Free Exhibits - District Court of Colorado - Colorado

Case 1:03-cv-02579-RPM

Document 145-4
OVERFLOW

Filed 01/11/2007

Page 1 of 13

Page
IN

DISTRICT FOR DISTRICT

COURT

COLORADO

Civil

Action

03cv02579RPMBNB

VARCO
Plaintiff

SYSTEMS

CORP

Defendant

VIDEOTAPE

DEPOSITION

OF
November

16

BRETT 2006

Volunte

II

of deposition Plaintiff Colorado 80202 at 555 on Street 3200 Denver Novethber 16 at 952 a.m. before Barbara and Reporter Merit Reporter Certified Realtime Registered Public within Notary

JAMES

PURSUANT TO FORD was

continued

the on behalf

of

EXHIBIT

OVERFLOW

Case 1:03-cv-02579-RPM

Document 145-4 OVERFLOW
Page
114
So
to

Filed 01/11/2007

Page 2 of 13

Page

116

102824
if

Fm

trying to understand to

chronologically bit
it

103054

going

do
sign

on

would

be

1030552
103058 103102
certain

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rate thats right

out here

would you Sure What
going
call this

one
to

do
too

have
is

this

sitting

to date

1031055
10 08

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rate

doing

pressure going to

of

correct

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mark

it

as

103110

1028498 102854
10285510

Exhibit

Exhibit Exhibit about

1031108
was

MJtRALEY

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marked

talldng

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The problem
control system runs continuously
all is like

this

10285813

is

no

start

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understand

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but pressure Let
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frying

to

see

how

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to

me
it

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once

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got

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explain

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time

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you

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rate

the question

or decrease

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release

in

response

to

pressure

MR
question

ATKINSON
ahead

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to the

form

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pressure

or

down

103115 10311810 10311811 10 1912 10312313 10312414 10312715 10313016 10313317 10313318 10313519 10313720 10313721 10 31 10314423 10320724 10321025

beforewegotoweightonbit

MR BOWICK BYMRRALEY
to

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do

weight-on-bit

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to

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of

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Page 102928 102936 102948 102954
takes

115

Page 103211
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117

pressure and sends
to the

an analog measure

of

pressure then
takes

AutoDriller
takes the rate

we

want

understand

as

best

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can as
it

pressure
fast

of penetration

chronologically
pertains to

how
on
bit as

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works

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of

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stepper

to

be

moving
and

lately

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response
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to

motion

103223
103244
ticks

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way when

said

setpoint

second

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curves along then 10
this

setpoint rate

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step that thats

103247

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is fast fast

drum

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based

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thats

not brake
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curves

upon
steps

the

current

actually

and
to

to

each

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situation

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to

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when

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on
bit

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things

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for

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weight
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at

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rate

of penetration

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16
17 18

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steps another

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andthe

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or

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to

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up

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10335523
25

load
its

thats

even

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weight

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it

at

certain

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measuring

hook

it

10

114

to

117

OVERFLOW
daaeecbc-fOa5-4dcf-b808-5a2c3983261e

Case 1:03-cv-02579-RPM

Document 145-4 OVERFLOW
Page
306

Filed 01/11/2007

Page 3 of 13

Page

308

165754

MR
sent

ATKINSON
pressure
is

question

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ahead

170018

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ifs

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signal

often the stepper driver

by

transducer

different

1700203
fair to

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signal

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the

RALEY
to

say

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to the stepper

motor

responds
signal

changes
the pressure
is

pressure

because

it

1700335 1700397
brake

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stepper

different

different

motor

sends

signal

to the

165813

MR
objection

objection

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brake
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same thing

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is

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165822 165825 165828 165831 16583216 16584918

question
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exact meaning
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release

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to

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keep

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make

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first

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to the

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17010618
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agree

that

the

Pason

AutoDriller release

is

automatically
drilling

regulating
rig

of

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16585321
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pressure signal Andthendoesitgodirectlytothe
microcontroller

17011620
17
doghouse computer
or

drill

string

drill

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do
it

measurement

of

or does both

go

to

the

16590524

does

it

go

to

they rejoin

17012723 17012824

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it

does
transducer

lthinkitgoestotheEDRandtheEDRsendsit

Through

Page

307 we

Page 170130
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also

309

165912

to

the
it

know
the
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call

doghouse
right

computer

involve

measurement

of

1659193 165920
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it

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on

occasion through hook-load

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be
at

may
call

170141

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thats

the

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they

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weight pressure transducer
fluid

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the

signal driver

or passed

along

to

170158 170207 17021311

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the stepper

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relates to drilling

send

signal

165938
signal

MR MR BY Mit
microcontroller
to

pressure

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16594111 16 16594814 16595415

me

rephrase from the

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signal

if

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fluid

pressure

changes

the

signal sent the stepper driver

correct

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the

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right signal
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hook-load

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signal

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changes

is

the
to

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stepper

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to

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from

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17024020 170242 17024422 17024523
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58

306

to

309

OVERFLOW
daaeecbc-fOaS-4dcf-b808-5a2c3983261e

Case 1:03-cv-02579-RPM
Wildcat

Document 145-4
FORD

Filed 01/11/2007

Page 4 of 13
6/1/2004

Page

IN FOR Civil .3 THE

STATES DISTRICT OF

COURT

Action

No

03M-2579

BNB

WILDCAT

L.P

Plaintiff

PASON

USA

Defendant

OF
10 11 12

FORD

June

2004

PURSUANT TO SUBPOENA the deposition FORD BRETT was taken on behalf of the Plaintiff at 555 17th Street Suite 3200 on June Denver Colorado

of

2004

at

905
and

Reporter
13
14

before Susan Notary Public within

a.m

Schneider Colorado

APPEARANCES
For the

Plaintiff

15 16 17 18

ROBERT SANER AL-AZEM ESQ The Firm 1900 West South Loop 3/D International Tower Suite 77027 Houston

ESQ

For
.19

the

BARBARA

LAFF

ESQ

20 21

Ireland Pryor Pascoe 1675 Broadway Suite 2600 Denver Colorado 80202
Also

Present

James

Wilkinson

22

24

.r-

[email protected]

HUNTER

GEIST

INC

303.832.5966

800.525.8490

Case 1:03-cv-02579-RPM
Wildcat Pason

Document 145-4
FORD BRETT

Filed 01/11/2007

Page 5 of 13
6/1/2004

Page

71

separate analogous
drill

servo
to
3.32

separate

control patent that

that

would be
the

Varney relation the true to weight that

string

command
on

thats

what

we

did

increasing

bit
difficult to

Isnt
weight on bit

it

its

determine

deviated
answer
It

Yeah
let me

to

that

question

yes

Well

this
So

can

be

difficult
true
as

yes
the release weight of on

its

not
is

necessarily
same thing

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

drill

the

increasing

bit
me did advance by drill clarify the We way way that that what we

device string
hook
is

had

would
string

We

would

advance

drill

changing What

explicitly taught
and

in

this

paper

is

measuring
so

pump maintain that
and lots of

releasing And we

drill

string
of

that

we

constant

did that

times

difference between
what call weight the same thing as on we have here the And have
so

the

weight
on the bit

on

bit we

measured when

weight

which

load
bit we

so here

were
the

description of
on on as bit
is

measured weight

bit the

at

And

increasing
is

increasing

slacking

off

releasing

the

[email protected]

HUNTER

INC

303.832.5966

800.525.8490

Case 1:03-cv-02579-RPM
Wildcat

Document 145-4
FORD BRETT

Filed 01/11/2007

Page 6 of 13
611/2004

Pason

Page

72

string
But

thats

not

necessarily

true

in

deviated

welibore Okay
There There
are are two two kinds kinds weight
is

weight weight
on the

on on

bits bits
on on Even on with in

Youre correct
Theres
the

actually
of the

physical

bit live

rock
know

and the

that real

bit
an 10
11

You never
you

live the

weight
real

on

bit
weight

MWD

really know

live

bit

an

instantaneous

sense
the on bit
as

measured

on the

the

l2
13 14 15 16 17 18 19 20 21 22 23 24

surface
weight
be on

is

measured vertical probably
good did
in

thats
close
In

bit

In but be we

to

incorrect might not
What

deviated

well

that

case the weight bit

and on

what bit

the
in the Wildcat

patent patent

teaches
is

same the So in

weight
on bit

on

were
at

is

measured
patent

the

surface using weight
Wildcat of that the weight
on the weight on patent on on

--

Im

bit

this

paper
on fed was the was

in the

same had

sense

that

used weight

bit

They

measurement
was

bit

They That

relay
on not bit

inferred
this actual

at

25

That

actually

[email protected]

HUNTER

303.832.5966

800.525.8490

Case 1:03-cv-02579-RPM

Document 145-4

Filed 01/11/2007

Page 7 of 13

IN

FOR

STATES DISTRICT

COURT OF COLORADO

WILDCAT

LP
Plaintiff

vs
PASON

03

2579

ENS

CORP
Defendants

HEARING
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

MOTION FOR TRANSCRIPT

INJUNCTION

Proceedings

held

before for the 7th

HONORABLE District
of of

MATSCH
beginning
at

District

Judge the

Colorado
in

957 a.m
Room

2004

the Conference

United

States

Courthouse

Denver

Colorado
APPEARANCES For the

Plaintiff

Matthews Esq Guy Bowick Esq Bobby Firm The Matthews South 1900 Tower 3D/International Suite 1800 77027 Texas Houston 80265 Denver Colorado
James Hartley Esq Holland Hart LLP 17th Street 555 80201 Denver Colorado

recorded Proceedings transcript produced

sound electronic transcription

recording

Case 1:03-cv-02579-RPM

Document 145-4

Filed 01/11/2007

Page 8 of 13

APPEARANCES
For the

Cont
Kelley Well Laff Esq Bergelt Esq Pryor

Defendants

2600 80202 Denver Colorado

Ireland PC Pascoe 1675 Broadway

10 11
12

14

16 17

19 20

22 23 24

Case 1:03-cv-02579-RPM

Document 145-4

Filed 01/11/2007

Page 9 of 13

Brett
If

Direct

124

was meant

broader

construction
it

14

where

relaying

communicate
infringe

autodriller

would even--I

Claim

14
say

dont Okay And
what
is

dont

say possible

probable

so

thats the reason
meant
in

say the

these

cases

in this

claim And
10 11 12
13

you

created
to

summary chart
is

the

opinion

youre

going

give

right

Thats correct Okay Okay
meaning

So
The the

why

you

explain question
if

important

here means

is

the

14 15 16 17 18 19 20 21 22 23 24 25

relaying
Pason--says

And

communicate

transmit
probable signals

possible
it If

Id

say

because the

you

in

term via

switches
which
is

relays use of relays transmit
taught because Claim
in

relays

the

patent

in

my

opinion
in

infringe claimed

Pason

doesnt use relays
taught
in

the

way that

is

14
there

or

the

patent
of comes up

Okay
sometime

another terms

of--well

youre

talking

about

SPE

paper

Case 1:03-cv-02579-RPM

Document 145-4

Filed 01/11/2007

Page 10 of 13

IN

THE FOR

STATES DISTRICT

DISTRICT

COURT

WILDCAT

SERVICES

LP
Plaintiff

vs
PASON USA

03

2579

ENS

Defendants

HEARING
10

MOTION FOR TRANSCRIPT

PROCEEDINGS

Proceedings
12 13 14 15 16 17 18 19 20 21 22 23 24 25

held

before for 8th day

HONORABLE District
of

RICHARD of

MATSCH
beginning the
at

District

Judge the

Colorado
in

a.m Room
United

2004

Conference

States

Courthouse

Denver

Colorado
APPEARANCES For the Guy Matthews Esq Bobby Esq The 1900 West South 3D/International Tower Suite 1800 Houston Texas 77027 Denver Colorado 80265 James Hartley Esq Holland Hart LLP 555 17th Street Denver Colorado 80201

recorded Proceedings transcript

electronic transcription

recording

service

Case 1:03-cv-02579-RPM

Document 145-4

Filed 01/11/2007

Page 11 of 13

APPEARANCES
Far the

Cant
Barbara Kelley Weil

Esq

Bergelt Esq Ireland Stapleton Pryor Pascoe PC 1675 Broadway 2600

Denver Colorado

80202

10 11 12 13 14 15 16

18 19 20 21 22 23 24 25

Case 1:03-cv-02579-RPM

Document 145-4

Filed 01/11/2007

Page 12 of 13

Brett

Redirect

24

art

or above Ordinary skill
in

art

was

quite

young

at

the

time
You were
at

the

time

Yeah And
that is not

the

skill-

now

have

much

more

skill would
When we you

you

say
work
you was

did that remember meant talking

30
to do about work back
in is

So
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to

said just talked you

what

obvious you

you
about

we when

did your

late

Eighties Right
was
it

you work being

were

talking

about

your

invention- -your

obvious

heard

Mr Bowdens

testimony

background

didnt you

And
in the he

do

you

believe on what

Mr
was

Bowden telling

has Court about what

art based

could think Would

so
look now
at

you

the and

figure can

Wildcat show the Court what

us

which

Exhibit

11

Case 1:03-cv-02579-RPM

Document 145-4

Filed 01/11/2007

Page 13 of 13

Brett the hook The sorry--what string
to

Redirect
the

25

drill

string

is
the out
as

this part

right here can move

below
in

thats
you

the bit

you

and

drill Okay Well And
this is the the

hook
load
is

connected the

to

the

drilling down

rig

the hook

thats

from that All

hook And
are that draw this pulls wench the hook right over up and

right
draw
the

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

The

works

there right

Its

down

Right Okay
Is

the

brake

part

of

drill

No
Is

the

hook

part

of

drill

No
How about draw

works

No
Now
of drill
in

your

dont right

mention

word

release

dont
Why

not
didnt choose
of it

Because words release What

to

express

the

concept

in the

drill

string

mean