Free Exhibits - District Court of Colorado - Colorado

Case 1:03-cv-02579-RPM
.4

Document 146-4

Filed 01/11/2007

Page 1 of 5

LEER
Sent
Friday Ford Trevor

To Cc
Subject

RE

Wædcats

Move

Ford thiS note from Trevor Halt an Pason His got differences referred to in the claim are diffetences the This understanding neastired value tonsistent with US patent over columns line 26 through in tfle
Hi

understanding between set

of

claim 14
and

is given

fferences
Moreover
example
for as table P3GB

set

out

in

Bowden

would

track

description 14 line 10 condition example

point of

Thus

the

table

ROP

understand Trevors the Pason condition system tracks the explanation for as welL He said The user enters points or limits parameter the brake to and Pressure that system adjusts appropriately
set

maintain

these

points
technical claim 14 explanation
appears to be that

consequently
the

the
of

Paean

system operates

within

Claim measured
se.ectiflg ROP
scent

also and used

selecting as

one
that

tontrol

Trevor step namely

nor
that

goes

on to
the

state

Theselecting
Pason

of the

pressure

ad
the

other conditions
to me the

algorithm
of

ason

been would operate

is parameter alaim 14 requires based on none may select would developed empirically step of at

that

least

some

of the

time

within

parameters

of

14
explanation
least some appears of to.be

consequentlythe
the

parameters
there

of

technical claim 14

Pason

system operates

withiL

time
the operation of the Pascr appears if t4arkmanfconstruction other issues seem to me to be any

is basis to invalidate within the scope of dlaim there hearing that affirms

Unless

the

claim
not

tof all
Terry

Therefore

Terry Leier

Blake

Cassels Gxtydon t13 Plaza World Exchange Street 20th Floor 45 Ottawa Ontario

flplA4 Tel Fax
613.788.2244

2-ulail This email

613.788.2247 [email protected]
email and

communication
this

intended

reOipient

CONFIDENTIAL AND LEGALI PRIVILEGED If you above me at the telephone liumber shown corrmiunication and any Thank you immedIately

not or by

he
return

ET Linformation apparaissant ce Ølectronique est ldgalemØnt PRIVIIS3IEE OEtes en consequence Si ce message est parvenu par erreur vous prlØ CONflDENtIELLE immCdiatement par tØlØphone ou par courriel De ce plus veuillezdCtruire de nous aviser immØdiatement Merci message

Original MessagemailtoTrevor.Holtspason.con Prom Trevor Holt 2004 Sent Friday May

IT

Case 1:03-cv-02579-RPM
To Cc
LEIER TERRY Bob Rodda Trevor Subject RE Wildcats
Holt Desperate

Document 146-4
Move

Filed 01/11/2007

Page 2 of 5

Hi Terry
am forwardixig you some information that sent to Ford Brett This may give more of an in assuming of Pason AutoDriller Your understanding into the workings system our algorithm is quite different defined that then by the four ranges mentioned for claim 14 Its hard to put our algorithm into one category range control or PID we combination of both and respond to other conditions in the algorithm have been developed ROP could be of as third parameter in range table
you have

made

to differential control was to the one of the thought the reference pressure and not that the was differential was parameters being controlled pressure as in PID loop To us differential pressure is performing differential control defined as off So technically standpipe standpipe pressure current pressure in we are trying to maintain consistent stand-pipe pressure

hope

this

information

helps..

Thanks
Holt

Pason

AutoDriller

System Overview
EDR

The Pason AutoDriller ties into the Pason ROP depth and torque Standpipe Pressure

system for

feedback

of

Weight

On Bit

high-resolution An electric brake

encoder motor

is

used to monitor draw-works used to pull
on the

movement handle
standard

stepper

is

band

the EDR WOE pressure the feedback microprocessor is used to interpret ROP and movement to decide whether high-resolution encoder draw-works torque It then sends out the more braking or less braking is needed to maintain its set points the brake handle move correct stepping signals to the stepper motor

depth

The adjusts Pason

user

enters

set

points

or

limits

for

ROP

WOE

and
set

Pressure that

the

system

the

handle WildCat
differences

to maintain

points

AutoDriller

Pason uses motor controlled
Pason gearing
is

from

stepper motor controlled from mechanical apparatus

microprocessor

instead

of

pneumatic

Adjustments for
systems

software based system and Wildcat more flexible system different ROP ranges etc are taken care of in software instead used Wildcat system and other apparatus
is

Pasons
the fully following

fully electronic sensors control box stepper motor The Pason system uses that wildCat uses pneumatic/mechanical system for sensor feedback technologies
system

to the

Pressure

electronic
ring

WOE ROP
The in

electronic

Draw-works
user

pressure transducer beam electronic sensors on electronic high-resolution shaft points
as GUI of

fast

sheave

encoder
Pason i.e system front primitive Wildcat panel

pounds

pressure

absolute set enters in PSI ROP in

opposed

to

the

of

analog dials with no reference ahd then check their gages to see

Case 1:03-cv-02579-RPM

Document 146-4
to the if they we achieved able

Filed 01/11/2007
your actually
the to set

setting it to They adjust point they were looking for vast number
Each If of parameters and the
i3

Page 3 of 5

Because it system and conditions and an extra level software itself situation is the AutoDriller the Wildcat system
The do not

monitor

of safety in
is

operation for integrity
This type of

sensor

disabled

control

suspicious is not present

patent
relays

has

number

of our system

to

relays

pneumatic

devices

We

employ any

or pneumatics

it

fully

From what understand fact number of other prior patents that that are that Wildcat is to their use differential pressure patent Their implementation covers differential pressure using drilling implementation and as described in pneumatics patent clearly we do not use this type of ar implementation

From Sent

To

Message Rodda Friday May Holt
Bob

2004 Desperate

AN

SUbject

FW Wildcats

Trevor Take look bob

at

Terrys

email

and

me

know

your thoughts

Message TERRY mailto TERRY LEIER@blakes .com Thursday May 13 2004 159 PM To TERRY [email protected] cc [email protected] kmccarthyirelandstapleton Move Subject RE Wildcats Desperate
-Original

From Sent

corn

Hi

Barb
be

claim
of

14

might part art unconsidered
that

his

you have

his own prior use information that Brett has indicated he There is other that may be used as validity prior report the TJSPTO as discussed 29 my letter to Jim Hill of October of the patents discussed in were sent you but not Ford

Furrow and 4046355 to Martin which are attached This letter outline of the relevance claim brief introductory prior art in relation to Bowden documents were considered by the USPTO 14 As mentioned none of art patent re-examination request So the Judge in the action should nor are they part of further comments more be very receptive to them as it is new ground can provide desired specific comments for Brett at the appropriate time

4519585

tension as bit 35 and.claim 14 cable for weight on bit sensor in bit which take to mean weight on bit as the weight of changes unless it approaches the bit would not change light so all cable tension prior There are however in using art also essentially deals with the same thing the drill string can get stuck tension as on bit because or proxy for weight and on its side making the drill string can go around bends curves portions cable tension to map to on bit for numerous adjustments/corrections to get weight Bowden
refers uses to In the

addition to the issue of whether there is the issue Hill letter1
is missing disclosure

the of the

Bowden whether
form

There

continuation application never did Examiner couldnt make sense of it

for

claim valid over the art listed in claim workable notes to the Examiner that the added Does the Basic disclosure make The

of said Claim 14 simply refers to selecting any both said first and said second signals to control

signal release said
changes

second drill

signal and

claim

14

calls

changes

signaling

There

are

however

namely

Case 1:03-cv-02579-RPM

Document 146-4

Filed 01/11/2007

Page 4 of 5

Increasing Fluid Pressure

Decreasing Fluid Pressure

Increasing Bit weight Decreasing Bit weight

We

have

to

look

at

the

disclosure

to

see

what

the

release

would good

and whether such release is good e.g it out prematurely something or for claiming an unworkable are invalid
In addition make and use
is

operates the

rig release

the

correctly

in these conditions or no good breaks

bad

claims

invention
the disclosure are then and not the the use one how to explained or the disclosure response to the Examiners claims are bad the invention for failure

there the

is

the

issue
If

of
.are

invention

problems explanation

particularly
that be

given

the the of

objections
to

couldnt understand
by
an adequate and

invention

to make

claims are valid question of infringement documents in detail at all new Pason disclosure but did see of invention Im not pages that were directed to technical aspects sure that PÆson uses differential control at all perhaps control or range control would table PID proportional range something like the following

Alter

arises

assuming the
all of

not

reviewed

Low Fluid Pressure Low
Bit In Bit weight range weight

In

range

Fluid Pressure

High Fluid

Pressure

High weight

control of claim 14 include the system is not defined by of conditions called by claim 14 would require calculating the derivative measurements which measurements and shifting away from range measurements to changes three and three more columns more giving something as follows Such

Low Decreasing Fluid Pressure Low Decreasing Bit weight Low Decreasing Bit weight In range Bit weight La range weight

Low Increasing Fluid Pressure

In

range

In

Decreasing Fluid Pressure

High range Increasing Decreasing Fluid Fluid Pressure Pressure

High Fluid

Pressure

10

12

14

15

16

18

Bit

20

21

22

24

Bit

weight

26

27

28

30

gb

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

Document 146-4
32

Filed 01/11/2007
34

Page 5 of 5
35

36

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

entire Naturally we develop provide expert input and any engineer Autodriller can explain how it works On the patent prosecution the European prior art to the re-examination as well the there US

of involved

reasoning the

when technical

time

is

Brett can
of the

aspects

are

other

issues We may get

to

the to address

to

disclose

patent

office

chance

Thats
Terry

pretty much

map

should

we

need

it.

Terry Leier

Blake

Graydon LLP World Exchange 20th Floor 45 OConnor Street Ottawa Ontario
K1P 1A4

Tel
Fax
613.788.2247 com

E-mail terry leiercblakes

This email communication CONFIDENTIAL AND LEGALLY If you are not the shown above or by return intended recipient me at the telephone this communication email and and any copy immediately you Linformation CONFIDENTIELLE
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