Free Exhibits - District Court of Colorado - Colorado


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Date: January 11, 2007
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State: Colorado
Category: District Court of Colorado
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Case 1:03-cv-02579-RPM

Document 148-2

Filed 01/11/2007

Page 1 of 5

From
it

LEIER TERRY
Friday May Ford Brett Trevor

14

208 PM

Cc

RE

Ford1 from Trevor got this note the differences referred to in measured This understanding in the Bowden US patent over columns differences set out in the

Hi

Holt

ii

at Pason His understanding of claim 14 is between are differences set point and the description of operation line 10 line 26 through column 14 Thus the

that

would Pason

condition

example

table

Moreover

as understand Trevors explanation the this parameter He said example table as well for ROP WOE and Pressure that system adjusts maintain these set points

The

condition the system tracks or limits user enters set points handle to appropriately

consequently
the parameters

the of

appears

to

be that

Pason

operates

within

14

claim 14 measured

also

has used

one selecting HOP or other conditions in seem to me that the control within the parameters of
-nsequently the
parameters Unless to fall hearing Terry Leier cassels Exchange
45

as

step control namely pressure and weight
the

HOP

goes

While that algorithm of Pason algorithm

is to state that parameter The selecting step of claim 14 requires the Pason system may select none based on it would have been developed empirically would operate least some of the time

14
explanation appears at least some of to be that Pason system operates within

of

claim basis

14

there within

the scope affirms the

of Pason to invalidate the claim operation appears is of claim if Markman/constructiOn Therefore issues does not seem to me to be any other claim

Blake
World 20th

Graydon Plaza

LLP Street

Ottawa
K1P

Ontario

Tel Fax

613.788.2247 [email protected] AND the any LEGALLY

E-mail

EBII
PRIVILEGED
number
If

This email communication is coNFIDENT1At intended recipient please notify me at email and communication and

you are not the above or by return

immediately

you

Linformation cONFIDENTIELLE
de nous message aviser

PRIVILEGIEE ET est lØgalement dans Le message Clectronique OEtes en consequence priØ est parvenu par erreur vous vous message ddtruire cc immCdiatement courriel De plus veuillez par tØlØphone ou
Si cc

immddiatement

Merci

Original Message----From Trevor Holt Trevor

EXHIBIT

DATE

[email protected] EXAM OFSHERALEE

Sent Friday

May

14

MORRISON COURT REPORTER

Case 1:03-cv-02579-RPM
To Cc LEIER Rodda

Document 148-2

Filed 01/11/2007

Page 2 of 5

Bob

Subject

RE

Trevor Desperate Move

Wildcats

Terry
am forwarding you information that sent to Ford Brett This may give more of an the of the Pason AutoDriller correct in understanding system that our algorithm is quite different that defined by the four ranges mentioned for claim 14 hard to into one category we use our algorithm range control or PID combination of both and in that have to other algorithm developed ROP could as third parameter in range table made you have thought parameters performing defined as in end hope this reference to differential pressure control was to the fact that one of the controlled was differential pressure and not that control was control PID loop To us differential pressure is as in off bottom So technically current pressure pressure standpipe we consistent stand-pipe pressure trying to maintain being information

helps..

Thanks
Trevor

Holt

Pason

AutoDriller System
The Pason

Overview ties into the Pason and torque used
is

AutoDriller

EDR

for feedback

of

Weight

on

Bit

andpipe

Pressure

ROP

depth
encoder motor

high-resolution electric brake

to monitor to pull on the brake

movement
handle of standard

stepper

used

system
is to interpret the feedback from EDR microprocessor WOB pressure ROP the high-resolution to decide whetther encoder draw-works movement then sends put the or less braking is needed to maintain set points It braking

depth

torque

more correct

stepping

signals

to

the

stepper or

to

move

the brake and Pressure
set

adjusts Pason

The user enters set the brake handle Wildcat

points

limits for ROP these to maintain

that

system

points

AutoDriller Pason uses controlled

motor

controlled stepper from mechanical apparatus based ROP system and
is are

microprocessor

instead

of

pneumatic

Pason is software for different Adjustments gearing systems and

ranges

etc

apparatus

more flexible than the WildCat system instead of taken care of in used by the Wildcat system

Pasons
the fully following

is fully electronic sensors pneumatic/mechanical system that Wildcat for sensor feedback technologies

box uses
The

compared stepper motor Pason system uses the

to

Pressure

WOB HOP

electronic electronic

Draw-works The in pounds user

pressure transducer beam sensors on crown fast ring and electronic movement electronic high-resolution shaft encoder absolute
set

sheave

enters
in

pressure

PSI

points in ft/Hr

the
as

of to

opposed

Pason EDR system i.e WOB front panel the primitive Wildcat

Case 1:03-cv-02579-RPM
of analog
and dials check their no reference gages
to see

Document 148-2
to
if

Filed 01/11/2007

Page 3 of 5

the they

then

it to your actually setting They adjust achieved the set point they were for looking

Because it electronic vast number able to monitor system we parameters conditions and an extra level of safety during Each sensor and tware algorithm itself monitored in real time for integrity If suspicious situation is detected AutoDriller is disabled This type of control not present the Wildcat system The Wildcat employ any
patent relays has number of in or pneumatics
to

in

do

not

our

system

it

relays and is fully

devices electronic

We

From what fact differential pressure means that Their implementation implementation and relays as described in pneumatics implementation
use

number that are prior patents to their patent is covers differential pressure using drilling their patent Clearly we do not use this type of an

From Sent

Original Message Bob Rodda

To

Friday

May Holt

14

2004

922

AM Move

Subject

FW

Wildcats

Desperate

Trevor Take bob

look

at

Terrys

email

below

me

know

your

thoughts

Original

Prom
tt

LEIER

Message TERRY mailto

TERRY

.com
Bob Rodda

2004 159 PM Thursday May LJEIER TERRY [email protected]

cc
Hi

[email protected] RE Wildcats Desperate Subject

[email protected]

that for claim 14 Ford Brett has indicated he has his own prior use information is other of his report that may be used as prior might part validity art unconsidered in my letter to Jim Hill 29 by the CJSPTO as discussed that you have Most of the patents discussed were sent you but not and 4046355 to Martin which are attached This letter 4519585 claim of introductory of brief prior art in relation tn Eowden 14 As mentioned none of art patent documents were considered USPTO by in the action should So the Judge nor are they part of request

Barb

be

very specific Bowden

receptive comments

them as it for Brett at the
to

new

ground

appropriate

can time

provide

comments

more

desired

uses cable as on bit sensor 35 and claim 14 weight proxy for weight in of the refers to changes which take to mean weight on bit as the weight not change unless bit the speed of light so all cable approaches in cable art also essentially deals with the same thing are however problems tension as the drill string can get stuck or proxy for weight on bit and lie on its around bends and curves making portions of the drill string can for numerous adjustments/corrections to get cable tension to map to weight on bit of whether the to the In addition is the issue of the Hill whether is the missing There in the disclosure did continuation never for application aminer .saim both Claim
14

claim claim added Does the

valid over defines notes Basic

the the

prior

art listed

in

invention
Examiner that

disclosure

sense

Bowden The

sense simply

of

said
14

refers to selecting and said second for changes

any

to

one of said first signal said control the release of said are however changes

second

signal

and

string

calls

signaling

There

conditions

Case 1:03-cv-02579-RPM

Document 148-2

Filed 01/11/2007

Page 4 of 5

Increasing Fluid Pressure

Decreasing Fluid Pressure

reasing weight Decreasing weight

we have and

to look

at

the disclosure
is

to

see

what
the

the

would or no good then

conditions

e.g

operates invention

or wears it out prematurely something an unworkable are invalid for claiming
In

the rig correctly release is good

breaks
claims

addition
use

there the

is

the

issue

make

invention If there is inadequate particularly given the that he couldnt objections
to be supported all the an adequate

teaches one how to adequately are not explained or the disclosure problems in the response added to the Examiners the invention the claims are bad for disclosure of how to make use the invention
of are

whether

and the claims are valid the question of infringement reviewed all of the new Pason disclosure in at all but see some that were directed of invention Im not to technical aspects sure that Pason uses differential control at all perhaps or range control table proportional integral derivative PID control range control like the something

After

arises

not

Low Fluid nw weight In range Bit weight High Bit

Pressure

In range Fluid Pressure

High Fluid

Pressure

Such conditions measurements three more

system for and

is

not

defined by would 14 from range

shifting and three Low

away more

of claim 14 include the derivative of calculating measurements to changes measurements

the the which

adds

columns

giving

something

as

follows
High Decreasing Fluid Pressure High Increasing Fluid Pressure

Decreasing Fluid Pressure Low Decreasing

In range Decreasing Fluid

In range Increasing Fluid

Bitweight
Low Decreasing
10 12

Bitweight
In range Bit weight
In

13

14

16

18

range weight

19

21

22

23

24

Bit High

weight

25

26

27

28

29

30

Case 1:03-cv-02579-RPM
Bit weight
31

Document 148-2
32 33

Filed 01/11/2007
34 35

Page 5 of 5
36

course one must look at the Pason system to determine how it operates Ciearly control with conditions is simpler than the differential ranges control with its conditions dont know that Pason would obtain any benefit by going to the 36 conditions that control falling the scope of the changes for in claim 14 over the condition controller
Of
tge

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

of

reasoning
in the

time technical

is

right

aspects

Brett Pason

can

On the patent prosecution side there are other the European prior art the US patent office the re-examination as well

issues
We

may

relating to the to chance to address get

disclose in

Thats pretty
Terry

much

the

map

should

we

need

it

Leier Cassels LLP Graydon World Exchange Plaza 20th Floor 45 OConnor Street Ontario Ottawa Blake
K1P
1A4

Tel 613.788.2244 Fax 613.788.2247 -mail [email protected]
.is email communication is intended recipient please delete email this

CONFIDENTIAL me at and

AND the any

LEGALLY

PRIVILEGED
number

If

you

are or

not by

the return

immediately Ølectronique est

Thank

you
ET ce

Linformation apparaissant dans cc CONFIDENTIELLE Si cc message vous
de nous aviser message

immØdiatement

par

parvenu tØlØphone ou

est

erreur courriel De

PRIVILEGIEE lØgalement OEtes en consequence plus

Merci