Free Exhibits - District Court of Colorado - Colorado

Case 1:03-cv-02579-RPM
Wildcat

Document 148-6
Ben
-v-

Filed 01/11/2007
Systems

Page 1 of 3

05-25-04 Pason

Services

USA

Page

IN

FOR

UNITED STATES THE DISTRICT

COURT DISTRICT COLORADO

WILDCAT

L.P
Plaintiff
CIVIL

ACTION

NO

VS
03M2579
PASON SYSTEMS USA

BNB

Defendant

10

ORAL
12

AND

VIDEOTAPED
MAY

DEPOSITION

OF

THOMAS

25

2004

13

15 16

THIS
18

DESIGNATED TRANSCRIPT CONTAINS TESTIMONY BY COUNSEL AS CONFIDENTIAL

ORAL
20 21

AND
as

VIDEOTAPED DEPOSITION
witness
at the

OF

THOMAS

Plaintiff

and
to

sworn
numbered

instance of the taken in the
on

cause

Tuesday
Mary

May

25

2004
22

1034

a.m

before
463

23

24 25

Reporter and State of Texas reported by machine shorthand and audio/video recording at the offices of West South Firm Suite 1800 Houston to Agreement of Texas and Counsel and Federal Rules of Civil Procedure he re ord the provisions $seted on attached Public
in

Certified Shorthand

Dopico Notary

hereto

EXHIBIT

to
Fax

713

521-111

713

520-0084

Case 1:03-cv-02579-RPM

Document 148-6

Filed 01/11/2007

Page Page 2 of 3

of

Thomas Ben 2004-05-25
38
or not the Has ever anyone Pason device of the discussed the of you Wildcat whether

Yes
Out presence your

lawyer
fl
t%S

No
tr

0944 0944 0944 0944 0944
tV

Thomas Ben 2004-05-25
41
Nobodys
for you the Has anybody
10 11 12 13 14 15

Pason ever Or

ever device

--

Has
--

anyone the Wildcat Anybody ever

compared

showed have

you

said

Well
about about

we

dont

it

this We have this
the

dont
We got
of

to worry to be careful

of Uh-htth

presence

attorneys

No

0948 0948 0948 0948 0948 0948 0949 0949 0949

Case 1:03-cv-02579-RPM

Document 148-6
Ben

Filed 01/11/2007
USA

Page 3 of 3

Thomas
L.P

05-25-04

Wildcat Services

-v

Pason

Page

Page 40

they Yes
sir

0943 0943
discussed with you the Wildcat question

MS
0944 0944
rephrase

LAFF

Object
if

to the

the

You may

you

0947 0947
you

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or not the Pason

whether patent

Yes

BY MR MATTHEWS
it

want me

to

0947

Yes
Out of
presence of your

0944
lawyer

0947

0944 Okay
made

No
Has anyone ever
this told prior

0944
you Pason

0944
going
10 or
their

stay on

the

same

road

theyre that

0947

device

based

upon

0944 0944
Do you know
that device

provided only Again
--

10 11 12 13 14 15 16 17 18 19 20 21 22 23 other

No
Do you
not there has ever

0947
what youre

know been

--

whether

0944
--

test

compared
that Pason

0945 0945
14
telling

assuming
is --

you

know

device

and the

me

0947 0947

No
Have you Between The Between
---

0945
heard of such

test

0945 0945

15 16
1.8

--

thats Pason or whatever percent up of then
-it

0947
where move
from
to

0945
device Wildcat of

And
percent to 34
it

0947

and
automatic
tests

Pason

device and the
--

was

with respect other

the

18

words
be

have heard
another

between other and
Pason

0945 0945
20 21

moves

percentage-wise
hit

0948

between

automatic

very

substantial

on

Wildcat Object

0948
the

0945
do not know
automatic
driller specifically
if

MS

to the

0945 0945
test

22 23 24
to

was

Wildcat

BY MR MATTHEWS
38
--

--

from

1.8

percent

up

0948

24
25

And the other automatic
to versus

34

percent

0948 0948

weight-on-bit

test

25

Yes

Page didnt it believe that

Page

41

Yeah
was the set-up

Have you

obtained

0948

0945 0945

patent

before

Sir
believe that

No
0945
it

sir

0948
been involved
in

was the set-up there whose
automatic

Have you
at

that

process

0948

Do you know

0945 0946 0946
or

all

No
Okay
said guess automatic 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 it the
all

0946
What
the percentage of about
1.8
--

No
you the

sir

0948
ever
--

Well youve
of percent

Nobodys

Has anyone ever compared
with

0948 0948 0948

percentage
for

Pawn

device

patent
--

Pawn was

0946
10 11 12 13 14 15 16

anybody ever showed

you

Anybody ever

said

like

that
--

0946
thats based on
daily

we dont
about

dont
got

to worry be
careful

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basis

thats

0946

Or

0946 Okay
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the course that of
this

0946
quarter
it

Outside

of

presence

of

0949 0949 0949 0949 0949 0949 0949

average

out

may 0946 0946
is

Uh-huh

No
attorneys
attorneys Are have you have

Okay
automatic automatic
their If their

And
then
is its

only product revenue percent
is

driller drillers

with of
its

respect revenue
if

0946 0946 0946

17

you

including directly
--

nobody

only

product
their

correct that

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only

would be

Yeah
21 got

revenues Sure And
that
is

0946
their

them

out-house

0949 0949

only

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0947
09J47

we

out-house

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respecto

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percentage

27

MS
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to

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substanti hitjn

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0949 okay

25
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11 Pages Mary Fax Reporting mdnnirnThcnnnnf

38

to

41

713

521-1118

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