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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`DYNAENERGETICS EUROPE GMBH and
`DYNAENERGETICS US, INC.
`
`Petitioner
`
`v.
`
`QINETIQ LIMITED
`
`Patent Owner
`____________
`
`
`Case: PGR2023-00003
`Patent No. 11,215,039
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`____________
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`DECLARATION OF MARCO SERRA
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`
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 1 of 100
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`
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`I, Marco Serra, hereby declare as follows:
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`PGR2023-00003
`U.S. Patent No. 11,215,039
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`
`I.
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`Background
`1.
`I have been retained by Petitioner, DynaEnergetics Europe GmbH and
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`DynaEnergetics US, Inc. (collectively “DynaEnergetics”) in connection with the
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`above-captioned Post Grant Review (“PGR”) proceeding involving U.S. Patent No.
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`11,215,039 (“the ’039 Patent”) (Ex. 1001).
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`2.
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`I have been asked by DynaEnergetics to offer opinions regarding the
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`’039 Patent and claims 1-5 (the “Challenged Claims”) of the ’039 Patent, as set forth
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`in the Petition for PGR (“the Petition”). This declaration sets forth the opinions I
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`have reached to date regarding these matters.
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`3.
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`I am being compensated by DynaEnergetics at my standard hourly
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`consulting rate of $230 per hour for my time spent on this matter. My compensation
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`is not contingent on the outcome of the PGR or on the substance of my opinions.
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`4.
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`I have no financial interest in DynaEnergetics or Patent Owner.
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`II. Education and Work History
`5.
`I have a M.Eng in mechanical engineering from the University of
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`Pretoria (South Africa, 1993) and a SM in Engineering and Management from the
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`Massachusetts Institute of Technology (USA, 2002). I began working as a
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`mechanical engineer in 1993.
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 2 of 100
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`U.S. Patent No. 11,215,039
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`I have extensive experience with modeling and simulation software
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`6.
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`programs for use in designing, testing, and evaluating downhole tools and
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`equipment, including perforating equipment such as shaped charges. Of specific
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`relevance to this matter, I have extensive experience in the modeling and simulation
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`of oil well completions in which the dynamic response of the wellbore fluid and tool
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`string structural components to the release of energy by the detonation of strings of
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`shaped charges, is calculated. This work, which has been conducted over
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`approximately the last 15 years has, amongst other things, required the
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`characterization of simulated shaped charge performance against data obtained in
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`field tests for the performance of various types of shaped charges. This was done in
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`order to accurately represent the shaped charges and tool string in a computationally
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`advantageous configuration. This specific aspect of the work required the modeling
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`and simulation of each field test, including shaped charges, and the calibration of
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`equation of state and other parameters to match simulated performance to
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`experimental performance, validating each charge model for use in the larger string
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`models. This type of activity is done iteratively and, incidentally, produces a library
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`of data relating shaped charge design parameters to shaped charge performance and
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`provides a reference or store of information that can be used to guide shaped charge
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`selection or shaped charge design activities with the aim of enhancing or optimizing
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`shaped charge performance in accordance with some desired characteristic. The
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 3 of 100
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`PGR2023-00003
`U.S. Patent No. 11,215,039
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`validated shaped charge models are then available for use in simulations aimed at
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`optimizing perforation string performance with regard to perforation cleanout and
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`well skin, a measure of well flow resistance, to obtain optimal communication
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`between the oil-bearing formation and the well.
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`7.
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`Furthermore, over the years I have also simulated API Section IV
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`shaped charge tests in detail to evaluate their performance and validate them against
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`the results of actual API Section IV tests in order to calibrate equation of state
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`parameters. Such simulations and/or tests evaluate shaped charge performance in an
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`environment representative of downhole conditions, attempting to characterize the
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`hole that will be created by the shaped charge in similar conditions downhole.
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`8.
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`Attached as Appendix A is a copy of my current C.V. further
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`elaborating on my professional background and qualifications.
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`III. Materials Considered
`9.
`In forming my opinions, I have reviewed the ʼ039 Patent and its
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`prosecution history. I have also reviewed and considered prior art references, and
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`other documents and information as set forth in this declaration.
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`10.
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`In reaching my opinions, I have relied upon my experience in the field
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`and also considered the viewpoint of a person of ordinary skill in the art (“POSITA”)
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`at the time of the earliest claimed priority date of the ’039 Patent. As explained
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 4 of 100
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`U.S. Patent No. 11,215,039
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`below, I am familiar with the level of a person of ordinary skill in the art regarding
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`the technology at issue as of that time.
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`IV. OVERVIEW OF THE TECHNOLOGY
`A. Technology Background
`11. The ’039 Patent is generally directed to explosive charges (“shaped
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`charges”) detonated deep underground in oil and gas wells to perforate rock
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`formations and liberate the oil and gas trapped in the rock. Below I discuss shaped
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`charge technology generally and certain fundamental shaped charge design
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`principles.
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`1.
`Shaped charges and perforating
`12. A shaped charge (shown below) consists of
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`three primary
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`components—a case, an explosive, and a liner. The liner is conventionally
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`positioned on top of the explosive within the case—i.e., the explosive is positioned
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`between the case and the liner in order to direct as much of the energy released by
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`the explosive detonation toward the liner as possible.
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 5 of 100
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`Ex. 1009, Fig. 3.
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`13. The liner is typically formed from a pressed metal powder in a conical
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`or hemispherical shape, depending on the desired perforation characteristics.
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`Initiating the explosive generates a high pressure detonation front that advances
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`along the liner and forces the liner to collapse progressively from the back of the
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`charge to the open front end of the charge. The liner material is accelerated towards
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`the center line of the charge and forms a jet of collapsed liner material that extends
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`out of the charge at hypersonic speed. In typical operations, after detonation, the jet
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`perforates a metal carrier housing the shaped charge, a wellbore casing lining the
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`well, a concrete barrier around the wellbore casing, and then finally the rock
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`formation surrounding the wellbore, thereby creating a hole—i.e., a “perforation
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`tunnel”—in the rock. The properties of the shaped charge design (including the liner)
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`affect the jet, which in turn impacts the properties of the perforation tunnel, such as
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`its shape, propagation direction, and amount of debris or roughness within the
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 6 of 100
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`tunnel. The desired hole shape may include, for example, a specific hole geometry,
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`a specific dimension such as entry hole diameter, (average) perforation diameter,
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`depth, width (in the case of non-circular holes) or degree of taper, and/or a metric
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`such as volume or a ratio (such as an aspect ratio) derived from the hole geometry
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`and/or dimensions.
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`2.
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`The development of liner designs using experimentation and
`modeling techniques
`14. Liner design is a fundamental aspect of shaped charge design. For
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`example, Quattlebaum discloses that “[v]ariations of [liner designs], as has been
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`demonstrated and widely accepted within the industry, can be optimized to tailor the
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`performance of a charge for a given set of conditions, including optimizing hole
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`size.” Ex. 1007 at 8. I agree that varying liner designs to tailor shaped charge
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`performance is well known and routinely practiced by shaped charge designers in
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`the oil and gas industry. I also agree that tailoring shaped charge performance is
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`based on desired performance under the particular operational conditions in which
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`the shaped charge will be used. Desired performance may include forming a desired
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`hole shape in a rock formation.
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`15. Shaped charge designers have long known that liner properties such as
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`shape, thickness, and composition affect jet formation and resultant hole shapes.
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`Initially, the effects of liner variations were explored through trial and error
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 7 of 100
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`experimentation—Poulter describes this work as “cut-and-try” procedures. Ex.
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`1008, 1:41-48. This work produced extensive data correlating shaped charge designs
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`with perforation results.
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`16. For many decades, the industry has combined experimentation with
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`modeling to explore the effects of liner and shaped charge design variation on overall
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`shaped charge performance. Mathematical solvers known as “hydrocodes” have
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`been used to model and study shaped charge design and performance since about the
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`late 1960’s. These codes are based on the conservation equations of continuum
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`mechanics and use equations of state and strength models to resolve material
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`behavior. Hydrocodes enable the high resolution simulation of the physics and
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`resulting dynamics of shaped charge detonation, providing insight on a level of detail
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`that experiments alone cannot do for quantities such as pressure, velocity and
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`impulse. This allows us to understand the mechanism of jet formation in minute
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`detail for any charge and liner design and to alter the parameters of that charge or
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`liner design to target a desired performance. A highly resolved simulation allows us
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`to track the velocity and direction of each part of the liner as it forms the jet and to
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`understand how the jet is formed in order to maximize or optimize its performance.
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`Thus, charge designs for achieving desired jet or hole properties could be deduced
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`from general design parameters—for example, well-known conventional liner
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`shapes and corresponding jet or hole shapes—and modeling the effect of design
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 8 of 100
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`parameter variations on jet properties and corresponding hole properties. Using
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`experimental data in conjunction with modeling is standard practice in a rigorous
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`scientific approach and is important because all models necessarily make
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`simplifying assumptions in order to be manageable. This means that they have to be
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`validated against experimental observations that represent reality as closely as
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`possible. Until a model has been validated, the accuracy of its results remains in
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`question. For example, in the specific case of shaped charge simulations, the
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`pressure generated by the explosive is not simulated on a chemical reaction level as
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`this would require a simulation scale that is incompatible with the scale at which the
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`structural simulation is run, making the model infeasible. Instead, the pressure
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`exerted by the explosive is represented with an equation of state with parameters
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`derived either from experiments or from specialized simulation software that
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`calculates the parameters of the detonation for the equation of state. The exact
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`parameters governing the behavior of the explosive in the hydrocode charge
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`simulation, therefore, need to be validated against experimental results that
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`reproduce the simulated case and confirm the accuracy of the model so that its
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`predictions can be trusted.
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`17. Engineers
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`solved mathematics describing
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`the hydrodynamic
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`phenomena associated with shaped charge physics by hand before computer-based
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`codes and programs became available. Historically, a shaped charge designer would
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 9 of 100
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`use past experience, empirical data, and general design principles to “select” a liner
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`with a composition and/or geometry for making a desired hole shape, in a certain
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`rock type. The shaped charge designer would then run calculations varying certain
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`liner parameters to generate theoretical hole shapes for the variations and select the
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`liner design that achieved the theoretical desired hole shape. After fabricating the
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`selected liner according to the design properties, it could be tested under
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`standardized testing conditions designed to simulate downhole conditions. The
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`perforation created by the liner could be compared to the theoretical result to confirm
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`whether the liner design is likely to create the desired hole shape in an actual
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`downhole environment. If not, the iterations of liner variations could begin again
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`while the test results would add to liner design empirical data.
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`18. The performance of shaped charges has been modeled using computer
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`programs since well before even the December 13, 2012 filing date of the
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`GB1222474 application to which the ’039 Patent claims priority. Autodyn™ (in
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`development since 1986), JEPETA™, LS-Dyna (originally started development in
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`1976 and added explosive modeling capabilities in 1979), and OTI*HULL
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`(development started in 1971) represent just a few examples of programs that can be
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`used to model various aspects of shaped charge performance. Hydrocode solvers
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`available in these programs can model jet formation—among other things—based
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`on shaped charge design parameters including liner composition, geometry, etc.
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`DynaEnergetics Europe GmbH
`Ex. 1003
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`Different computer modeling programs may have different background
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`computational operations and theories of simulations but are nonetheless well-
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`known for modeling shaped charge performance. JEPETA™, for example, is an
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`analytical code used in a two-step process for modeling perforations in, e.g., a rock
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`formation that uses the properties of a perforation jet modeled using a hydrocode
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`such as Autodyn™ and the type of rock to calculate a hole depth and radial profile.
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`19.
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`It must be noted, however, that the introduction of these hydrocodes did
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`not change the basic iterative approach applied “manually” to designing a shaped
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`charge that, e.g., Poulter, refers to as “cut-and-try” (Ex. 1008 at 1:42-48, 2:8-11,
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`2:37-47)—it made it more efficient by speeding up operations, and providing
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`detailed insight of the jet collapse and formation process, to render each step in the
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`iteration more likely to get closer to the design goal more quickly. This was hugely
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`advantageous because in Poulter’s “cut-and-try” the designer would generate a
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`design based on their best estimate of the expected result, and then would test it
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`physically to produce a result. Id.. If the result differed from expectations, the
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`designer would iterate on the design and test again. This is a slow and expensive
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`process. With more and more tests, building a library of charge designs and
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`associated performance, allowing the designer to correlate cause and effect, he
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`would be able to converge onto a design. For each “cut” though, the only information
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`usually available would be the initial (before experiment) and final (after
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`DynaEnergetics Europe GmbH
`Ex. 1003
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`experiment) states, with no easy way of seeing the development of the jet. With
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`computer modeling, the level of insight changed by allowing the designer to play the
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`jet formation forwards and backwards in microsecond-scale timesteps and really
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`understand the dynamics, making the changes in design parameters more targeted,
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`producing a more efficient iterative process, but nevertheless an iterative one.
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`3.
`The use of prior results in the selection of liners
`20. Knowledge gained in simulation and testing of previous shaped charge
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`designs plays a key role in the design and development of improved shaped charges
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`and shaped charge liners. The exact design parameters of shaped charges and liners
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`represent a source of competitive advantage for companies in this industry and, as
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`such, remain closely guarded and proprietary. This information, conceptually stored
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`in a library relating design to performance, is of immense value to the designers as
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`it represents a reference or starting point for incremental development of improved
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`charge and liner designs, making the development process more efficient and less
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`expensive than it would otherwise be if every design began from a clean slate.
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`21. Shaped charge designers are, however, willing to share some fairly
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`generic charge specifications and performance figures. Industry groups work to
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`record and disseminate information regarding shaped charge performance that can
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`be used by designers to benchmark the performance of their designs against those of
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`their competitors using standardized tests. This conceptually enables them to gauge
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`DynaEnergetics Europe GmbH
`Ex. 1003
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`the efficacy of their design at least in relative terms. For example, the American
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`Petroleum Institute (API) promulgates industry standards (currently known as API
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`RP 19B and 19R (prior to 1998, API 43)) for oil and gas shaped charges. Shaped
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`charge manufacturers are able to test their charges against these standards and
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`provide data regarding those tests to API. Importantly, the API accepts and then
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`makes publicly available “data sheets” that describe the performance of certain
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`shaped
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`charges
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`against
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`a
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`number
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`of
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`metrics.
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`
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`See
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`https://mycerts.api.org/search/compositesearch, selecting the search term “API-
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`19B” from the Specification/Standard pull down menu. This returns a list of
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`companies, selecting any of which provides access to their registered charge
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`performance datasheets. The data sheets record the name of the shaped charge, some
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`basic parameters of the shaped charge (including explosive and case material),
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`specification of the concrete target, various environmental conditions under which
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`the testing was conducted, and parameters of the hole produced from each test shot
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`(including long and short axis lengths of the casing hole diameter and total depth).
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`22. Like API, some shaped charge manufacturers also make public their
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`own records detailing performance testing of shaped charges. For instance, the Jet
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`Research Centre (JRC), which is mentioned in the ’039 Patent, provides data sheets
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`for various charges on its own website. The data sheets record the name of the shaped
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`charge, parameters of the shaped charge (including explosive and case material),
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`DynaEnergetics Europe GmbH
`Ex. 1003
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`some conditions under which the testing was conducted, and parameters of the hole
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`produced from each test shot (including entrance hole diameter, variance in entrance
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`hole diameter and total depth).
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`B.
`23.
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`The ʼ039 Patent
`Independent claim 1 recites a method for manufacturing a shaped
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`charge liner for producing a desired hole shape. Steps [a] – [e] relate to various steps
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`for selecting and modifying a liner design, while step [f] requires forming the liner:
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`1. A method of manufacturing an enhanced shaped charge liner design for use
`in an oil/gas well perforator that is usable to form a desired hole shape in a
`rock formation, the method comprising
`[a] comparing the desired hole shape to a library of known liner designs,
`the library including data relating to a hole shape formed by each of the known
`liner designs within the library;
`[b] selecting a liner design from the known liner designs that produces
`a hole shape optimised to the desired hole shape;
`[c] varying at least one parameter of the selected liner design to form a
`modified liner design;
`[d] modeling the hole shape that the modified liner design produces;
`[e] repeating the varying and modeling steps until the hole shape of the
`modified liner design converges towards the desired hole shape to thereby
`create a final liner design; and
`[f] forming the enhanced shaped charge liner in accordance with the
`final liner design.
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`
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`DynaEnergetics Europe GmbH
`Ex. 1003
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` Examining the language of independent claim 1, a first point to note is
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`24.
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`that it claims a “method of manufacturing” a shaped charge liner when it actually
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`describes a method for designing a shaped charge liner. Nowhere in the claim is an
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`actual method for producing a finished charge liner described. Step [f], requires
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`“forming the enhanced shaped charge liner in accordance with the final liner
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`design”, acknowledging that the product of the actions described by claim 1 is not a
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`manufactured shaped charge liner, but rather a shaped charge liner design.
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`Additionally, merely introducing the word “forming” is still not sufficient to
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`describe a “method for manufacturing” as a number of viable methods are already
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`known for this purpose and this claim does not introduce a novel method.
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`25.
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` A second point to note is that the process described by claim 1 is a
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`process that is commonly known in engineering and problem solving in general. The
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`concept of a library, whether pre-existing or created as a result of the same process
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`described by claim 1, is well known in engineering and beyond. The idea that
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`information in such a library is used as a reference to provide a starting point for the
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`iterative design process is also not new and is common practice in any field where
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`research or development is conducted. If this weren’t so, then knowledge developed
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`through previous experience would have no value. The concept of iterative design
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`to arrive at an optimal solution, is also common practice in engineering and other
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`DynaEnergetics Europe GmbH
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`fields. In short, there is nothing in independent claim 1 that is novel or that was not
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`known long before the priority date of this ‘039 patent.
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`26. The invention claimed by independent claim 1 covers concepts that are
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`so basic and rudimentary that they cannot be eligible for patent protection, nor can
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`they be valid over the prior art cited in this declaration to support this assertion.
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`C. THE CITED PRIOR ART
`1.
`Davison
`27. Davison describes a “well perforator improvement effort … to increase
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`the jet energy and penetration as much as possible[.]” Ex. 1009 at 1. The objective
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`included maintaining the same shaped charge outer dimensions and limiting the
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`explosive mass. Id. Accordingly, Davison focuses on modifying the liner—“[t]he
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`most critical component of the perforator.” Id. Davison’s baseline liner was a
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`conventional conical liner that the study replaced with a bell-shaped liner having
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`variable thickness, “similar to ones that have shown significant gains in performance
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`in prior studies” (id.):
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`DynaEnergetics Europe GmbH
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`Id. at 3.
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`28. Davison discloses a five step approach for optimizing the “improved”
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`shaped charge design: “(1) Compute the perforator jetting with the definitive
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`AUTODYN 2D program; (2) Compute the hole shape using the analytical
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`penetration theory; (3) Derive liners that give jets of maximum energy and holes of
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`maximum size; (4) Test the most promising designs; and (5) Iterate to converge on
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`the ‘best’ design(s).” Id. at 4. Specifically, Davison varied the mass distribution of
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`the bell-shaped liner to optimize jet energy and target penetration. Id. at 6-7. The
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`mass was properly distributed along the liner—for purposes of the modeling
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`calculations—by varying the modeled liner thickness at different portions to reflect
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`measurements made on the manufactured liners, effectively calibrating the modeled
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`mass distributions. Id. at 6. Davison describes modeling using the AUTODYN 2D
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`hydrodynamic computer program “and its thin-shell jetting option” in which “[t]he
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`liner is characterized as a jetting thin shell coupled to a fully two-dimensional
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`representation of the explosive.” Id. at 1, 4. Davison also describes modeling the
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`hole shape using “[t]he JEPETA program [that] takes the jet produced by the jetting
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`thin shell model in AUTODYN 2D and computes its effect on a target [and] includes
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`the influence of target strength and jet breakup.” Id. at 5.
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`29. Davison concluded that the optimized bell-shaped (“improved”) liner
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`design according to the modeled iterations resulted in 10% greater jet kinetic energy
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`versus the baseline conical liner. Id. at 8. Specifically, Davison noted that the
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`improved bell-shaped liner with variable thickness and greater diameter also had
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`more surface area than the baseline, “and points along the improved liner travel
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`further than points along the baseline liner[, which all] contribute to an improved jet
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`… that creates a deeper and wider perforation[.]” Id. at 3. Davison reports certain
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`results according to the hole shape—e.g., entry hole diameter, total target
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`penetration, and diameter of the hole at the perforation bottom. Id.
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`2. Guinot
`30. Guinot discloses modifying a shaped charge design to produce
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`elliptically shaped perforations aimed at stabilizing the perforations and minimizing
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`the production of sand from the perforated rock formations. Ex. 1010 at Abstract.
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`Guinot illustrates the desired elliptically shaped hole in FIGS. 1B-1D:
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`DynaEnergetics Europe GmbH
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`31. According to Guinot, “[b]y modifying the liner one could create non-
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`circular jets[.]” Id. at 10:61-64. While Guinot’s “design iterations were directed [to
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`the shaped charge case],” this is only because “modifications to the case are
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`comparatively easy to make,” where “fabrication of … a [modified] liner is more
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`difficult.” Id. at 10:61-66. Guinot does not describe liner modifications as
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`undesirable but in fact expressly discloses—despite the design iterations being
`
`directed to the case—modifying a liner to achieve the desired hole shape.
`
`32. Guinot’s method for optimizing a shaped charge design includes
`
`numerically modeling the shapes of the jets produced by a given shaped charge
`
`design and iterating on that design. Id. at 7:10-16, 10:26-35, 10:60-67. In one
`
`
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 19 of 100
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`PGR2023-00003
`U.S. Patent No. 11,215,039
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`example, optimizing may mean achieving an elliptically shaped hole with a
`
`particular aspect ratio. Id. at 3:64–4:6, 11:25-31. Orthogonal views of a
`
`representative modified shaped charge are shown in FIGS. 14A and 14B,
`
`highlighting the modifications made to the charge design in order to shape the jet to
`
`be elliptical and to produce an elliptical hole. FIGS. 17A and 17B show hydrocode
`
`modeling of the jet produced by the charge depicted in FIGS. 14A and 14B, FIG.
`
`17A showing the mid jet cross-section and FIG. 17B showing the jet tip cross-
`
`section. Guinot further labels the figures, represented below, as showing the
`
`expected “JET & HOLE PROFILE[S].” In other words, hydrocode modeling of the
`
`jet can also provide a model of the expected resulting hole. See id. at 11:27-31.
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`
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`
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 20 of 100
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`PGR2023-00003
`U.S. Patent No. 11,215,039
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`
`
`3. Quattlebaum
`33. Quattlebaum discusses optimizing shaped charge design and
`
`specifically that “[b]road improvements have been applied in the design and
`
`materials [for specially designed shaped charges] as the physics have become better
`
`understood and testing techniques have advanced and evolved.” Ex. 1007 at 1. For
`
`example, “[j]et perforator performance can vary greatly depending upon the
`
`particular materials used in the charge case and liner [and] the geometric shape and
`
`dimensions of the liner, charge case, and explosive column.” Id. at 6, 8. “Variations
`
`of these three components, as has been demonstrated and widely accepted within the
`
`industry, can be optimized to tailor the performance of a charge for a given set of
`
`conditions, including optimizing hole size[.]” Id. at 8. Further, “[r]ecent studies”—
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`
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 21 of 100
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`PGR2023-00003
`U.S. Patent No. 11,215,039
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`i.e., an existing library of empirical data—show that “manufacturing process can
`
`also significantly affect performance.” Id.
`
`34. Quattlebaum discloses a shaped charge “developed and manufactured”
`
`to achieve a desired hole size and minimize hole size variations due to, e.g., different
`
`distances between the shaped charges and the rock formation when a perforating gun
`
`is off-center within the wellbore casing. Id. The desired hole size is determined by
`
`calculating the size and number of holes that are required to distribute stimulation
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`fluid evenly across perforations in the intended interval, for maximizing well
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`stimulation (fracturing of rock formation) and production. Id. at 2. Quattlebaum’s
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`optimized shaped charge was developed and manufactured and deployed to the field
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`for various field trials. Id. at 9. The field trials included different wells having
`
`different rock formations, compositions, and/or properties. Id. at 9-12. Quattlebaum
`
`judges the shaped charge performance by the wellbore treatment pressure and flow
`
`rate measured in each of the field trials.
`
`4. Walters
`35. Walters is a shaped charge textbook excerpt discussing and disclosing
`
`a wide variety of shaped charge features, properties, dynamics, and experiments.
`
`Walters describes the excerpted pages as “present[ing] the ‘picture book’ of shaped
`
`charge examples and applications.” Ex. 1014 at 329. In fact, Walters’ “picture book”
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`shows an optimized liner design including variable angles and thickness:
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`
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 22 of 100
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`PGR2023-00003
`U.S. Patent No. 11,215,039
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`
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`Id. at 330.
`
`Id. at 331.
`
`36. Walters includes descriptions and illustrations of computer modeling
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`and experimental testing for liners with numerous variables including materials (at
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`334, 336, 343, 375), thicknesses (at 375, 381, Table 1), and apex angles (at 334, 336,
`
`Figures 9, 14-16). Among other things, Walters shows and describes jet formation
`
`simulations with numerical studies from HELP and EPIC-2 computer codes
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`generating profiles such as those in Figure 22:
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`
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 23 of 100
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`
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`PGR2023-00003
`U.S. Patent No. 11,215,039
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`
`
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`Id. at 343.
`
`37.
`
`In another study, Walters tabulates data from iterative testing of
`
`hemispherical lead liners having different thicknesses, id. at 375, and summarizes in
`
`Table 1 (id. at 381) results including penetration depth and jet velocity for varying
`
`liner thickness. The data suggests that jet quality, as indicated by depth of
`
`penetration, is maximum for an optimal liner thickness in the tested range of liner
`
`thicknesses.
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`
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 24 of 100
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`PGR2023-00003
`U.S. Patent No. 11,215,039
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`38. Walters also includes a reference to work done by Geiger and Honcia
`
`in 1977, where the behavior of a planar symmetric liner of pyramidal shape was
`
`studied, id. at 330. In the accompanying Figure 3 (id. at 331) shown below, a
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`radiograph is shown of the jet formation exhibiting features similar in nature to those
`
`modeled and described in the ’039 Patent.
`
`
`
`5.
`Smith
`39. Smith “describes the development and field testing of alternative
`
`charge designs aimed at improving performance in high compressive strength
`
`formations” and presents computer simulations and laboratory tests showing the
`
`improved charge design performance. Ex. 1015 at 1. Importantly—as with Guinot
`
`and Davison—Smith discloses using mathematical modeling principles in
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`conjunction with empirical data to effectively predict shaped charge performance.
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`
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`DynaEnergetics Europe GmbH
`Ex. 1003
`Page 25 of 100
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`PGR2023-00003
`U.S. Patent No. 11,215,039
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`Id
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