UNITED STATES PATENT AND TRADEMARK OFFICE
`
`—————————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`—————————————
`
`
`JOHN CRANE, INC., JOHN CRANE
`PRODUCTION SOLUTIONS, INC., & JOHN CRANE GROUP CORP.,
`
`Petitioners,
`
`v.
`
`FINALROD IP, LLC,
`Patent Owner.
`
`
`
`—————————————
`
`IPR2016-01786
`U.S. Patent No. 9,045,951
`Issued June 2, 2015
`
`—————————————
`
`
`
`PETITION FOR INTER PARTES REVIEW
`UNDER 35 U.S.C. §§ 311-318 & 37 C.F.R. 42.100 et. seq.
`
`
`
`
`
`

`
`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`
`Table of Contents
`
`
`I.  MANDATORY NOTICES (37 C.F.R. § 42.8) ................................................. 1 
`A.  Real Party-In Interest (37 C.F.R. § 42.8(b)(1) .............................................. 1 
`B.  Related Matters (37 C.F.R. § 42.8(b)(2)) ...................................................... 1 
`C.  Counsel & Service Information (37 C.F.R. §§ 42.8(b)(3)-(4)) ..................... 2 
`II.  CERTIFICATION AND FEES ......................................................................... 2 
`III.  IDENTIFICATION OF CHALLENGE (37 C.F.R. § 42.104(b)) & RELIEF
`REQUESTED (37 C.F.R. § 42.22(a)(1)) ................................................................... 2 
`IV.  BACKGROUND INFORMATION FOR THE ’951 PATENT ........................ 3 
`A. 
`Introduction ................................................................................................... 3 
`B.  Background of Field of Art ........................................................................... 5 
`C.  Overview of the ’951 Patent .......................................................................... 8 
`D.  Prosecution History of the ’951 Patent ....................................................... 10 
`V.  THE CLAIMS OF THE ’951 PATENT ARE UNPATENTABLE ................ 12 
`A.  Relevant Field of Art and Level of Ordinary Skill ..................................... 12 
`B. 
`Independent Claims Listing ........................................................................ 12 
`C.  Claim Constructions .................................................................................... 20 
`(a)  “define a [first/second/third] distribution of force” (claims 4, 7, 14, and
`21) 21 
`(b)  “such that” (Claims 4, 7, 14-15, 21) ........................................................ 22 
`D.  Ground 1: Claims 4, 6-8, 14-15, 17, 21-22, 35, 47, 52, and 65-68 are
`unpatentable under 35 U.S.C. §103 as obvious over the Rutledge ’431 Patent in
`view of Iwasaki & McKay ................................................................................... 25 
`(a)  Overview of Rutledge ’431, Iwasaki, and McKay Patents ...................... 25 
`(b)  Reasons and Motivation to Combine ....................................................... 26 
`(c)  Independent Claims 4, 7, 14, and 21 ........................................................ 27 
`(d)  Claims 6 and 52 ........................................................................................ 41 
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`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`(e)  Claims 8 and 35 ........................................................................................ 43 
`(f)  Claims 15 and 22 ...................................................................................... 45 
`(g)  Claim 17 ................................................................................................... 46 
`(h)  Claims 65-68............................................................................................. 48 
`E.  Ground 2: Claims 50, 57, and 59 are unpatentable under 35 U.S.C. §103 as
`obvious over the Rutledge ’431, Iwasaki, and McKay Patents further in view of
`Anderson .............................................................................................................. 50 
`(a)  Reasons and Motivation to Combine ....................................................... 50 
`(b)  Claim 50 ................................................................................................... 52 
`(c)  Claim 57 ................................................................................................... 55 
`(d)  Claim 59 ................................................................................................... 56 
`VI.  CONCLUSION ................................................................................................ 58 
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`ii
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`

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`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`
`EXHIBIT LIST
`
`Case No. IPR2016-01786
`U.S. Patent No. 9,045,951 (“’951 Patent”)
`U.S. Patent No. 9,045,951 File History
`U.S. Patent No. 6,193,431 (“Rutledge ’431 Patent”)
`U.S. Patent No. 4,475,839 (“Strandberg”)
`U.S. Patent No. 4,662,774 (“Morrow”)
`U.S. Patent No. 8,113,277 (“Rutledge ’277 Patent”)
`U.S. Patent No. 4,822,201 (“Iwasaki”)
`U.S. Patent No. 4,919,560 (“Rutledge ’560 Patent”)
`U.S. Patent No. 5,253,946 (“Watkins”)
`Declaration of Gary R. Wooley
`Side-by-Side Comparison of the ’951 Patent claims
`U.S. Patent No. 4,401,396 (“McKay”)
`U.S. Reissue Patent No. RE32,865 (“Rutledge ’865 Patent”)
`U.S. Patent No. 7,730,938 (“Rutledge ’938 Patent”)
`Edward L. Hoffman, Finite Element Analysis of Sucker Rod
`Couplings with Guidelines for Improving Fatigue Life, Sandia
`National Laboratories, (Jul. 11, 1997) (“Hoffman Article”).
`U.S. Patent No. 8,062,463 (“Rutledge ’463 Patent”)
`U.S. Patent No. 6,886,484 (“Thomas”)
`U.S. Patent No. 4,653,953 (“Anderson”)
`Printout of Fiberod History from “https://superod.com/about-us/”
`Press Release for Smith’s purchase of Fiberod (March 19, 2008)
`Asset Purchase Agreement Between Smiths and Fiberod (March
`2008)
`Intellectual Property Disclosure Schedule from Asset Purchase
`Agreement
`U.S. Patent No. 8,851,162 (“Rutledge ’162 Patent”)
`U.S. Patent No. 9,181,757 (“Rutledge ’757 Patent”)
`Case No. 7:15-cv-00097 (W.D. Tex.), September 15, 2015, First
`Amended Complaint
`
`Exhibit
`1001
`1002
`1003
`1004
`1005
`1006
`1007
`1008
`1009
`1010
`1011
`1012
`1013
`1014
`1015
`
`1016
`1017
`1018
`1019
`1020
`1021
`
`1022
`
`1023
`1024
`1025
`
`
`
`
`
`
`
`
`iii
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`

`
`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`Petitioners, John Crane, Inc., John Crane Production Solutions, Inc., and
`
`John Crane Group Corp. (“John Crane”), respectfully request Inter Partes Review
`
`(“IPR”) of claims 4, 6-8, 14-15, 17, 21-22, 35, 50, 52, 57, 59, and 65-68
`
`(“Challenged Claims”) of U.S. Patent No. 9,045,951 (“the ’951 Patent”, Exhibit
`
`1001), believed to be currently assigned to Finalrod IP, LLC (“Finalrod” or “Patent
`
`Owner”).1
`
`I. MANDATORY NOTICES (37 C.F.R. § 42.8)
`A. Real Party-In Interest (37 C.F.R. § 42.8(b)(1)
`Petitioners, John Crane, Inc., John Crane Production Solutions, Inc., and
`
`John Crane Group Corp., are the real parties-in-interest.
`
`B. Related Matters (37 C.F.R. § 42.8(b)(2))
`The ’951 Patent is also currently the subject of the following litigations:
`
`Finalrod IP, LLC, et al. v. John Crane, Inc., et al., Case No. 7-15-cv-00097 (W.D.
`
`Tex. 2015). Petitioners are filing an additional IPR of claims 60-63 and 69
`
`concurrently herewith as IPR2016-01827. The ’951 Patent is a continuation-in-
`
`part of U.S. Patent No. 8,851,162 (the “’162 Patent”), which was the subject of
`
`IPR2016-00232 (terminated).
`
`
`1 While no assignment data has been recorded at the U.S.P.T.O., Finalrod
`
`represented in District Court that it is the owner of the ’951 Patent. See
`
`Exhibit 1025, ¶ 13.
`
`
`
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`1
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`

`
`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`C. Counsel & Service Information (37 C.F.R. §§ 42.8(b)(3)-(4))
`Lead Counsel: Dion M. Bregman (Reg. No. 45,645); Back-Up Counsel:
`
`Jason C. White (Reg. No. 42,223), Ryan B. McBeth (Reg. No. 69,817), Nicholas
`
`A. Restauri (Reg. No. 71,783), and Nicholaus E. Floyd (Reg. No. 74,438).
`
`Service Information: Service of any documents may be made at Morgan,
`
`Lewis & Bockius LLP, 1400 Page Mill Road, Palo Alto, CA, 94304 (Telephone:
`
`650.843.4000; Fax: 650.843.4001).
`
`Petitioners
`
`consents
`
`to
`
`e-mail
`
`service
`
`at:
`
`JohnCrane-
`
`FinalrodIPRs@morganlewis.com.
`
`II. CERTIFICATION AND FEES
`Petitioners certify that the ’951 Patent is available for IPR and that
`
`Petitioners are neither barred nor estopped from requesting this IPR on the grounds
`
`identified herein.
`
`Petitioners authorize the USPTO to charge Deposit Account No. 50-0310
`
`(Order No. 015304-21-5001) for the fees set in 37 C.F.R. § 42.15(b) for this
`
`Petition, and further authorizes payment for any additional fees to be charged to
`
`this Deposit Account.
`
`III.
`
`IDENTIFICATION OF CHALLENGE (37 C.F.R. § 42.104(b)) &
`RELIEF REQUESTED (37 C.F.R. § 42.22(a)(1))
`
`Petitioners ask the Board to find the Challenged Claims unpatentable based
`
`on the following grounds:
`
`
`
`
`
`
`2
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`

`
`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`Ground 1: Claims 4, 6-8, 14, 15, 17, 21, 22, 35, 47, 52, and 65-68 are
`
`unpatentable under 35 U.S.C. §103 as obvious over U.S. Patent No. 6,193,431
`
`(“Rutledge ’431 Patent”; Ex. 1003) in view of U.S. Patent No. 4,822,201
`
`(“Iwasaki”; Ex. 1007) and further in view of U.S. Patent No. 4,401,396 (“McKay”;
`
`Ex. 1012).
`
`Ground 2: Claims 50, 57, and 59 are unpatentable under 35 U.S.C. §103 as
`
`obvious over the Rutledge ’43, Iwasaki, and McKay Patents further in view of U.S.
`
`Patent No. 4,653,953 (“Anderson”; Ex. 1018).
`
`The ’951 Patent (Ex. 1001) was filed on December 18, 2013. The ’951
`
`Patent is a continuation-in-part of U.S. Patent No. 9,181,757 (Ex. 1024), filed on
`
`Feb. 17, 2012, which is a continuation-in-part of U.S. Patent No. 8,851,162 (“’162
`
`Patent”; Ex. 1023), filed August 9, 2011. However, the ’951 Patent specification is
`
`distinct from those of the earlier two patents, the ’951 Patent’s Application Data
`
`Sheet acknowledges that the ’951 Patent contains claims that are not entitled to a
`
`priority earlier than December 18, 2013, and the application was examined under
`
`the AIA. Ex. 1002, at 6, 125. Even so, prior art Exhibits 1003-09 and 1011-18
`
`indisputably qualify as prior art as each reference issued or was published more
`
`than a year prior the earliest possible priority date of August 9, 2011.
`
`IV. BACKGROUND INFORMATION FOR THE ’951 PATENT
`A.
`Introduction
`In 2008, Petitioners, John Crane, acquired The Fiber Composite Company,
`
`
`
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`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`Inc. (“Fiberod”), a company formed by one of the ’951 Patent inventors, Russ
`
`Rutledge. See Exs. 1019, 1021. As part of this acquisition, Petitioners purchased
`
`several Rutledge patents from Fiberod, including, among others, the prior art
`
`Rutledge ’431 Patent (Ex. 1003), Rutledge ’277 Patent (Ex. 1007), Rutledge ’865
`
`Patent (Ex. 1013), Rutledge ’938 Patent (Ex. 1014), and Rutledge ’463 Patent (Ex.
`
`1016) (“the prior Rutledge patents”). See Ex. 1020; Ex; 1021; Ex. 1022. Under
`
`the purchase agreement, Mr. Rutledge agreed not to compete with John Crane for
`
`three years, i.e., until 2011. See Ex. 1021. On August 9, 2011, shortly after the
`
`expiration of the agreement, Mr. Rutledge filed a U.S. patent application which
`
`ultimately issued into the ’162 Patent (Ex. 1023), the parent of the ’951 Patent
`
`challenged by this Petition. Ex. 1001.
`
`On June 29, 2015, Finalrod, Mr. Rutledge’s new company, sued John Crane
`
`in W.D. Texas alleging infringement of the ’162 Patent. On September 15, 2015,
`
`Finalrod added the ’951 Patent to the lawsuit. As set forth in detail herein, the
`
`’951 Patents claim a device having similar features as disclosed by the prior
`
`Rutledge patents that Mr. Rutledge sold to John Crane in 2008.
`
`
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`4
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`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`
`B.
`Background of Field of Art
`A sucker rod pump is an oil extracting device that operates to bring below-
`
`ground oil to the earth’s surface. See Ex. 1015, at 9, Figure 1 (shown below with
`
`coloring added). Generally, in order to recover oil from deep oil wellbores, a bore
`
`is drilled into the ground and a casing and tubing (yellow) is inserted into the bore.
`
`A reciprocating pump, such as a horse head pump (green), is used to actuate the
`
`pump to recover oil from the reservoir. A sucker rod (blue) is connected to the
`
`reciprocating pump at one end and is connected at its end to a travelling valve that
`
`reciprocates within a standing valve that is secured within the wellbore.
`
`“Typically, a series of sucker rods are connected end to end to form a sucker rod
`
`string, which extends from the pump drive....” Ex 1006, 1:61 – 2:17.
`
`
`
`The ’951 Patent is directed to an end
`
`fitting designed to be used in connection with oil
`
`sucker rod strings. Ex. 1001, Abstract. End
`
`fittings, such as those claimed by the ’951
`
`Patent, are commonly used in the oil industry to
`
`connect two fiberglass sucker rods to each other
`
`end-to-end in order to form a string of sucker
`
`rods that may be used for oil extraction.
`
`Ex. 1010, ¶¶ 13-16; Ex. 1001, Fig. 1. Given that
`
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`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`the string of sucker rods can, at times, exceed a thousand feet in length, a well-
`
`known and common understanding in the industry is that end fittings must
`
`withstand “mechanical forces acting on the rod/adhesive/metal interface…
`
`compressive forces, such as during a stroke of the pump either up or down, and
`
`negative load forces.” Ex. 1006, 7:51-54 (emphasis added throughout unless
`
`otherwise noted); see also Ex. 1010, ¶¶ 13-18.
`
`For decades, the industry standard has been to use fiberglass sucker rods to
`
`reduce the weight associated with traditional steel sucker rods. Ex. 1008, 1:21-24;
`
`Ex. 1010, ¶¶ 16-18. However, one problem to be solved is that “[f]iberglass is just
`
`difficult to grab a hold of and hold securely and it is very important that the
`
`structure have such integrity as to substantially eliminate fiberglass rod-to-end
`
`fitting parting....” Ex. 1012, 1:51-54. In addition, it was well-understood that
`
`“[d]amaging stress concentrations in the area of rod entry into a fitting and within
`
`the rod end fittings must be minimized....” Id. at 1:56-58; see also Ex. 1010, ¶¶
`
`18-35 (providing overview of force concentrations encountered during use). It was
`
`also well recognized that “any attempt to minimize the destructive forces leading
`
`to catastrophic failure must be focused on the fiberglass/adhesive/metal
`
`interface,” i.e., the wedge system formed in the end fitting interior. Ex. 1003,
`
`4:42-44.
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`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`One of the earliest concepts for “gripping” a sucker rod while still
`
`minimizing stress concentrations was to use a wedge design, wherein wedge-
`
`shaped gaps (yellow in the portion of Figure 25 of Ex. 1003 shown below) are
`
`formed between the inner wall of the steel end fitting (blue) and the fiberglass
`
`sucker rod (green).
`
` Ex. 1003, Fig. 25
`
`(references omitted and coloring added). The
`
`wedges are filled with an epoxy, such that
`
`when the epoxy hardens, “the angle of the
`
`taper of the respective pockets [] relieve stress
`
`on the epoxy ... filling space between the rod
`
`11 and each fitting 12.” Ex. 1012, 2:63 – 3:1;
`
`Ex. 1010, ¶¶ 36-43. Thus, it was well-known
`
`in the industry that parameters defining the
`
`geometric shape of the wedges, such as the angle at which the leading and trailing
`
`edges of each wedge taper, the overall wedge length, and the geometry of the
`
`wedge cross-section, as well as many other features of the wedge, can all be varied
`
`to affect the distribution of forces on each wedge-shaped portion. See Ex. 1012, at
`
`3:1-14 (describing embodiments having various angles of taper); Ex. 1010, ¶¶ 38-
`
`43 (collecting background art).
`
`Accordingly, a principal motive in wedge design is to vary these wedge
`
`
`
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`7
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`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`parameters in order to manipulate the distribution of compressive stress to avoid
`
`spiking of compressive stresses at any one location, which can lead to premature
`
`failure. See Ex. 1010, ¶¶ 40-43 (describing that it was general knowledge to a
`
`person of ordinary skill in the art at the time of the invention (“POSITA”) to
`
`modify various wedge design features to distribute compressive forces). A
`
`POSITA would have been aware of these general design considerations and the
`
`common types of problems that must be addressed in any end fitting design that
`
`utilizes wedges. See Ex. 1010, ¶¶ 36-39 (discussing problems to address during
`
`sucker rod use, including “decrease the severity of the stress concentrations”), ¶¶
`
`40-43 (discussing factors that lead to stress concentration), ¶¶ 44-46 (discussing
`
`the naturally uneven distribution of forces on a wedge system), ¶¶ 47-49
`
`(discussing well-known principles of wedge design to alter wedge shape and direct
`
`forces).
`
`C. Overview of the ’951 Patent
`The ’951 Patent issued as a continuation-in-part from the earlier ’162 Patent.
`
`Ex. 1023. The ’162 and ’951 Patents are two of about a dozen patent applications
`
`relating to end fittings and wedge designs filed by members of the Rutledge family
`
`over the last 30 years. The ’951 Patent is directed to a wedge design for sucker rod
`
`end fittings. Ex. 1001, Abstract. As discussed below, the ’951 Patent claims
`
`combinations of well-known and obvious design patterns that were previously
`
`
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`8
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`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`disclosed in the prior Rutledge patents, as well as other end fitting prior art.
`
`Ex. 1010, ¶¶ 36-49.
`
`
`
`The independent claims of the ’951 Patent each recite a wedge system
`
`formed in the interior surface of a sucker rod end fitting. As explained in further
`
`detail below, the independent claims recite that the force distribution on the inner
`
`wedge is greater than that on any intermediate wedge, which is in turn greater on
`
`any outer wedge – i.e., the forces on the wedges progressively increase towards the
`
`closed end of the end fitting (similar to the “force differential” limitation of the
`
`’162 Patent). Each independent claim recites one or more design parameters that
`
`help give the wedges their “triangular configuration,” including combinations of
`
`(1) leading edge length, (2) trailing edge length, and/or (3) the size of the angle
`
`formed between the two edges (shown on the two annotated portions of Ex. 1001,
`
`Fig. 10 below).
`
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`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`
`
`
`The dependent claims all recite certain relationships between edge lengths and
`
`angle sizes chosen from the various possible permutations of how these three
`
`parameters can relate to each other (e.g., claim 4 reciting two angles having same
`
`size and one being different). The ’951 Patent doesn’t describe any benefit
`
`associated with each recited permutation, and in fact, different dependent claims
`
`recite opposite configurations from each other.
`
`D.
`Prosecution History of the ’951 Patent
`The ’951 Patent was filed on December 18, 2013, over 34 years after Mr.
`
`
`
`Rutledge’s first application (Ex. 1013) that related to end fittings. Ex. 1002, at 1.
`
`In the first non-final Office Action, the Examiner rejected the majority of the
`
`claims as being anticipated and obvious over the Morrow reference (Ex. 1005).
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`

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`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`Ex. 1002, at 126. In rejecting the claims, the Examiner stated that Morrow
`
`(Ex. 1005, 2:20-39) disclosed all of the limitations of the independent claims,
`
`including the recited force distributions on each wedge and forces that were
`
`greater toward the end fitting’s closed end. Ex. 1002, at 126-28.
`
`The Examiner also indicated that claims 2, 4 - 7, 10 - 21, 24, 25, 27 - 32, 34,
`
`36 - 37, 40 - 57, 59 - 64, 66 - 77, 15 - 21 and 88 - 91 were allowable. Ex. 1002, at
`
`130. No reason(s) for allowance were provided, but each of the allowed claims
`
`recited a specific relationship between two or more edges and/or two or more
`
`angles within the wedge system.
`
`
`
`Subsequently, independent claim 4 was allowed after adding the limitations
`
`that “at least two” of the angles differ in size and that the second angle is equal to
`
`either the first or the third angle. Independent claim 14 was allowed after adding
`
`the limitation that the first trailing edge length and second trailing edge length
`
`differ. Independent claim 21 was allowed after adding the limitation that at least
`
`two of the trailing edge lengths vary. See Ex. 1002, at 151-67. Independent claims
`
`7 and 60 were allowed without any amendments.
`
`
`
`Thus, the claims were allowed after the particular relationships between the
`
`leading edges and/or angles were added to the independent claims. As explained
`
`below, these relationships were simple design choices chosen from a known
`
`limited set of possible configurations and do not make the claims patentable.
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`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`There was nothing novel about each of these configurations at the time of the
`
`purported invention, and in fact, the allowed claims recite many configurations that
`
`are directly opposite to each other and none of these configurations change the
`
`force distribution profiles recited by the independent claims (i.e., the inner
`
`wedge receives the most compressive force regardless of the recited configurations
`
`of edges and/or angles).
`
`V. THE CLAIMS OF THE ’951 PATENT ARE UNPATENTABLE
`A. Relevant Field of Art and Level of Ordinary Skill
`The ’951 Patent is directed to wedge designs for sucker rod end fittings. The
`
`relevant field of art therefore relates to the end fitting designs for sucker rods. See
`
`Ex. 1010, ¶¶ 74-75. One of ordinary skill in the art for the ’951 Patent would have
`
`had at least 4 years of educational training in Mechanical Engineering or other
`
`similar fields, such as Civil Engineering or Petroleum Engineering, or equivalent
`
`field experience, plus at least two years’ experience in the design, development,
`
`and use of sucker rods and end fittings. Ex. 1010, ¶¶ 76-78.
`
`B.
`Independent Claims Listing
`The Rutledge ’951 Patent has six independent claims, all directed to end
`
`
`
`fitting designs for sucker rods. Claim 1 is not challenged. Claims 4, 7, 14, and 21
`
`all recite forming a “wedge system” in the interior end of an end fitting having
`
`either two “wedge portions” (claim 14) or three “wedge portions” (claims 4, 7, and
`
`21) formed in the end fitting’s interior wall. The below claims listing shows
`
`
`
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` 12
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`
`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`claims 4, 7, 14, and 21 side-by-side. Where one of the claims lacks a particular
`
`limitation, the respective box is shown in gray. Similarly, where the claims
`
`contain distinct limitations (that Petitioners will address separately for each claim)
`
`the respective box is shown in red.
`
`Section #
`
`V.D.(c).1
`
`V.D.(c).1
`
`V.D.(c).1
`
`V.D.(c).2
`
`V.D.(c).2
`
`
`
`
`Claim Listing - Independent Claims 4, 7, 14, and 21
`[7.1] An end
`[14.1] An end
`[21.1] An end
`[4.1] An end
`fitting for a
`fitting for a
`fitting for a
`fitting for a
`sucker rod, the
`sucker rod, the
`sucker rod, the
`sucker rod, the
`end fitting
`end fitting
`end fitting
`end fitting
`comprising:
`comprising:
`comprising:
`comprising:
`[21.2] a body
`[14.2] a body
`[7.2] a body
`[4.2] a body
`having an
`having an
`having an
`having an
`interior, a
`interior, a
`interior, a
`interior, a closed
`closed end, an
`closed end, and
`closed end, an
`end, an open
`open end, and
`an open end;
`open end, and
`end, and
`[7.3] a wedge
`
`[21.3] a wedge
`[4.3] a wedge
`system formed
`system formed
`system formed
`in the interior,
`in the interior,
`in the interior,
`wherein the
`wherein the
`wherein the
`wedge system
`wedge system
`wedge system
`comprises:
`comprises:
`comprises:
`[21.4a] an
`[7.4a] an outer
`[4.4a] an outer
`outer wedge
`wedge portion
`wedge portion
`portion formed
`formed in the
`formed in the
`in the interior
`interior
`interior
`proximate to
`proximate to
`proximate to the
`the open end,
`the open end,
`open end,
`wherein the
`wherein the
`wherein the
`outer wedge
`outer wedge
`outer wedge
`portion
`portion
`portion
`comprises
`comprises
`comprises
`[4.4b] a first
`[7.4b] a first
`[21.4b] a first
`leading edge, a
`leading edge, a
`leading edge, a
`first trailing
`first trailing
`first trailing
`edge, and a first
`edge, and a first
`edge, and a
` 13
`
`[14.4a] a first
`wedge portion
`formed in the
`interior
`proximate the
`open end,
`wherein the first
`wedge portion
`comprises
`
`[14.4b] a first
`leading edge, a
`first trailing
`edge, and a first
`
`

`
`angle between
`the first leading
`edge and the
`first trailing
`edge,
`
`angle between
`the first leading
`edge and the
`first trailing
`edge,
`
`[4.4c] wherein
`the first leading
`edge faces the
`open end and
`the first trailing
`edge faces the
`closed end, and
`
`[7.4c] wherein
`the first leading
`edge faces the
`open end and
`the first trailing
`edge faces the
`closed end, and
`
`[4.4d] wherein
`the length of the
`first leading
`edge, the length
`of the first
`trailing edge,
`and the size of
`the first angle
`define a first
`distribution of
`force in the
`outer wedge
`portion;
`
`[7.4d] wherein
`the length of
`the first leading
`edge, the length
`of the first
`trailing edge,
`and the size of
`the first angle
`define a first
`distribution of
`force in the
`outer wedge
`portion;
`
`V.D.(c).2
`
`V.D.(c).3
`
`V.D.(c).2
`
`[4.5a] an
`intermediate
`wedge portion
`formed in the
`interior between
`the outer wedge
`portion and the
`closed end,
`
`V.D.(c).2 [4.5b] wherein
`
`
`
`[7.5a] an
`intermediate
`wedge portion
`formed in the
`interior
`between the
`outer wedge
`portion and the
`closed end,
`[7.5b] wherein
` 14
`
`[14.4c] wherein
`the first leading
`edge faces the
`open end and
`the first trailing
`edge faces the
`closed end, and
`
`[14.4d] wherein
`the length of the
`first leading
`edge, the length
`of the first
`trailing edge,
`and the size of
`the first angle
`define a first
`distribution of
`force in the first
`wedge portion;
`and
`
`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`angle between
`first angle
`the first leading
`between the
`edge and the
`first leading
`first trailing
`edge and the
`edge,
`first trailing
`edge,
`[21.4c]
`wherein the
`first leading
`edge faces the
`open end and
`the first trailing
`edge faces the
`closed end, and
`[21.4d]
`wherein the
`length of the
`first leading
`edge, the
`length of the
`first trailing
`edge, and the
`size of the first
`angle define a
`first
`distribution of
`force in the
`outer wedge
`portion;
`[21.5a] an
`intermediate
`wedge portion
`formed in the
`interior
`between the
`outer wedge
`portion and the
`closed end,
`[21.5b]
`
`
`
`
`
`

`
`the intermediate
`wedge portion
`comprises a
`second leading
`edge, a second
`trailing edge,
`and a second
`angle between
`the second
`leading edge
`and the second
`trailing edge,
`
`the intermediate
`wedge portion
`comprises a
`second leading
`edge, a second
`trailing edge,
`and a second
`angle between
`the second
`leading edge
`and the second
`trailing edge,
`
`[4.5c] wherein
`the second
`leading edge
`faces the open
`end and the
`second trailing
`edge faces the
`closed end, and
`
`[7.5c] wherein
`the second
`leading edge
`faces the open
`end and the
`second trailing
`edge faces the
`closed end, and
`
`[4.5d] wherein
`the length of the
`second leading
`edge, the length
`of the second
`trailing edge,
`and the size of
`the second angle
`define a second
`distribution of
`force in the
`intermediate
`wedge portion;
`and
`
`[7.5d] wherein
`the length of
`the second
`leading edge,
`the length of
`the second
`trailing edge,
`and the size of
`the second
`angle define a
`second
`distribution of
`force in the
`intermediate
`wedge portion;
`and
`[7.6a] an inner
`
` 15
`
`V.D.(c).2
`
`V.D.(c).3
`
`V.D.(c).2 [4.6a] an inner
`
`
`
`
`
`
`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`wherein the
`intermediate
`wedge portion
`comprises a
`second leading
`edge, a second
`trailing edge,
`and a second
`angle between
`the second
`leading edge
`and the second
`trailing edge,
`[21.5c]
`wherein the
`second leading
`edge faces the
`open end and
`the second
`trailing edge
`faces the
`closed end, and
`[21.5d]
`wherein the
`length of the
`second leading
`edge, the
`length of the
`second trailing
`edge, and the
`size of the
`second angle
`define a second
`distribution of
`force in the
`intermediate
`wedge portion;
`and
`[14.6a] a second [21.6a] an
`
`
`
`

`
`wedge portion
`formed in the
`interior between
`the intermediate
`wedge portion
`and the closed
`end, proximate
`to the closed
`end,
`
`[4.6b] wherein
`the inner wedge
`portion
`comprises a
`third leading
`edge, a third
`trailing edge,
`and a third angle
`first angle
`between the
`third leading
`edge and the
`second third
`edge,
`
`[4.6c] wherein
`the third leading
`edge faces the
`open end and
`the third trailing
`edge faces the
`closed end, and
`
`wedge portion
`formed in the
`interior
`between the
`intermediate
`wedge portion
`and the closed
`end, proximate
`to the closed
`end,
`[7.6b] wherein
`the inner wedge
`portion
`comprises a
`third leading
`edge, a third
`trailing edge,
`and a third
`angle first angle
`between the
`third leading
`edge and the
`third trailing
`edge,
`
`[7.6c] wherein
`the third
`leading edge
`faces the open
`end and the
`third trailing
`edge faces the
`closed end,
`
`V.D.(c).2
`
`V.D.(c).2
`
`V.D.(c).3
`
`[4.6d] wherein
`the length of the
`third leading
`edge, the length
`of the third
`
`[7.6d] and
`wherein the
`length of the
`third leading
`edge, the length
`
`
`
`
` 16
`
`[14.6b] wherein
`the second
`wedge portion
`comprises a
`second leading
`edge, a second
`trailing edge,
`and a second
`angle between
`the second
`leading edge
`and the second
`trailing edge,
`
`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`inner wedge
`wedge portion
`portion formed
`formed in the
`in the interior
`interior
`between the
`proximate the
`intermediate
`closed end,
`wedge portion
`between the first
`and the closed
`wedge portion
`end, proximate
`and the closed
`to the closed
`end,
`end,
`[21.6b]
`wherein the
`inner wedge
`portion
`comprises a
`third leading
`edge, a third
`trailing edge,
`and a third
`angle first
`angle between
`the third
`leading edge
`and the second
`third edge,
`[21.6c]
`wherein the
`third leading
`edge faces the
`open end and
`the third
`trailing edge
`faces the
`closed end, and
`[4.6d] wherein
`the length of
`the third
`leading edge,
`the length of
`
`[14.6c] wherein
`the second
`leading edge
`faces the open
`end and the
`second trailing
`edge faces the
`closed end, and
`
`[14.6d] wherein
`the length of the
`second leading
`edge, the length
`of the second
`
`

`
`trailing edge,
`and the size of
`the third angle
`define a third
`distribution of
`force in the
`inner wedge
`portion,
`
`[4.7a] wherein
`at least two of
`the first angle,
`the second
`angle, and the
`third angle
`differ in size
`
`[4.7b] such that
`during use a
`compressive
`load applied to
`the sucker rod at
`the inner wedge
`portion is
`greater than a
`compressive
`load applied to
`the sucker rod at
`the outer wedge
`portion,
`
`of the third
`trailing edge,
`and the size of
`the third angle
`define a third
`distribution of
`force in the
`inner wedge
`portion,
`[7.7a] wherein
`the first trailing
`edge, the
`second trailing
`edge, and the
`third trailing
`edge differ in
`length
`
`[7.7b] such that
`during use a
`compressive
`load applied to
`the sucker rod
`at the inner
`wedge portion
`is greater than a
`compressive
`load applied to
`the sucker rod
`at the
`intermediate
`wedge portion,
`and the
`compressive
`load applied to
`the sucker rod
`at the
`intermediate
`
` 17
`
`V.D.(c).5
`
`V.D.(c).6
`
`
`
`
`[14.7a] wherein
`the length of the
`first trailing
`edge and the
`length of the
`second trailing
`edge differ, and
`
`Petition for Inter Partes Review
`of U.S. Patent No. 9,045,951
`the third
`trailing edge,
`trailing edge,
`and the size of
`and the size of
`the second angle
`the third angle
`define a second
`define a third
`distribution of
`distribution of
`force in the
`force in the
`second wedge
`inner wedge
`portion,
`portion,
`[21.7a]
`wherein the
`length of at
`least two of the
`first trailing
`edge, the
`second trailing
`edge, and the
`third trailing
`edge vary, and
`[21.7b]
`wherein the
`first
`distribution of
`forc