that whether a reference is reasonably pertinent
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`turns on how the problem faced by the inventor is reflected, either explicitly or
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`implicitly, in the specification.
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`22.
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`It is my understanding that the following are exemplary rationales that
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`may support a conclusion of obviousness:
`
` Combining prior art elements according to known methods to yield
`predictable results;
` Simple substitution of one known element for another to obtain
`predictable results;
` Use of known techniques to improve a similar method or product in the
`same way;
` Applying a known technique to a known method or product ready for
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`Page 9 of 136
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`improvement to yield predictable results;
` Obvious to try – choosing from a finite number of identified,
`predictable solutions, with a reasonable expectation of success;
` Known work in one field of endeavor may prompt variations of it for
`use in either the same field or a different one based on design incentives
`or other market forces if the variations are predictable to one of ordinary
`skill in the art; and
` Some teaching, suggestion, or motivation in the prior art that would
`have led one of ordinary skill to modify the prior art reference or to
`combine prior art reference teachings to arrive at the claimed invention.
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`23.
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`In addition to the above, I understand that a person of ordinary skill in
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`the art may resort to logic, judgment and common sense available to him or her at
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`the time of the invention to find a claim feature obvious, even if the prior art relied
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`on does not explicitly state or teach that feature. I understand that when common
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`sense is relied on to find a feature obvious, the reasoning for that conclusion must
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`be articulated with sufficient clarity.
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`24.
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`I also understand that a patent claim is not proved obvious merely by
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`demonstrating that each of its elements was, independently, known in the prior art.
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`An obviousness determination requires finding both that a skilled artisan would have
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`been motivated to combine the teachings of the prior art references to achieve the
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`claimed invention, and that the skilled artisan would have had a reasonable
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`Page 10 of 136
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`expectation of success in doing so. I understand that it is important to be careful not
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`to allow hindsight reconstruction of references to produce the claimed invention,
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`without any explanation as to how or why the references would be combined to
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`produce the claimed invention.
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`25. Regarding “objective evidence” or “secondary considerations,” I
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`understand that for such evidence to be relevant to the obviousness of a claim, there
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`must be a causal relationship (called a “nexus”) between the claim and the evidence.
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`I also understand that such objective evidence may include: commercial success of
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`products covered by the patent claims; long-felt need for the invention; failed
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`attempts by others to solve the problem addressed by the invention; copying of the
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`invention by others in the field; unexpected results achieved by the invention; praise
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`of the invention; the taking of licenses under the patent by others; expressions of
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`surprise by experts and those skilled in the art at the making or use of the invention;
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`and that the patentee proceeded contrary to the accepted wisdom of the prior art.
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`26.
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`I understand that a person of ordinary skill is also a person of ordinary
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`creativity. I further understand that the obviousness analysis need not seek out
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`precise teachings directed to the specific subject matter of the challenged claim, but
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`instead can take into account “ordinary innovation” that does no more than yield
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`predictable results, which are inferences and creative steps that a person of ordinary
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`skill in the art would be understood to employ.
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`Page 11 of 136
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`27.
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`I understand that sometimes it will be necessary to look to interrelated
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`teachings of multiple patents and publications; the effects of demands known to the
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`relevant field or present in the marketplace; and the background knowledge
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`possessed by a person having ordinary skill in the art. I understand that all these
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`issues may be considered to determine whether there was an apparent reason to
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`combine the known elements in the fashion claimed by the patent at issue.
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`B. Prior Art
`28.
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`I understand that for purposes of this proceeding, prior art includes
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`patents and printed publications in or outside the United States before the effective
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`filing date of the claimed invention. I also understand that prior art includes U.S.
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`patents, published U.S. patent applications, and published international applications
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`(pursuant to the Patent Cooperation Treaty) that themselves have an effective filing
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`date before the effective filing date of the claimed invention, as long as they name
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`another inventor.
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`C. INHERENCY
`29.
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`I understand that if a prior art reference does not expressly set forth a
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`particular claim element, the prior art may still disclose that element if it is “inherent”
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`in its disclosure. To establish inherency, it is my understanding that evidence must
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`make clear that the missing descriptive matter is necessarily present in the thing
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`Page 12 of 136
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`described in the reference. It is my understanding that inherency may not be
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`established by probabilities or possibilities. In other words, it is my understanding
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`that the mere fact that a certain thing may result from a given set of circumstances
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`is not sufficient to establish inherency.
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`30.
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`I understand that under the principles of inherency, if a prior art device,
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`in its normal and usual operation, would necessarily perform a claimed method, then
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`the method will be considered to be anticipated by the prior art device. I also
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`understand that when the prior art device is the same as a device described in the
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`specification for carrying out the claimed method, it can be assumed the device will
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`inherently perform the claimed process.
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`D. Person of Ordinary Skill In The Art
`31.
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`I understand that “a person of ordinary skill in the art” or POSITA is a
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`hypothetical person who is presumed to have known the relevant art at the time of
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`the invention. Such a person would necessarily have the capability of understanding
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`any scientific and engineering principles applicable to the pertinent art.
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`32.
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`I understand that factors that may be considered in determining the level
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`of ordinary skill in the art include, but are not limited to, the following:
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`a. the educational level of the inventor;
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`b. the type of problems encountered in the art;
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`Page 13 of 136
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`c. prior art solutions to those problems;
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`d. the rapidity with which innovations are made;
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`e. the sophistication of the technology; and
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`f. the educational level of active workers in the field.
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`33.
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`I understand that a person of ordinary skill in the art is not a real person,
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`but rather is a hypothetical individual having the qualities reflected by the factors
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`above. This hypothetical person has knowledge of all prior art in the relevant field
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`as if it were arranged on a workshop wall and takes from each reference what it
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`would teach to a person of ordinary skill in the art.
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`34.
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`I understand that a person of ordinary skill in the art is a person of
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`ordinary creativity, not an automaton. In many cases a person of ordinary skill will
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`be able to fit the teachings of multiple prior art references together like pieces of a
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`puzzle.
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`35.
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`I understand that a person of ordinary skill in the art can collaborate
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`with one or more other persons of ordinary skill in the art for one or more aspects
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`with which the other person may have superior expertise, experience, and/or
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`knowledge.
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`Page 14 of 136
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`E. CLAIM CONSTRUCTION
`36.
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`It is my understanding that claim construction, or the interpretation of
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`the claims of a patent, is ultimately a question of law. I have been informed that
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`claim terms are generally presumed to carry their ordinary and customary meaning.
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`However, I understand that a patent applicant is his own lexicographer and is entitled
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`to provide alternate definitions of words in common usage, but if the patent applicant
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`uses a term that is in common usage without providing an alternate definition, then
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`that term should generally be understood as having its common meaning.
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`37.
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`I understand that a person of ordinary skill in the art is deemed to read
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`a claim term not only in the context of the particular claim in which the disputed
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`term appears, but in the context of the entire patent specification and the “file
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`history” of the patent developed during examination by the Patent Office.
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`38.
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`I understand that the claims, the specification, and the file history are
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`referred to as “intrinsic evidence,” and are to be read as a person of ordinary skill in
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`the art at the time of the invention would have done at the time of the alleged
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`invention.
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`39.
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`In addition to the intrinsic evidence, I understand that the court or
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`tribunal may also consider other relevant evidence, which is called “extrinsic
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`evidence,” concerning relevant scientific principles, the meaning of technical terms,
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`and the state of the art. Such evidence includes the testimony of expert witnesses.
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`Page 15 of 136
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`Although extrinsic evidence may be used to resolve ambiguities that may exist after
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`reviewing the intrinsic evidence, I understand that extrinsic evidence cannot be used
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`to contradict a claim construction that is clear from the intrinsic evidence.
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`40.
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`I understand that some claims are independent, and that those
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`independent claims are complete by themselves. Other claims refer to these
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`independent claims, or other dependent claims, and are “dependent” on those claims.
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`The dependent claims include all of the limitations of the claims on which they
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`depend.
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`V.
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`SUMMARY OF OPINIONS
`41. For reasons described in more detail in this Declaration, my opinions
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`are summarized as follows:
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`42. Claims 1-8, 11-15, 18, and 20 were obvious under 35 U.S.C. § 103 over
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`Maverick in view of Rambin, further in view of Marran. Maverick discloses a skid-
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`mountable reciprocating pump having a power end assembly with end plates and
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`multiple middle plates, with a pair of feet attached to each plate. Rambin discloses a
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`modular skid base for supporting reciprocating pumps such as Maverick’s. Marran
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`discloses pads for mounting a pump to a base such as in Rambin. It was obvious to
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`mount the feet of Maverick’s pump to a skid such as in Rambin using Marran’s pads.
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`The differences between Maverick in view of Rambin, further in view of Marran
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`and the claimed invention are such that it was obvious to a person having ordinary
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`Page 16 of 136
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`skill in the art when considering Maverick in view of Rambin, further in view of
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`Marran. This combination is referred to as Ground 1.
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`43. Claims 10 and 17 were obvious under § 103 over Maverick in view of
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`Rambin, further in view of Marran, further in view of Ojalvo. Marran discloses pads
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`for mounting a pump as in Maverick to a skid as in Rambin. Ojalvo suggests the use
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`of web stiffeners or “gussets” to stiffen structural steel members such as skid
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`segments. It was obvious to mount the feet of Maverick’s pump to a skid as
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`suggested by Rambin, modified with web stiffeners or gussets as suggested by
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`Ojalvo, using Marran’s pads. The differences between Maverick in view of Rambin,
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`further in view of Marran, further in view of Ojalvo and the claimed invention are
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`such that it was obvious to a person having ordinary skill in the art when considering
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`Maverick in view of Rambin, further in view of Marran, further in view of Ojalvo.
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`This combination is referred to as Ground 2.
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`VI. TECHNOLOGICAL BACKGROUND AND STATE OF THE ART
`44. The claims of the ‘659 Patent are directed toward a reciprocating pump
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`assembly, and specifically the power end frame assembly, as well as a skid for
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`supporting the pump. Ex-1001, Abstract.
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`45.
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`I understand that, for purposes of the Petition, that the effective filing
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`date of the invention can be no earlier than July 25, 2014, the date that the first
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`provisional application from which the ‘659 Patent was filed claims priority. See Ex-
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`Page 17 of 136
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`1001, “Related U.S. Application Data.” Therefore, I will discuss the technological
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`background, including the basic operation of reciprocating pumps and the design of
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`their housings and skids, before that date.
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`A. BASICS OF RECIPROCATING PUMPS
`46. A reciprocating pump is generally understood as any machine using
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`reciprocating motion to cause fluid to be moved from one location to another.
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`Reciprocating pumps are a form of positive displacement pumps. These pumps
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`encase a fixed fluid volume in a rigid enclosure and displace a cylindrical volumetric
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`portion of it via a plunger (also referred to as a piston). Such pumps have long been
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`used to meet high pressure pumping requirements. For example, these pumps are
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`often used as drilling or “mud pumps,” which are used to circulate drilling fluids and
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`cuttings (drilling mud) during drilling of oil or gas wells. See, e.g., Ex-1015, 1:15-
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`22. They are also used in hydraulic fracturing, which involves pumping fluid at high
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`pressures to create fractures in hydrocarbon-bearing formations. See Ex-1016 ¶2.
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`47. These pumps have two primary sections. The “fluid end” receives
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`relatively low pressure fluid and, via a number of plungers, pressurizes the fluid to
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`a relatively higher pressure. Id. The plungers are driven by a crankshaft in the “power
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`end” which is attached to a power source or prime mover, such as a diesel engine or
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`electric motor. See id. In the figure below, the fluid end (116) includes everything in
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`Page 18 of 136
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`the purple housing, and the power end (100) includes everything in the green
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`housing. Id. ¶20
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`48. The power end
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`includes crankshaft 134 (orange) coupled
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`to
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`piston/plunger 146 (blue) via connecting rod 144 (pink). Ex-1016 ¶ 20. The engine
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`(not shown) rotates the crankshaft, causing the piston to reciprocate between a
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`suction stroke away from the fluid end and a power stroke toward the fluid end, as
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`indicated by the dashed red arrow. This causes fluid to be drawn into the fluid end
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`via an inlet and out of the fluid end via an outlet, as indicated by the blue arrow.
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`49. When the plunger moves back on the suction stroke, suction valve 154
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`opens and fluid is drawn from suction inlet 166 into passage 158. The suction valve
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`Page 19 of 136
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`closes at the end of the stroke. Id. The plunger re-enters the chamber on its forward
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`power stroke, forcing the fixed volume of fluid in passage 158 through the output
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`valve 156. Id.
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`B. HIGH-PRESSURE PUMP ASSEMBLIES
`50.
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`It is common for reciprocating pumps to use multiple plungers and
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`corresponding fluid end assemblies. Such pumps are generally referred to as
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`“multiplex” pumps, such as “triplex” (three plungers) and “quintuplex” (five
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`plungers) pumps. Ex-1017, 3:28-38.
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`51. An example of a “triplex” pump assembly is depicted below, having a
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`set of three cylinders 16 in respective plunger bores. Ex-1017, 4:43-64. It has a
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`power end 13 (green) with three plungers and a fluid end 15 (purple) having three
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`corresponding plunger bores. Id. A single crankshaft reciprocates all three plungers,
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`causing fluid in the suction manifold 19 to be drawn into the suction inlet (not
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`depicted) of each fluid assembly and pumped out of discharge outlet 21. See id., 5:2-
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`11.
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`Page 20 of 136
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`C. POWER END CRANKSHAFT BEARING JOURNALS AND
`SUPPORT COMPONENTS
`52.
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`In order to understand the invention described by the claims, I will
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`discuss power end design with respect to the figures below, which are taken from
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`Ex-1018. Ex-1018 is directed to an invention of a crankshaft which has been reduced
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`in weight by removing material. See Ex-1018, Abstract. However, the arrangement
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`of the various components is representative of typical multiplex power ends using
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`crankshafts which have not been so modified.
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`53.
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`In a triplex pump, the crankshaft 300 features four main bearing
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`journals 302. The main bearing journals have a bearing face 304 upon which roller
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`bearings 602 are installed. Ex-1018 ¶¶26, 32, Fig. 6 (reproduced below). The roller
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`bearings feature an inner bearing race that contacts the main bearing journal face
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`304. Id. ¶32.
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`Page 21 of 136
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`54. The crankshaft 300 is located inside pump housing 702. Id. ¶ 33, Fig. 7
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`(reproduced below). The main bearings 602 which roll within outer bearing races
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`706, which are mounted within bores through the main bearing webs 704 (green).
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`Id. The webs of the ‘659 Patent are referred to therein as “plate segments” or simply
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`“segments” and differentiated as to whether they are “end [plate] segments” or
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`“middle [plate] segments.” See, e.g., Ex-1001,3:47-60 (referencing Figures 14-20),
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`9:55-62. The claims refer to them as both “plates” (claim 1 and dependents) and
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`“segments” (claim 12 and dependents). Id., 21:37-22:59.
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`55. The webs provide positional support for the crankshaft and help
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`dissipate the tremendous force and vibration generated within and by the frac pump
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`during operation. Ex-1018 ¶33. The bearing face 304 supports the forces exhibited
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`on the crankshaft by the reciprocating connecting rod/piston/plunger arrangement
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`by transferring the compressive forces encountered from the rod bearing journal 308,
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`through the main bearing journal bearing face 304, the roller bearings 602, the outer
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`bearing races 706, into the support webs 704, and ultimately to the power end
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`housing where the forces are dissipated. Id.
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`56.
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`It was common for multiplex pumps to have supports of some type to
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`support the crankshaft and its bearings. For example, before the effective filing date,
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`Kerr sold the QWS1000S fracturing pump. As shown below, the power end housing
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`includes such supports, comprising circular end and middle “plates” as shown.1 The
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`crankshaft would extend through and be supported by such components, as was
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`common practice at the time.
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`1 Available at https://www.youtube.com/watch?v=678NKpSpL9I as of April 18,
`2014.
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`D. PUMP SKIDS AND STRUCTURAL ELEMENTS
`57.
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`It is common to mount machinery such as pumps and motors to “skids”
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`for transport and/or ease of placement. See, e.g., Ex-1017, 1:26-29, 4:67-5:2; Ex-
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`1022, 6:45-57. “Skid” is simply a term used to refer to the framework used to support
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`such machines. Ex-1023, 1:19-21.
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`58. Many applications require transportation of pumps to various locations.
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`For example, for fracturing operations a pump truck typically needs to fracture wells
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`at different well sites. The power end housings of these pumps are designed to be
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`mounted to a skid for transport to or from a wellsite (e.g., by truck). Ex-1017, 1:26-
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`29.
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`59. Skids typically have a frame formed from multiple, intersecting beams
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`or tubulars for mounting very heavy machinery, such as the pump assemblies
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`discussed above. Reciprocating pumps have been mounted to such skids for
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`transport for many decades.
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`60. For example U.S. Patent 4,553,298 (Ex-1022) discloses a power end
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`housing that is integral with a support skid. In reference to Figure 2, the skid “is
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`constructed in accordance with oilfield equipment practices” and includes parallel
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`beams 102 and 104 (green) that are interconnected at their opposite ends by
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`transverse steel tubular sections 106 and 108 (red). Ex-1022, 6:45-57. The beams
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`102 and 104 can be I or H beams. Id.
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`61. U.S. Patent 4,341,508 (Ex-1004) also discloses a skid assembly for
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`multiple reciprocating pumps. Ex-1004, 1:42-54, 6:53-60, Fig. 4. The skid includes
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`parallel “I-beam type structural elements” 120, 122, and 124. Id., 9:27-33, Figs. 9,
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`10. These skid segments connect together using bolt flanges and locking elements.
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`Id., 9:33-47. Figure 11 shows a power source (engine/motor) connected to a drive
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`through shaft 152 for rotating the crankshafts of two pumps 148, 150.
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`62. Skids are typically comprised of at least two longer longitudinal or side
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`members, and any number of transverse members. The particular arrangement and
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`number of longitudinal members and transverse members is a design choice based
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`on the desired orientation and load of the equipment mounted thereon. The primary
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`prerequisites are that the skid adequately and stably support the mounted equipment
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`while performing its intended function of providing a stable base for transportation
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`and operation. See, e.g., Ex-1030 at 21 (“2. The skid . . . must be of sufficient strength
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`to prevent flexing of the equipment. 3. The skid . . . must be of sufficient size and
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`design to maintain the equipment free of strain.”).
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`63. For example, the skid of Exhibit 1022 referenced above is oriented such
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`that its two longitudinal or side members 102 and 104 are perpendicular to its
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`crankshaft 20 and parallel to the power end’s bearing support plate members 50,52,
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`54, and 56. Ex-1022, 4:56-62, 5:24-34, Fig. 2.
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`64.
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`In Exhibit 1004, when considering the overall skid base, the
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`longitudinal members 120 are parallel to the driveshafts 60, 68, 90 (which turn the
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`crankshaft and are in alignment with it), and are thus perpendicular to the bearing
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`support webs or plates. Ex-1004, 6:53-60, 7:41-55, Figs. 1, 9. Fig. 1 is reproduced
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`below with the underlying skid base of Figure 9 imposed for reference. When
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`considering the individual pump skid modules, the longitudinal members are
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`actually the transverse members 124, which run per