`FOR THE SOUTHERN DISTRICT OF TEXAS
`HOUSTON DIVISION
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`Civil Action No. 4:22-cv-00965
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`JURY TRIAL DEMANDED
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`§
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`C&M OILFIELD RENTALS, LLC
`D/B/A C-MOR ENERGY SERVICES,
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`Plaintiff,
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`v.
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`ENSIGN US SOUTHERN DRILLING
`LLC,
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`Defendant.
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`PLAINTIFF C&M OILFIELD RENTALS, LLC’S
`DISCLOSURE OF PROPOSED CLAIM TERMS FOR CONSTRUCTION
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`Pursuant to the Patent Scheduling Order (ECF No. 35), the Court’s Order Extending
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`Certain Deadlines of the Scheduling Order (ECF No. 43), and P.R. 4-1, Plaintiff C&M Oilfield
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`Rentals, LLC (“C&M”) identifies below its proposed terms or phrases for construction from the
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`asserted claims of U.S. Patent Nos. 10,900,626 and 10,976,016. C&M’s identification of claim
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`terms or phrases below include the identification of terms within those phrases.
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`C&M reserves the right to supplement, revise, modify, and/or otherwise finalize its
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`proposed terms and claim elements for construction by, without limitation: (i) adding or removing
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`surrounding words from the identified term or claim limitation; (ii) combining two proposed terms
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`or constructions into a single proposed term or claim element; and/or (iii) splitting a proposed term
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`or claim element into two or more proposed terms or constructions.
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`C&M also reserves the right to supplement, revise, modify, and/or otherwise finalize its
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`proposed terms and claim elements for construction in response to, without limitation: (i) any term
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`or claim element proposed by Defendant Ensign US Southern Drilling, LLC (“Ensign”) for
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`construction; (ii) any evidence and supporting materials cited or otherwise identified by Ensign;
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`Petitioner Ensign
`Exhibit 1016 - 1 of 3
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`or (iii) any argument by Ensign. C&M further reserves the right to present constructions, if
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`necessary, for any term or claim element proposed by Ensign for construction.
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`C&M’s proposed terms and claim elements for construction are as follows:
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` “crown deck” (claims 9 and 19 of the ’626 Patent and claims 1, 2, 23 of the ’016 Patent)
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` “mounting pole” (claims 9 and 19 of the ’626 Patent and claims 1 and 23 of the ’016
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`Patent).
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`Dated: March 27, 2023
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`
`Jason C. White (admitted pro hac vice)
`jason.white@morganlewis.com
`Karon F. Fowler (admitted pro hac vice)
`karon.fowler@morganlewis.com
`Eugene S. Hwangbo (admitted pro hac vice)
`eugene.hwangbo@morganlewis.com
`MORGAN, LEWIS & BOCKIUS LLP
`110 North Wacker Drive, Suite 2800
`Chicago, Illinois 60606
`T: 312.324.1000
`F: 312.324.1001
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`Respectfully submitted,
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` /s/ Elizabeth M. Chiaviello
`Susan Stradley
`Texas State Bar No. 24116787
`Southern District of Texas No. 3710386
`susan.stradley@morganlewis.com
`MORGAN, LEWIS & BOCKIUS LLP
`1000 Louisiana Street, Suite 4000
`Houston, Texas 77002-5006
`T: 713.890.5000
`F: 713.890.5001
`
`Elizabeth M. Chiaviello
`Texas Bar No. 24088913
`elizabeth.chiaviello@morganlewis.com
`MORGAN, LEWIS & BOCKIUS, LLP
`1717 Main Street, Suite 3200
`Dallas, Texas 75201
`(214) 466-4000 Telephone
`(713) 466-4001 Facsimile
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`Attorneys for Plaintiff C&M Oilfield Rentals, LLC
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`2
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`Petitioner Ensign
`Exhibit 1016 - 2 of 3
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`CERTIFICATE OF SERVICE
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`The undersigned counsel hereby certifies that a true and correct copy of the foregoing
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`document was served via the Court’s ECF/CM e-filing system to all counsel of record on March
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`27, 2023.
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`/s/ Elizabeth M. Chiaviello
`Elizabeth M. Chiaviello
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`3
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`Petitioner Ensign
`Exhibit 1016 - 3 of 3
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