Free Exhibits - District Court of Colorado - Colorado

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 1 of 33

WILDCATVPASON
The purpdse
of

BRrrr EXPERT REPORT
is

to describe
of

Bretts patent

of the

alleged

infringement of the

Pason

AutoDriller

Bowdens

5474142

Comments
Drilling for
drill

on Drilling Lexicon terms
of art
is

meaning of Relaying
as there
in

jargon

are often
drilling

several

names
of

the

same
is

some importance
directly

this

case

is

that

advance
or lowering

string

linked slacking

on bit off the
is drill

Also releasing

some
brake
is

times called
the for

string

Increasing

weight

on

bit

accomplished
or advancing

sometimes called drill by means of the releasing
says increasing
off literature
is

and thus
or letting off the

So

example when
to releasing possibly

reference the

weight
positive

on bit that slacking

really

Identical

the

off etc

Also

displacement

mud

motors are also

as

PDMs

2ure
The words
basic
to

moyno motors

and that

drillingjjuid..pressijje

motors mud italqQgmetimes alle
downhole

.or

riu

standpipe point

pressure pump
is

or sometimes

pressure
of

relevant

that

references

may

use two completely different
This
in

describe

EXACTLY
in

may
Also

of the functioning to someone skilled
different

same Pason system

physical

phenomenon
described described

means

that the patent

or the device
clearly

the art be very

prior

use

completely

words
relaying
not provide with
or

important here is meaning of Supplemental memorandum does Websters New World College

The
of

Plaintiff

cites

in

its

17
in

copy
rest of

reference

13

definition

of

Relaying
control

to

mean an
current

act or of

transmitting activate or circuit

or as by relays an

electromagnet
large

or electronic
activate Plaintiff

and usually

used

to

But there are other possible

meanings

of the

word

infringement

by the
the of

the relay Pason system
definition different

uses these other meanings

when

asserting

As

dont have

exact

cited

by

Plaintiff

provides
following
is

good description the words

meanings

definition

of

and relaying

from

relay

rl
An
act

of pØssing something along from one person

group

or station

relay race

division

relay

race
to in

El
EXHiBIT
by
31-May-04

to another

E.ironics
activating

device
or

that

responds

small current or voltage an
electric circuit

switches

other

crew of

another

crew

shift

Focd

Bretts

Opinion_v2

Page

of

34

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 2 of 33

fresh

team

as of

or

dogs

to

relieve

weary animals

hunt task or

journey

tr.v

relayed relaying To
pass

g15 r-%
if

along by or as

relayed

the message

to

his

Tosupplywithfreshrelays

To

control or retransmit

means of

relay

English
to

relaifresh
re-

team of
to

for

hunt
origin

Old See leip-

from
in

relaier

relay

re-

lajer

leave

Roots
The reason
the the

meaning

of the

meaning word

of

word

is

case The

is

that

the

Plaintiff

changes
the

depending

on the situation

patent
In

teaches

relay
in
its

electronics

by-means-of-a-relay

sense definition

above
cites

one place
of

17

May

Supplemental
formal definition
Plaintiff

Memorandum
of

43
But

the

PPlaintiff

the electronic

sense as the system

term
the 17

discussing the

has changed
In to

word

in

to

the pass-along

sense definition

above
elected signal...

the

same
this

Supplemental
of

Memorandum para 45
to

47

Plaintiff

has

use

or transmitting

said

The reason
formal
infringe

this

important

is

that

if

means as
of
will

the Plaintiff

asserts

in

its

definition

Transmit

means

the

Pason

not

on

the

Bowden

patent More

be explained
relaying 11

no relay to

control

or transmit any

signal

the Pason system has below means pass along quite clearly anticipated

transmitting conveying the prior art in fact complete

Bowden
within

and 14 were Pason
its

by
not
to

the prior art and at least

Claims 11 and

14 could
clearly

have

been

novel

at

the

time

can point very

the art prior to

Bowden

as the basis

system
valuable

Background
drilling

Why
device

pressure control Bowden
in

when

with key
constant described the patent
controlling

One
as
is

of the

advance
to

of the pressure

motor perhaps
limited

PDM

so

or

other factors

valuable

To

provide

foundation
positive

understanding

the potential

value

of the invention pressure
bit is

its

purpose when
very useful surrogate
to

mud motors
for

the standpipe

measure

motor torque
implication

thus by inference

torque
for this
is

actually
that

applied
its

the bit

by
the

reason

over

operating
to

range
pressure
of

delivered at the across
of

PMD
note

very across

nearly
its

linearly

related

drop

the motor

Also as

operating
rate

range

the

very nearly linear

flow

the tool

Ford

Bretts

Opinion_v21

Page

of

31.May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 3 of 33

In

normal rotary
surface
to

drilling

e.g
toque
is

without as
to

using

the

torque

measured

at

the

infer

so unreliable
is

be

virtually

expensive downhole measurement device
the rate at which surface
real that
is

used
bit

called

an

MWDt
on bit

unless an

Even then
to the
in

torque
it

measured near
usually not
really

the

can
to

be sent back
information

so slow that

is

possible

use

this

torque

time to control

key parameters

rotary measure
at

and weight
the

means

when

using

way

to

important

parameters that are not normally easily measured

When
torque the
drilling

drilling

with

the variations

in

pump
is

can
to

delivered

by the be
the

PDM

to

which
information pressure

the

tell you about torque actual weight

on

and
efficiency
is

infer drilling fluid

about operating efficiency can tell you important things
the

So

to

control

drilling

progressing
the

and

change

weight

is

increased

lowering

or

advancing

Ford

Brett

v21

Page

31MayO4

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 4 of 33

THE NOVELTY OF USINGPUMP PRESSUREJrO RELEASE
foundation Pressure
control of
in

CONTROL

STRING

the

BodºFrPatent

is-the

of

as

control parameter
in

This

describes

why

Pump
Patent

Pressure

as

parameter was known
relating to

the art prior to the novel

and

therefore

any claim
invalid

using

pump pressure as

control parameter could

should

be
the

Perhaps particular concept of using to automatically on bit was not in least sense novel Bowden

embodiments

be novel

advance
filed his

or weight

patent

Using
drill

pump

pressure

string

was constructed

automatic control parameter for and well before Bowden

of

appllca lion

Amocos
Reference Dnlling

Experimental

Ri
Wait
paper

late

1980s
Controlled

Brett

5$

Warren 1990
and

D.E

Field

SPE 20107
between

was published

1990

describes

that

was

performed

have personal

experience

constructing also

operating

what meant
to

is

claimed

in

Bowden
than

Claims 11
using

14
an
electrical

relay

mean pass
quotations

actually

relay

representative

rather from the

publication

are

relevant

Page

Column however
the and
rig

ln rUtty formations con Page
s.. still

significant

percentage
continuously

of

PbMs
variedTM

available

power

be unused

if

on

bit

is

not

Column

Para

the real purpose of the

was to test the possibility of operating
to

down

hole

motor

turbine

or

PIDM

at closer

peak

__________

TMThe

conitiflgorithms on bit so that

implemented
relevant

and tested parameters

have the purpose of controlling turbine

thel

weight

RPM

downhole

torque

surface torque

and standpipe

pressure

are almost

urigure on
bit

13 shows an applied to

example where speed

an

adaptive

was used

to vary the weight at
level

high

PbM

so that

the torque would

about

20%

under

the

stall

torque of

tool

Ford

BreWs

Opinion_v21

Page

0134

31-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 5 of 33

Appendix

Pg

pØra algorithms were implemented
in

The-control

such

way that

user could or stand

select pipe

the penetration rote surface torque pressure weight

downhole

torque turbine

to
bit

maintain would
in

constant

PbM

torque as parameters

for control constant

The
in

on

be adjusted to maintain the parameter
ligthology

the

face of changes

and bit characteristic

The

above
that

published

excerpts
control

and the paper taken as

whole

to

describe

the drilling

show
the

Bowden Bowden application published mechanism The
drill

system computer program and detailed algorithms was actually constructed used and published Specifically paper shows

and

so that
automatically

was
Fluid

released

Drilling

pressure

was measured
the changes signal
in

signal representing

drilling fluid

pressure the

produced sense
to
drill

The
string

drilling

pressure

was relayed

pass

controller
rate

The
the Therefore

of release

of the the
signal

drill

was
of

increased
drill

the
string

signal decreased

rate

pump pressure was decreased

pump Bowden

pressure

11

was

not

novel

at

the

of application
is

The above

discussion

assumes

that

word

relayed

the pass

on

convey

or transmit

sense

Of

particular

interest

for

14

is

in

Appendix

Appendix

Page 10 pam
on
bit

The
jweight

weight

actually

is

the

maximum desired
by

on bit selected

the operator

or the value

ieme eqs BY
Appendix

Page 10

para for the project with
bit
is

The
either

final algorithm programmed

an adaptive

scheme

that

can

run separately functions
if

or

concurrently

any other control

algorithm

With
can be

algorithm overruled

the

on

commanded
exceeds

other control

schemes

the actual

penetration

rate

set

The above
described
the

published
in

excerpts Claim 14

and was

paper taken
actually

as

whole show
used

that

what

is

Bowden

and published

well

before

Bowden

application

date

Specifically

Ford

aretts

Opinion_v21

Page

31May-O4

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 6 of 33

The

drill

string

was

automatically

released

Drilling

Fluid pressure

and
in

weight were
to

measured
drilling

Signals weight
Either

were
on
bit

created

response

changes

These

signals signals

represented

pressure and both parameters
the
to
drill drill

or both of selected
to

were

selected the

to

control the

string

The

was relayed
control the release 14 of the not

pass
string at the
is

controller

drill

Therefore

Bowden

142

Claim

was

novel

application

The
or transmit

assumes sense

that

word

relayed

used

in

the

pass

on

Varney Patent
Further
clearly

3222183 1965
system
for

Varney
describes

Figure

and

associated the weight

automatically

controlling

imposed

on

bit that

uses the pump
Further invention
in

the control input

Varneys use with

he

explicitly

states

1.18
of

the
drill

applicability

of the

to

motor on the lower

end

the

string

Varney Dec

Figure 3223183

14

.4

VARNfl
JflAAWS

flu VMILXJO
Filed 1963

ShntsSbset

The Varney The

patent
drill

describes
is

an approach

identical

to

Bowden

Claim

11

Specifically

string

automatically
is

released

Drilling

fluid

pressure

measured

Ford BreWs

Opinion_v21

Page

of

31-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 7 of 33

signal representing

changes
is

in drilling

pressure
to
drill

is

produced
rate of signal

The

drilling fluid

pressure signal
string

relayed
of the

release

of the

was

increased

when
drill

the

pump

decreased
puinp Therefore

and the

rate of release

was decreased

when

pressure signal increased
11

Bowden
discussion

was

not novel

at

time of
in

The

above

or transmit actuating
relay

assumes that the word relayed the sense On the other.hand to include the brake 10.5-10
if

the

pass

on

convey
by

132 which responds

then

Varney

anticipates

Bowden
to

11

in

senses of the word has long

relay
in

Since
art

using

and
the

if

as parts of relays had you anyone

actuate

components
in

the

skilled

the

late

80s how would you

construct relay

power transformer or switch as is

one

possility

would have

an electro-mechanical

by Young

below

Ford

Bretts

Opinion

v21

of

34

31.May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 8 of 33

Using Relays to control advance
of the application

was not novel

at the

Young Young F.S
In

1968
Computerized
Drilling

Control

SPE
paper from
that

1968 Young
the

Humble
penetration using

Company
rate
control

described

their

with optimizing releasing

Figure

Young

described

used

weight

on

bit

system with as the control signal

paper shows Switch
but

technique
technique

shows

means

to

automatically

release another

control

Switch

Assembly

switch assembly

way

to say

Relay

There are two relevant Even which advance
it

points here as
off

IF

using not
drill

pump
at

control

input for advance using

of

string

novel
to

was
the

the time
is

application

as

way

string

not
the
drill

Automatically

releasing

string

response

to

control

parameters

is

not noveL

Young

Figure

Hg

brak

actuattr

Ford BreWs

Opinion_v21

Page

of

31

-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 9 of 33

Using several
time of the

variables

to control

string release

was not novel
several

at the

Bowden
in

application
the

One

of

the teachings being

Bowden

patent
string

is

the

of using

different

signals

useful
built this

to control

drill

release
that

as early as 1965 described
did just

system actually While Young in
input

and
did

Humble
not

see
as
that using

Figure control

anticipate
it

Pump
less at

because
to

he wasnt
drill

using
string

PDMs
release

never the

shows

selectively

was

not novel

time of the

apprication

Youll note
bit

that

Figure
drill

Figure brake

above

are

in

Bowden same was

The way the by means of

e.g
relay

string

advance

release was accomplished

Young

Figure

.ttctmc

flYAC 5cc

cuI

tot

Na

stn

farm
Fig 2Schanuatic

kseflttS

INn
rig

diagram

drillIng

computu

control

Ford

Page

90134

31

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 10 of 33

Using pump pressure as the Bowuien application

controlling

was not novel

at the

time of

It

long
to

been

in

the

industry

that

controlling

way

control affected

performance

with

PDM
As

that

advance
drilling

and that maintaining
drilling

pump pressure is bit e.g string constant pump
on
the

while

could

Patent control

improve must be based
string

performance

any

novelty

Bowden
to

142

on using release

relays in the electronic

sense as

way

POM

operation

manuals
describe control

commonly
that
drilling

from

late

and

early

80s see
pre-dating

attached

scanned
clearly

images
to

publications

from

Bowden
valuable

use

constant

way
out

to

of

pump pressure is good and These operation manuals were

handed

people

purchased

or rented

PDMs
Motor
Operations

Re
Page

Baker Service Paragraph weight
increase
is

Tools

Advantages

11979
to

As
wilt

added
in

the motor
proportion

and

bit

starts

drilling

pressure serves as
built-in
if

direct

to the torque

generated
is

means of

telemetry

to indicate

exactly

the motor
rig

performing even

wall

drag prevents

an accurate

response of

weight

indicator

Re

Service

Tools

Motor

Operations

Manual

Operation

Page 14 Section

By maintaining
remain the

constant

pressure on the

pressure gage

the torque at the

tool

same
Drilex

Re
6.5.1
drilling

Edition

Dowuhole

Drilling Motor

Handbook

Page

23

Performance Drilling 6.5 Increases torques
in

1981
pressure are directly range of
in

standpipe

proportional

to increases

in

within

normal running
either

motors Therefore

any be

change

intoque bye

which

be due to change
in

WOB

or formation

reflected 6.5.2 be kept

change

standpipe been found pressure should

Once
constant

optimum
giving

drilling

rote has

torque

the bit

Re

Smith

International
is

Inc
to

Handbook
bottom and
drilling

Page

22 and

23

Section

1-3

As the bit motor

lowered

torque demand on the

increases

pressure differential across the motor increases
an increase of
limiting

proportionally circulation

pressure
this pressure

will

on the
to

system pressure gauge

By

increase

the

Ford BreWs

Page

loot 34

31-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 11 of 33

recommended performance

valui

the tool selected

the

will

deliver

its

optimum

To assure

constant

torque throughout

entire

run maintain constant

pressure ratings

NOTE
increase

Adding or subtracting
or

will

cause

both

pressure and tortlue enables
as
drilling

decrease

accordingly
glance

rig pressure gauge tool
is

operator weight

to tell at

how

performing

cind

also serves

Smith International

Inc
bit

EMore
the
gauge

weight

on the

means

higher total system pressure at the pressure decreases weight

Ar
pressure the
drill

bit drills-off

the total system

The stand

therefore can be used
not distort

as an accurate

torque indicator

friction

the

The
the the

only

way

to

maintain

pressure

on the

rig

pressure

string of using not novel
at to control input to

on bit or release

gage is brake see
the
drill

to

advance

or release
Clearly

above
or weight

pump

to

control advance patent

of

string

on bit

was

application
is

Therefore
the

even
idea

IF

use of

relays

and

control

system
drill

certainly

using

pump

pressure as

release

was

not novel

Summary
At the
of

Bowden
releasing
in

Automatically

response

to

control parameters

was

well

known Young Use
string

1965
sense known
as part
off

of relays in the

the

mechanism

to

control

drill

advance

was

well

1965
drill

Use

of multiple

control

not just weight on bit to regulate

advance

was pump

well

known
to

1965
automatically
drill

Use

was

well

known

Vamey 1965
Usefulness
well

pump know Baker 1979
whats
et

control Drilex

element while

drilling

PDMs was

1981 Smith
11

Embodiments
published

claimed

and 14

actually

constructedand

Brett

al

Ford

Bretts

Opiniori2l

Page

of

31

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 12 of 33

my opinion narrow and
In

IF

there

is

novel

taught
of

the

Bowden
series of
In

it

would be

particular to

embodiment
choose between

the

control

sense

selectively very

control elements
in

my

opinion

such from our

claim would cover
prior art

particular

embodiment and
later in this for

my

mind
in

project deccribed through

at

As the Personal Note section Amoco did not choose to apply in et al 1990 because above

report describes

more

detail

protection

on the us
in light

it

didnt

seem

novel

to

Items

Ford

Bretts

Opinion

Page

12

of

34

3l9vtay-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 13 of 33

DiSCUSSION OF

OTHER

ISSUES

RELEVANT

THE

What
The

is

proper interpretation

Claims 11 and

of

IfS

5474142
only ambiguity
If

interpreting
is

Claims II and
the

is

in

meaning

of the word

relaying
describes
drilling

relaying feedback

used

or transmit
that

sense
drill

then

Claim 11
to the

system use

uses release
this

string

fluid

describe string

pressure Claim most any technique

would
to in that string

sense be
pressure

broad and as

drilling fluid

way

to

advance

the

drill

Claim

14

relaying

broad sense would describe
to

control

system
similarly

use release

drill

control one of several

and would be

broad
exception
to

The one arguable
meaning without
of the
relying

clear

broad used
in

interpretation

of the

claim

is

the

Relaying on use of the word
17

as

it

is

the

Reading

Claim 11

or 14

alone

in

the Invention

Summary

or Description take

of Preferred to

Embodiments or Plaintiffs mean communicate pass Bowden would have broad
that

May Supplemental
transmit
or

Memorandum

Relaying
control

on

send
cover

mean
most any feedback release
in

11
to

uses

drilling fluid
is

pressure the the

control
is

drill

The

problem here
definition

trying

to

use the

senses depending

on which
extent

supports

novelty

narrow definition or the

of the

the broad
in

The
these two
defines
different

Supplemental

Memorandum

explicitly Plaintiff

uses the
initially

and

formally

relaying

Supplemental
definition

Memqrandum
is

supported

or transmitting or para 43 as conveying by use of word in the application
in

the

word

relay
that

is

believe small current or voltage responds to an electric circuit
interpret to

used exclusively

rest of the

as

noun meaning
or other

change

by

activating

the

with the more

narrow meaning
the

of to of

the

word

relaying because
extensive pressure
to

do otherwise

would mean

that

the

examiner neglected
that

consider
drilling fluid

of art prior to the automatically

Bowden

application
drill

use

advance
String the

string

See

Novelty report broad

Control
art

Drill

Release

section
in

using Pump Pressure to Either the examiner neglected this sense control or retransmit
of Claims 11 taught

or intended of
invalid

relaying

the narrow electronic

by means would be
actually of

Because
on what and

clearly any

interpretation

and 14 and
date

know
by

for certain

actually

constructed

and others

Bowden
point of
all

patent
that

The

however used

interpreted the electrical
of patentability

in

the

Bowden

Patent
to

the

patent interpreted

teaches
consistently
for

device

sense
If

purposes

and infringement

means control Pason system

or retransmit

by means of

as
systems

patent

itself

then
relay

not infringe

The

Pason

uses

stepper motor not

Ford

Opiniony2l

Page

13

of

34

31-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 14 of 33

to

advance

the

string
the

If

means convey
11

or transmit clearly not

in

the

more
the time of

general

sense then

and

were

novel

application Not being patent

lawyer Im not able to know what sense
the
interpretation

the

body

the

matter but beyond
retransmit

my common
is

that

should

not

law says be

the

what

taught

which

mean

that relaying

means

control

or

by means of example
to

An means
to

make

the

same

poini
of

it

be as

if

received

patent
tried

on
to

wmotivaten

seek infringement
the impel
to

people from Tony
device

sense

automatically

transport and
using

because sentence

he what he did was motivate can

people in both

sense
the

Relaying

mean either
any

type of electro-mectianical Further support application
different of

or transmitting

means

but not

electro-mechanical nothing
It

of the word

relay select

teaches

past

use of
the

relays determination of

control sources proportionality

not

describe
of

back control algorithms use of

gain or
stepper
multiple

use
control to to control

multiple or digital control
of

or torque
drilling

motors

release

the

brake
shut

or

of

measurements
At least

of

parameters
11

of these

would

disclosed

emergency to be considered

procedures as teaching

some

broad

interpretation of

and 14
several
incorrect

By the
include
rather

way
4.26

the

statements

Incorrect rise

statements

would
the

rise off

bottom
as four

while drilling

bottom
formation

but

off to

on the
as
little

bit

just

balances hundred over

resistance

and can

as

much as
relate to

per
five that

hour
hour

rather

drill

from

one foot per hour
really

per

These are minor cant remember reading

points and dont patent
that

the

case

but are curious

had outright

errors

How does
Based
claims
either

the
description

AutoDriller
contained
that

compare
the Patent

with

Claims 11
and
not

on the
11

5474142 me
to

my
is

interpretation

of

and 14
or

Pason
point
to that

AutoDriller

fall

within the
that

scope
the

of

say tke sense control or fetransmit by means of drill relay The Pason system controls advance through release the brake.by complex stepper motor control system NOT infringement thp uses different meanings relaying in Para 43
key
this

claim 11
in

14 The

Relaying

Claims 11

have

electronic

Paras 45 and

41

its

17
in

electro-mechartical

sense

43

to

the

Memorandum They change-from the convey or transmit sense inParas 45
sense then the As mentioned above
But the
in

and

47
If

Relaying
indeed

is

-interpreted

in

the
of

convey
claims
are quite by

AutoDriller

does

fall

the scope

convey sense
in

Claims

and

broad
Plaintiff

relaying

as

it

the

of

the patent

defined

Para

means

that

are narrow

what

claimed
is

use of
broad claims

physical should
clearly

The

relevant

point here

that

novel
of

taught

in

the

of

the patent patent or

and

not depend
clearly

on multiple or changing
the multiple

words

the

same
to

at least

For Claims 11

and 14

cover

Ford

Page

14

of

31-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 15 of 33

the

system they
or

must be
interpreted

have Claims 11 advance But reasons described Claims by means
the claim
of to

to

mean pass
drill

on
novel

conveying
describes
drilling fluid at

transmitting
automatically

and
of

14 pretty clearly
string using clearly not section of narrowly

method
pressure

as the control input
for
all

were

the

time of

application

of

the

report defined

attempt

make
their

the

Bowden
that

be founded those

on

meanings would on meanings

or retransmit face
is

mean

relay was not broad

narrow

Even
doubt
all

if

the word
least

at

relaying Claims
described

defined

as control
novel
at

or retransmit the time of the
to

means

of

relay
for what

14 were

the reasons already

Using physical relays

as an embodiment

was

taught here

seem

novel

to

me
system represents
over the device
significant

Of some importance advancement patent problem
for
in

that the

and
to this that in

described

in

Bowden

Wildcat
fact

is

the the

system

is

taking

too

much market share
motor
not relays sophisticated
to

Besides the raw
release
drill

that

string

the

Pason system uses Pason system embodies
the

stepper

much more

control

stheme Any
releasing

that

using brake

e.g
would

on-off

to

control

of

drill

string

much worse

perhaps

the Bowden
system
in controlling

mathematically correct Patent would function

Pason system To The device described analogy would be helpful controller much like an air conditioning as an on/off
than the

home
has
large capacitance

can provide
with respect
that

response

IF

the time of
it

you are have
If

the response

high capacitance
for

would mean
it

controller

comes

to

stay on
is

some

time

the very

desired

control

condition

the

capacitance

low On-Off

control

jerky control
correct

An

every

day and

mathematically

drilling

would function
either to have the

be

if

analogy of you were to drive
fully

the

device road

in

on your options
constant

down
Off

the

were speed
over

or

fully

To

maintain as
let

you

say

would be continually smashing 70 mph you would the

the
fully

pedal to off and

the floor

as you you
forward

time you continually

would have

backward some way
control

smash to the floor again More sophisticated control
to

You
use
cruise
control

and
in

control
is

inputs

are proportional
this

to the control

modem

one example of

type of
to

system instead of On-Off smoothly control the parameter of interest The
control

much more

able

system
control

provides

much
that

of

the

weight

and

is

more

sophisticated

system

uses

multiple

inputs
to

complex logic
the string or even
It

constants and
pneumatics

electronic

advance

use on-off control

or electrical patent
of of

mechanical
this of
all

measurement
feedback
this

pump pressure The Bowden
is

does Pason

teach

any of

control the

the foundation
follow

System

that

disclosure
to

system does not other than very broad pressure

any

teaching

The the Bowden
drill

string

control the application

This

was

not novel

at

the time of the

Bowden

Ford

Opinion_v21

Page

15 o134

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 16 of 33

patent
after

changing

words

in

claims

Had someone brought up
difficulty
it

that

art

allowance

we

would have had quite some
this of ruling

novelty
there of of that

As the
to

situation

stands now

be some clear demonstration very hard to prove
our patent With broad
to

understand patent and as or malfeasance on the
of

would examiner
art

the

the examiner

on the relevance

to

be over turned
to

respect idea to

Bowden
in

find

odd

paucity

of
drilling

art and using

Its

as lithe

described

the

patent automatic
of

drilling

pressure

release

the

were

right

on the
Controlled

edge
prior

of drilling

technology

Our paper
has

TMEield

Experiences with Computer
at least

Drilling

SPE
providers of
drill

20107
of

1990

references use

ten of which are relevant
of prior to

art and those

references

are not by any
of

an exhaustive
fluid

art

Commercial

motors taught string and handed out Automatic There was
drillers lots of

mud

pressure

literature

with every

mud

motor describing

this

have

been on almost every deep drilling art on the should have

since

mid

1970s

considered

Ford

Bretts

Opinion_v21

Page

31-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 17 of 33

Pason
The
features

AutoDriller
AutoDriller But these

to prior publications

Pason

may

at

one time
in

had my
The reason
for

may
to

still

patentable narrowly that

features

opinion have

be so
opinion

defined

as to be economically of limited

value as the

my

system

most broadly and very
Society
similarly to

3223183
authors
Drilling

the computer

controlled

described

my and my

of Petroleum

Engineers

Experiences

Computer

.SPE2OI

07
measures
drilling

Most broadly the Pason system form
teaches

parameters
the release
fluid

combines them
of the
drill

in

the

computer
exactly
to

controlled
this

algorithm the
controlling

strings

Vamey

when

pressure
variables

Compared
similar that

SPE20107

the

system has
algorithm
to

same
different

computer combines Fundamental system

controlled

but
create

constants

measured and and some terms
is

these variables
differences the
drill

signal to release the

string

between
string

5PE20107
stepper controller

system
instead

the

Pason

of

hydraulic

ram as

in

SPE2O1O7
here
is

Perhaps the most important
release
of

that

the

rig

computer

controlled

the
fluid

response pressure
well before

to

various

measured patent Even by SPE2OIO7

including

and
that

drilling

the

Bowden

more

important

on was

bit

the approach

was

published

as evidenced

further supported

sHigh

Speed

Drilling

Research

1987

Duty to Disclose From my experience 25 patents have filed numerous Information Disclosure prior art While some people seem to think
work
doing your could the

on

my

inventions

my
including

co-inventors to
to

IDS
that

providing the inventors

of prior art tends

and examiners have
the

can

from
to

perspective
practice
art

that
is

youtre
to

when

handing over
considered
all

the examiner

something
to do the during

invention
to

have

always examiner consider

prudent possible

sound

process

My reasons
perspective
considers

for

providing

all

relevant prior are actually
to

the

of

the
it

prior to

art

during
that

the application

process

examiner process itself If be much more difficult for
the Prior art that

someone
the

later

use as

same

prior art to

challenge

hasnt
tool
in

been considered hands
of
all

part

examination

process could
believed

dangerous
ensuring could

adversary
potential prior art

always important

examiner
justify

considered
patentability

was

way

the
prior

of

my

invention

describe

the differences so that

my
could

invention

art

and

when

perhaps most importantly was just us and the
but they are

word
discussing
easily

Examiners are hard commercial
actually

to

convince

much more

convinced

By the way during the application process of my most useful patent we IDS based on information we found well after our initial filing that caused
reverse
his
initial

filed

an
to

of

our most important create

were

eventually

to

overcome

most of

objections

very broad and economically

Ford

Bretts

Opinionv2l

Page

of

34

31-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 18 of 33

PERSONAL
As when
infringers
is
If

NOTE
25 Patents

holder

am
built

supporter
to give

of

inventors rights and the patent economic
is

system as
to

whole

The system was
should claims

inventors

benefit inventor

and

it

should do so
is

are truly novel held accountable But the
in

pay

what

him

this

whole

that

the

any patent are
that

fact

and
of the

benefit the entire

claims

are allowed
rights

are reinventlons
inventors

wheel
to

system

falls

apart

of true
of

then cease
the

be valuable Bowden
are not novel of the same
interpretation
it

With
11

the

narrow

meaning
broad

system does not violate

and 14 With
others
in

interpretation personally the did not
built

and
idea
the

at

the late

Amoco SOs Further
the

word relaying and published
broad

the

claims

believe

be

novel at novel
project

we
have

built

Amoco
patent

had we believed
over the idea During that period

was

would
tiled

sought

coverage

our

Amoco

and had

granted

over 15
to the

patents

the idea

Those 15 patents
intellectual idea

testify in

the
field

Amoco was
of

actively

seeking
If

to

protect

property

Improved
drill

automatically

performance based on drilling

we had

believed

fluid

pressure

was novel

we

would

so Instead

publishing

we did

OatedMay2l2004
For

25t2i1

Ford

Page

18

34

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 19 of 33

SCANNED IMAGES OF DOWNHOLE

Deponent
DateiRPR

4Eerr
_________

LGwsInc
Ford
Bretts Opinion

Page

19

of

34

28-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 20 of 33

INTRODUCTION
Early in ISiS BalcerService

1bqis Mdtot

ciBaker Inter
the nibtok at

ncrtioudl.Corporaticin

tp the drillingindustry

Baker

tb

operates

low

convent4orzal btts Izcxs speeds torque capcrbthties to allow wore weight orvtbe Mt nnd can be used routinely with jet bits This tool represents major breakthrough oFdewri3dIe iriotors Lbaracterlstics perfornicince anclis tieldiesting

tenyprs

e$erjsiye

iaiirgry

and

1hsbookethutestheb.asicdesigndOpetation1the
motor to bip the percr acbisynaUmpefitszrnance A3spinchided is of dthrts and compilation data usS in rntortillinq the readyreferenceto Baker
appreciation
to

would
the

like to

enpecially

express

its

many

ii

thviduulsaM
this

zortzpdnies

intite

pettoainnihdustn

contributed in

and
the

assistance

developing making

desire

thetask
of

advice thejrexpetUse tool is Our Sincere easier with bol.ekwillbe

use

the

tCopyrighi jion

ltl$r Salter

Service
First

Tools

Division

Cupoxci

AU

tights

reserved

Ford

Bretts

Opinion_v3

Page

20

34

28-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 21 of 33

ADVANTAGES
The Downhote
the
fluid is

Drilling

isa positive
drilling rig

ment hydraulic

motor powered
purrrpedthrough
to

mud
bit is

When

the

the

or water turned at

speed
constant

proportional regardless the

the or

reniahis

relatively

developed
starts dihirtg the

weight

is

added

to

rriot

or arid

standpipe pressure will increase Indirect pxpottion to the osabuilt4n niectrisatteleme torque generated This serve$ motor is partermutig try to exactjy4row even if wall dtrrg.prevents art cresponse ot
ixidicatot

In addition
chill

to

dferingThenowuadvqntqgesof.u
rotary

downirole

motor over conventIonal stririg.ar4qlng

4ilIing

eg

se

wz.zotiztioncrflcrsepgwer located at the ha cozitrglled4enated dn1lin and ter diredtioual Baker motor oilers The tc lowing udvatitage

duced

CL.SSeed
motor operates
roller

at

This significantly

speed nidre corup4rtjl$e with lengthens4he bitMin with

Increased

on bottom time arid fewertouiidtrips

Bigh Torque More set down
penetration with reserve

can

be

put on
for the

hIt

lox

faster

powet

hard spots

High

Maximum
use of
Oil
jet

bit

hydraulics

are

utilized

by allowing

the

bits in drilling

Beqring

Prepressuredcmd pressure compensated tionprovides lorrgsealllfeaadmore dependbte
big

see
bear-

Bypass The valve
not

Ycilve

allows
to is

the

pipetoMczn4
to

dtai.nis

exposed ging Valve

4illligreturnsthcttxu4dicause.phrgexposed
the tool only

dumps

through

Through

pnmp down i

fluid

and

Overload Tcrqae Protectron The motor drive tram is protected torque with lessened chances
directionaL drilling

fromunusnaltyl4gh flop-overdunng

operations

..s

Ford

Opinion_v3

21

of

28-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 22 of 33

Ford

BreWs

Opinion_v3

Page

fl

34

2May04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 23 of 33

Baker SlOOEmEnott 8oqston

Service

TOOlS

DMslb3i

Road

P.O Box
elaYAB6-t322

Texasi7O4Q

1FThfEdlitqpiZ9

Printed

1n4J

Ford

Brews

Opinion_v3

Page

23

34

28-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 24 of 33

Ford

Bretts

Opinion_v3

Page

24

of

34

28-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 25 of 33

PREFACE
It

is

now

five

years
In

since

DRILEX

put

its

first

Positive

operational

use

March

Motor 1981 Since

into that

date the terms
of

Company

has grown
expertise

steadily

and

geographical

location eleven

There
sizes of

now
for

DR fLEX

motors
field

in

the

need
ri

definitive

data

has grown

to response popular accotthngly first demand1 ORILEXhave.vroducedthis edition of the which Handbook is iritendf tOifrºLt the e2pressed

requirements

of

1ndustry

VH

As modelsndversions
hole motors increase

ofDRiLEX Down DRILEX will amend
In

and
the

modifyihehndboaecordingiy meantime DRILEX will continue
the unequalled and CMI for which it
to

to
the

provide
Drilling

Industries

become

renowned

Ford

Bretts

Opinionv3

Page

25

of

28-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 26 of 33

PERFORMI9NCE
6.5 6.5.1
Opttmlalng Increases increases
of either reflected In
in

DRILL

the

DrIlling

pressure
within the

directly

to

normal
in

running

motors due ky.a

Therefore
to

any change
in

torque

range which will
will

change

WOB

or been

formation

be

6.52

Once

optimum pressure should be kept bit in order to aohiey
table

change rate has
constant

pressure standpjpe se
of

giving

$aadytotqueat
thØyotary
Will

itolten deeirabfe ar even

at

i0ta

5Opm

6.5.3

Weibt appfiedatlhe bmiidnglAgi4p When defiling wih or lamond bits may be deshable however they must bE kept

kL4

sting speeds

rotary

rpm

6S.4

60% of the motor When drilling 90P
or increments
startoff bitilIb
drilling

speed by
with the

WaS
it Is in

However
below

PDC

good
order to

to

optimum

WOD

increase

66
6.6.1

Mqta
stalt

occurs
the

output

torque.ot to

when the motor

torque This

at

the

bit

the weightis leads
to

can
of

occur

when

added

bit.or

change sudden should
It

formation

higher torque

L6.2

Stall

is

identified the bit rotary
lifted off

pressure be
vital

rise

When

this

occurs
and
of

table

Immediately
that
drill driller

clown

thisand

does

not

welt

for

motor

oil

DrIlling

With are from junk ci
jUhk.ln

PDc
it

tiltS

particularly liriportant ten to

vunerable
If Is

to

damage
possibIlity

and
to

therefore Xe

hole

spend This

1wnty
lift

minutes

cIrculating

close

bottom
bettiling

should

the

offending patern
anti

material la

before

6.72
irnportntto

cuts design bedthebit

its

own

it

ia.overte

Vsttwe ortitee
4tflld
for

gently
to
lift

at the

low
off.bottom

tenfeethas
circulate
bit

die
to

ensure

that

no

junk

down

23

Ford

BreWs

Page

26

of

34

28.May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 27 of 33

.1

Produced

for

PG

by

ConsuItatey

PeahoceWorcsstershfre

wale

England

Ford

Opinion_v3

Page

27

of

34

28-May-04

Case 1:03-cv-02579-RPM

Document 145-2

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Page 28 of 33

Ford BreWs

Page

28-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 29 of 33

PREFACE

SIXTh

REViSED
DYt4A-DRILL

pa pa

Several book

years ago wheh the First Editiort of was published our cb$clive was to offer
of

HSAd
of

successful

motors guldO on
printed regular

Your acceptance has

the

Handbook

as the mosi
information positive of

ndOUra

t4
design These

DRILL to.update the The OThA-DRILL
continuing process have
interval

basis

displacement Major

motorbas gone thivugh
ip

and

serVicing

tmprovedtheafreadywell
straight4tole

known
in

rehability

of

s4

tools

Long

runs iesuthng
the offers

test

savings tel and of

beOortte

toutina

pa

F2000
diplacemen1
with
its

dod ith the DYNA DRILL now
ideal

Sto-SPeo
tine

have and eath

comte

positive

motors each

br

specific

own advantages Therefore DYNA-DRILL Handbook Like past editions
is

operatingtharastefl5tios

has
the

prepared

the

of the of
this

primary purpose tool

to

ot.dhine

principles of the

operational ILL

requirements
new
Section Edition

new vOlume and on the

applications

indluding

steerable

system
Shtth with
is riot

We

Sincerely hope you
technical

DYNA.ORILL
as past rfdM

pa pa

HandboOk always our

as

much
to this Offer

ns on

available
in

addItional

advice

covered

book

The __

following
trio

are

registered

trademarks

ortraemarks

pf$mith

00

national

DYNA

QELIA toad

j4f
DRILL

iocto-tOtC tELTA ALYNA $UBt SOG tSLO-SPEeDc

0ELA

pa pa

Ii
Page 29
of

Ford

Opinlon_v3

34

28MayO4

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 30 of 33

When
break from
In

trippino

extreme periodic

depths or when
are
tool

peratures

are-high

tem recommened to
qr

circulation

This prevents

plugging

damage

high temperature

wells

where
to

fluid

characteristics

easy should

flow

thrbugh pccasionally

dump
fill

the the pipe or bottom
fill

stopped

Do

not run into

bottom

wlththe

DYP4A-DRILL

tool

Slatting the DVt4A.pRILL fluid

Tool

Whenthedesiredwellepthts.reachedepunpacanbe The ressure increase-ma -exceed started 9jtPpt9mpressure due

ate

no

eslqetoadOEffectojhL

The

hole

adequately

cleaned

starling

orientation

because torqqe
dirtytidle

Qan

be affected

an uAcir

cula$d
Fill

may
at

be
thetbol

out of the or by-staging thetool ledge normai
full

slowly to

rotating

450

time

This prevents maintain

buildup
circuMtlon rate

During

Pressure

As the

bit

is

lowered

to

bottom

and
anit

torguedemand
differential

on the motor the

tncreases

the pressure

acro$s

motor increases

pitportionally

Therefore-an the
circulation

indlcdpressurewfll
system
to

show-on
this

ptessure selected

increase the

gauge at -limiting therecommended valbe -M
pressure optlrnqrn

opertng

performance

See

Appendix

Ford

Opinion_v3

30

of

28-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 31 of 33

NOTE

For

Hydraulic

Thrust

extended and

Interval Bit

also Balance Appendht throughota

use
Charts

the to

nidmi$
To aseqre

effidiencySeg constant torque

61
the
tool

run maintain constant

pressure ratings weight
Will

NOTE
Therefore1
jail

or
the

subttaptirtg

caise

both

pressura and.torque

increase or decrease

at

aglancØ weight

pressure the

gauge
is

eflabies

petformtrtgandlso

opetatorto serves

as

drilling in

addition

maintaining
coristant

constant orientation

weight of

surewill also assure the

pres bentsub

DtiJling

DVNADRlLL

Tool

OperatingHydrauiics

andpe Gaue

IS

OffBbttom Pcesstge

ffSbtm
0v0t4a5n4

When
sure

the

poththe-dibptacetheælnidrot pressure

is total

the stand
required

surliace

pump equipment

to

gauge shows the known volume
pipe collara theannulus

amount

of

pres

of

positive-displacement surtact
is

motor bit1andbatkup
an
offbcdtcirrt

called

condition

IS

Ford

Page

31

of

28-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 32 of 33

Stxmpe

Gauge

cm

cm

Qr-Boitom

bng
Beqause
tinaf energy
that

the
directly

ve-disptacementrnotorplace.s
at

the

rtathe

ehery
from

the

bit

rather the

than

transferrir

through torque
at the

canbe

stai

avSItile

.poskive-cilspIcerpentrnbtert

direttlyprpportionaltd
is

the pressure
in

Sop

across

the

mdtor

as

change on the

More
sure
at

weight

bit the

system pressure means higher tqtaj system
bit drills-oft

pres
pres___

the surface

As

system

sure decreases

the stand
will

pressure

gauge

therefore

can be usedasan
drill

Æecuratetieigtfl and

torque

indicator

pipe

friction

Stanpipe

Gauge
Odfl-Ott

Off-Sottoni

Ptesstn

_r

When
prpssure
Sill-ott
if

the pressure guage reads then stops adding

optimum on-b
Weight
to the
driller

ttorn bit
-t

occurs

The pressure
thebit

will

puts

roorewsighton

Ford

BreWs

Opinionv3

Page

32

of

34 28-May-04

Case 1:03-cv-02579-RPM

Document 145-2

Filed 01/11/2007

Page 33 of 33

Ford

Opinion_v3

Page

33

of

34

28-May-04