Free Exhibits - District Court of Colorado - Colorado

Case 1:03-cv-02579-RPM

Document 148-8

Filed 01/11/2007

Page 1 of 6

Jm
____

LEIER TERRY SaturdayMayl5.20048O8AM
Ford
Trevor

Cc
Subject

Holt Bob Desperate

[email protected]

kbergeltirelandstapletofl.C0Ifl

REf

-Ri

Ford would say that looking at this again after our discussions yesterday the of 14 is actually directed as that is the original analysis four claim does not refer at all to differences from differential table set point or selected value Une The disclosure at columns just 26 through column .14 the claim describes different tb.ixzg than what What is says the disclosure describes let point or selected value set Out in claim 14 is really not supported or described in the disclosure at all and the and should be for that reason alone At best the claim is indefinite should be for that reason too youll
be have afraid

Ford

Dont

to decide what claim scope is to you and put that to tackle scope issues if you see the claim that on what your article says and many other publications the end interpretation of claim 14 would read on the prior art anyways and for what old Terry laSer
Cassels

your
way as

well scope or

report

is invalid

Slake
World 20th tiP

Exchange

Graydon Plaza

LLP Street

Floor

45

Ottawa

Ontario

613.1992244

E-mail
This email communi cat ion is CONFIDENTIAL AND LEGALLY intended recipient number please notify me at the email and this and any copy immediately
If you shown above Thank you

not
or by

the return

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dans cc message Ølectronique est CONFIDENTIELLE Si cc message est parvenu par erreur de nous aviser immCdiatement par tØlØphone ou courriel message immØdiatement Merci

irons

PRIVILtGIEE El legalement OEtes en consequence priC Dc plus cletruirece

Original

From LEXER TERRY Sent Friday May14

Message
2004 PM blaf.fi3irelandstapleton.com

Ioeponenta..T
Date/RPR

To Cc

Ford

Brett

Trevor Subject RE

felt so
Wildcats

Desperate

Move

14 is that of claim got this note from Trevor Bolt at Pason Hisunderstanding differences in the between set point and differences referred to are measured with This description of operation given in ThuS the Bowden us pateftt 26 through column 14 line 10 over columns 11 line set out condition differences in the Bowden claim track example table
Hi the

pple
it

table

ROP

.aintain

understand Trevors explanation the this parameter as well He said WOE and Pressure the system adjusts these set pointi
for

as

Pason

The

tracks the condition or limits user enters set points to brake handle appropriatel.Y

Case 1:03-cv-02579-RPM

Document 148-8

Filed 01/11/2007

Page 2 of 6

Consequently

the of

technical claim

the

explanation

parameters

14

appears

to

be

system

within

____

14

also and
as of

isured
selecting

selecting pressure

one

step control namely
and
the of

ROP
that

goes

to

state

that

selecting

an4her parameter stepof claim 14

is

While Pason

aOP or other conditions in seem to me that control
within
the

the Pason system may 4elect none based on have it would developed empirically would operate at least some ofthe time

parameters

of

claim

14
to

Consequently the parametersof Unless
there that
is

technical claim 14 basis
to of

explanation appears least some of invalidate
the

be

that

Pason

system

operates

within

time
the
is to

to

fall

hearing Terry

scope affirms the

the

claim
there

the claim the if Therefore does not seem to me

Pason

system

appears

be any

other

defense

issues

Blake

Terry

world 20th Floor

Lejer Cassels Exchange
45

Oraydon

z4.P

OConnor

Street

Ottawa
IC1P

Ontario

Tel Fax

613.788.2244 613.788.2247

E-mail terry.1eierblas.com

-s email communication nded recipient
and
delete

is CONFIDENTIAL please me at the this communication and any copy

If

you are not the above or by return

immediately

Thank

you
ST prid cc

Linformation apparaissant dans cc message Ølectronigue est lØgalement PRIVILEGIES CONFIDENTIELLE Si Ce message est parvenu erreur vous Øtes en consequence de nous aviser immCdiatement par tØlØphone ou courriel Dc plus immddiatement message Merci

Original

Cc

From Trevor Sent Friday Nay To LEIER TERM
Bob

Message .Boltepason.comj
2004 PM

Subject

Rodda Trevor RE Wildcats

Desperate

Move

Hi

Terry

am forwarding This may give more of an you some information that sent to Ford Brett into the understanding of in assuming Your Pason AutoDriller system that our algorithm is quite different then defined the fLur ranges mentioned for claim 14 Its hard to put our algorithm into one category range control or Pin we use combination of both and to other conditions the algorithm that developed empirically ROW could be thought of as third parameter in the range table you have made
the thought reference to differential pressure control was to the fact that one of the meters being controlled the control was was differential pressure and not that orming differential control as in PID loop To us differential pressure is .ined as off bottom standpipe pressure current So technically standpipe pressure .s the end we are consistent stand-pipe pressure trying to maintain

hope

this

information

helps...

____________________________________________________________

Case 1:03-cv-02579-RPM

Document 148-8

Filed 01/11/2007

Page 3 of 6

thanks
evor Holt

Pason

Autotriller The Pason

System

Overview
ties

AutojDrjller

Standpipe

Pressure ROP
high
izesolution

depth
encoder

into the Pason and torque
is is

EDR

system

tor feedback

Weight

OnBit

used used

to monitor
to

An

electri

brake

stepper

pull on

the brake

handle

of

band

depth torque more braking or
correct

microprocessor is used the less braking stepping

to interpret thee eedback from the WOE pressure ROP movement to dec4de whether encoder needed to maintain its set points It then sends out the to the stepper motor to move the brake handle appropriately and Pressure set points that the system

adusts
Pason

The user enters set points or limits for ROP WOE the brake handle appropriately to maintain these Wildcat differences controlled from mechanical from

Autoflri.ler/ Pason uses

motor Pason

microprocessor

instead

of

pneumatic

apparatus

g2ustmentsfor

jring
the

systems

software different and other

based System is more flexible than the Wildcat system ItO ranges eta are taken care of insoftware instead of the Wildcat mechinicalapparatus used system control

Pasons
fully following

system is fully electronic sensors pneumatic/mechanicalsystem that for senior feedbackx technologies

box
The

uses

stepper motor compared system uses the

to

electronic pressure transducer electronic hook-load beam ItO target ring and electronic proximity sensors Draw-works movement electronic high-resolution

Presiure

WOE

crown

fast

sheave

encoder

The user enters absolute set points into the GUI of Pason EDR system i.e WOE in pounds pressure in flOP in panel as opposed to the primitive WildCat of dials with no reference to the value They adjust your actuallysetting it to and then check their sages to see if they achieved the Set point were looking for Because electronic system and conditions and add an extra level software itself is algorithm situation is detected the AutoDriller the system we are able to monitor number of parameters Each sensor and If integrity suspicious type of control is not present in vast

of safety in real time

operation

disabled

The
do not employ any

patent relays

has of or pneumatics

references to relays and pneumatic our system Ut fully electronic

dªices

We

use

that understand the fact that number of other prior patents are to their Wildcat pressure means that patent is specific implementation Their implementation covers drilling with differential pressure using umatics and relays as described use this type of an in Clearly we do patent

From what differential

lementation

.flSflaflflflflant
From
Original Bob Message--

Case 1:03-cv-02579-RPM

Document 148-8

Filed 01/11/2007

Page 4 of 6

Sentt Friday May Trevor Edt

14

2004

922

AM Move

ject

flit

Wildcets

Desperate

revoit

Take

look at

bob
Original

Terrys

below

and let

me

know

your

thoughts

From LEIER TERRY mai1toTERRY.bExERtsblakes Sent Thursday May 13 2004 159 PM

Message

.conj

To Cc

TERRY blafflsirelandstapleton.com Bob Rodda [email protected] kmccarthysirelandstapleton Subject RE Wildcats Desperate Move

LEIER

cots

ES claim 14 Ford Brett has indicAted he has his own prior use information might There part of his report that as may be validity attack art unconsidered the USPTOaS discussed in my letter to Jim Hill of Qctober 29 2002 that you have Most the patents discussed in Jims were sent to you-but not 4519585 to Furrow This letter 4046355 to Martin which are attached brief introductory outline of the claim of the prior art in relation to Bowden 14 As mentioned none of these prior art patent documents were considered by USPTO nor are.tbey part of the the should request Judge in the FedCt action be very receptive to them as it is new ground can provide further comments more comments for Brett specific the appropriate desired time tension as sensor 35 and claim 14 prbxy for.weight on bit bit weight in bit -which take to mean weight the on bit as the weight bit not change unless it approaches of so all tension prior art also-essentially deals with the same There are however in using thing problems A4tepsionas the drill ituck or proxy for weight on bit because string can.get thedrill string can g around bends curves And lie on its numerous adjustments/corrections to cable tension to map to weight on bit Bowden refers uses cable to changes

cFi0n5

In addition to the Hill letter There is the never did file Examiner claim
14 simply first

issue of the there-is the issue of whether disclosure the formof continuation application for make sense of it

the

is over the art listed claim defines the added notes to the Examiner that Bowden The Does the Basic disclosure make sense

both said
Claim 14

refers to selecting any one of said first signal said second and said second signals to control the release of said drill changes signaling There are however changes conditions

signal

and

callsf or

namely

Indreasing Fluid Pressure Increasing Bit weight Decreasing weight

Decreasing Fluid Pressure

We

have to look at the disclosure and whether such release is good

to

see

what
if

the

e.g

operates
the

it out prematurely something or wears invalid for claiming are an unworkable there is the the invention

release would be in these or good rig correctly then release is good and bad
the

conditions

breaks
claims

fldditioa and use
inadequate

that .ajections to be supported

by

an

teaches one whether adequately there are problems are not explained or the given the added explanation in the response to the then claims are bad the invention inventions of how to make and use the adequate If

how

to

failure

Case 1:03-cv-02579-RPM

Document 148-8

Filed 01/11/2007

Page 5 of 6

and assuming the are valid the question of infringement reviewed all the new Pawn disclosure detail at all that were directed to technical of the invention aspects Im not s1kt thd see some that Pawn uses differential control at all or range control control portaonai integral derivative table range control would have the fdllowing thing
the

J%fter

all

above

arises

have

not

ie

Low Fluid .aOW weight

inrange
Pressure Fluid Pressure

High Fluid Pressure

in

range

itweight
High

itweight
such conditions
measurements three more claim 14 To include not defined by the derivative of claim 14 would require calculating and to changes measurements shifting away from range measurements rows and three more columns giving as follows
called

system for

the the which

adds

ow

Low Decreasing Fluid Pressure Decreasing

increasing Fluid

In range Decreasing Fluid

range Increasing Fluid

In

High Decreasing Fluid Pressure

High Fluid Pressure

itweight
Decreasing
10 11 12

Jwei9ht
LU range
Bit in weight range
19 20 13 14 15

15

17

sit weight
High

22

23

24

sit weight
gigh

25

28

29

30

31
must with

34

range
36

course Oontrol

conditions
the

conditions claim 14 over

look at the Pason determine how it operates Clearly the conditions differential ranges control its simpler than dont knOw that Pason would any benefit by going to the 36 for control falling scope of the changes called condition controller simpler

this entire Naturally we develop and any engineer provide expert input works Autodriller can explain how

of reasoning involved in the technical

time

is

right
of

aspects

Brett Pason

can

on the patent prosecutfon side European prior art to US the exam nation as well

patent

are other off

issues relating to the failure to disclose chance to address these in We may get

t.e
j.erry

pretty

much

road

map

should

we

need

it

Case 1:03-cv-02579-RPM

Document 148-8

Filed 01/11/2007

Page 6 of 6

Blake
tti

Terry

LaSer
Exchange 45 Ontario

rld
Tel Fax

Graydon Plaza

LLP

tawa
lA4

613.788.2244 613.788.2247 E-utail terry.leierblakescom

hSs
email

email and

communication

1tntended

recipient

CONFIDENTIAL please notify me at this communication and

the

any

If LEGALLY PRIVILEGED shown telephone immediately

you

are not the or by return

you

inforntion appaissant PRWILGIS El dana cc message Ølectronique eat lØgal-ement CONFIDENTIELLE Si cc eat vous OEtes en consequence message priC parvenu par erreur de nous aviser immØdiatement par tØlØphone on courriel Dc plus veuillez ddtruire.ce immØdiatement Merci message