throbber
IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
` 
`
`
`DYNAENERGETICS EUROPE GMBH, and
`DYNAENERGETICS US, INC.,
`
`
`
`
`
`
`
`
`Plaintiffs,
`
`
`
`
`v.
`
`
`
`
`
`
`
`
`
`HUNTING TITAN, INC.,
`
`
`
`
`
`
`
`
`
`Civil Action No: 6:20-cv-00069-ADA
`
`
`
`
`JURY TRIAL DEMANDED
`
`)))))))))))
`
`
`
`
`
`
`Defendant.
`
`________________________________________
`
`
`
`
`
`PLAINTIFFS’ PRELIMINARY INFRINGEMENT CONTENTIONS
`
`Pursuant to the Order Governing Proceedings (Dkt. 24), Plaintiffs DynaEnergetics Europe
`
`
`
`
`
`GmbH and DynaEnergetics US, Inc. (collectively, “DynaEnergetics” or “Plaintiffs”) provide the
`
`following Preliminary Infringement Contentions to Defendant Hunting Titan, Inc. (“Hunting” or
`
`“Defendant”). Plaintiffs’ contentions are preliminary in that they reflect Plaintiffs’ knowledge and
`
`contentions as of this date in the present action. Plaintiffs reserve the right to revise, amend, and/or
`
`supplement their infringement contentions as appropriate, including after Defendant provides
`
`additional discovery of the infringing products and after the Court provides its claim construction
`
`ruling. Plaintiffs also reserve the right to submit amended and final infringement contentions
`
`pursuant to the Order Governing Proceedings. These disclosures are made with respect to United
`
`States Patent Nos. 10,429,161 (“the ’161 Patent”) and 10,472,938 (“the ’938 Patent”) (collectively,
`
`“Asserted Patents” or “Patents-in-Suit”).
`
`
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 001
`
`

`

`I. Asserted Claims and Accused Products
`
`DynaEnergetics asserts the following claims against Hunting (collectively, “Asserted
`
` 
`
`Claims”):
`
`
`
`
`
`’161 Patent: Claims 1, 4, and 20
`
`’938 Patent: Claims, 1, 5, and 7-12
`
`Based on information reasonably available to Plaintiffs at this time and in view of
`
`Plaintiffs’ present understanding of the proper construction of these claims, Plaintiffs identify the
`
`following Accused Products for the Asserted Claims: the Hunting H-1™ Perforating Gun System
`
`accused of infringement in Plaintiff’s Amended Complaint, and any other products or systems
`
`made or sold by Defendant that are comparable in structure or function to the H-1™ Perforating
`
`Gun System. Plaintiffs expressly reserve the right to identify additional Accused Products if they
`
`learn through discovery or otherwise that additional instrumentalities infringe the Asserted Claims.
`
`The exhibits enumerated below include claim charts showing how the identified Accused
`
`Products meet each element of the Asserted Claims:
`
` Ex. A: the ’161 Patent versus Hunting H-1™ Perforating Gun System
`
` Ex. B: the ’938 Patent versus Hunting H-1™ Perforating Gun System
`
`Based on information reasonably available to Plaintiffs at this time and in view of Plaintiffs’
`
`present understanding of the proper construction of the Asserted Claims, each element of the
`
`Asserted Claims is literally present in the Accused Products, as set forth in Exhibits A and B.
`
`Plaintiffs reserve the right to assert infringement under the doctrine of equivalents after Defendant
`
`provides additional discovery and produces the Accused Products for inspection, and after the
`
`Court provides its claim construction ruling. Plaintiffs further reserve the right to revise, amend,
`
`and/or supplement these disclosures, including the attached claim charts, as appropriate, including
`
`
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 002
`
`

`

`after Defendant provides additional discovery and produces the Accused Products for inspection,
`
`after the Court provides its claim construction ruling, and as contemplated by the Court’s Order
`
` 
`
`Governing Proceedings.
`
`II.
`
`Priority Dates
`
`U.S. Patent No. 10,429,161 (“the ’161 Patent”) is a division of U.S. Patent App. No.
`
`15/287,309, filed on October 6, 2016, now U.S. Patent No. 9,702,680, which is a division of U.S.
`
`Patent App. No. 14/904,788, filed as App. No. PCT/CA2014/050673 on July 16, 2014 and now
`
`U.S. Patent No. 9,424,021, which claims priority to foreign application CA 2821506, filed July
`
`18, 2013. Internal documents produced with these contentions demonstrate that the priority date
`
`of the ’161 Patent is no later than June 19, 2012.
`
`U.S. Patent No. 10,472,938 (“the ’938 Patent”) is a continuation of U.S. Patent App. No.
`
`15/920,812, filed on March 14, 2018, which is a continuation of U.S. Patent App. No. 15/617,344,
`
`filed on June 8, 2017, which is a division of U.S. Patent App. No. 15/287,309, filed on October 6,
`
`2016, now U.S. Patent No. 9,702,680, which is a division of U.S. Patent App. No. 14/904,788,
`
`filed as App. No. PCT/CA2014/050673 on July 16, 2014 and now U.S. Patent No. 9,949,021,
`
`which claims priority to foreign application CA 2821506, filed July 18, 2013. Internal documents
`
`produced with these contentions demonstrate that the priority date of the ’938 Patent is no later
`
`than October 30, 2012.
`
`III. Document Production
`
`DynaEnergetics is producing (1) documents evidencing conception and reduction to
`
`practice for each claimed invention; and (2) a copy of the file history for each Patent-in-Suit with
`
`production numbers DYNA_WDTX_0000001 to DYNA_WDTX_0000999.
`
`
`
`
`
`
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 003
`
`

`

` 
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`By: /s/Eric H. Findlay
`Eric H. Findlay
`Texas Bar No. 00789886
`Roger Brian Craft
`Texas Bar No. 04972020
`FINDLAY CRAFT P.C.
`102 N. College Avenue, Suite 900
`Tyler, TX 83402
`Telephone: (903) 534-1100
`Facsimile: (903) 534-1137
`Email: efindlay@findlaycraft.com
`Email: bcraft@findlaycraft.com
`
`Barry J. Herman (admitted pro hac vice)
`Maryland Federal Bar No. 26061
`Julie C. Giardina (admitted pro hac vice)
`Maryland Federal Bar No. 21085
`WOMBLE BOND DICKINSON (US) LLP
`100 Light St, 26th Floor
`Baltimore, MD 21202
`Telephone: (410) 545-5830
`Email: Barry.Herman@wbd-us.com
`Telephone: (410) 545-5802
`Email: Julie.Giardina@wbd-us.com
`
`Preston H. Heard (admitted pro hac vice)
`Georgia Bar No. 476319
`WOMBLE BOND DICKINSON (US) LLP
`271 17th Street, NW, Suite 2400
`Atlanta, GA 30363
`Telephone: (404) 888-7366
`Email: Preston.Heard@wbd-us.com
`
`Ana J. Friedman (admitted pro hac vice)
`North Carolina Bar No. 53117
`WOMBLE BOND DICKINSON (US) LLP
`One West Fourth Street
`Winston-Salem, NC 27101
`Telephone: (336) 747-6622
`Email: Ana.Friedman@wbd-us.com
`
`
`
`
`
`Dated: April 22, 2020
`
`
`
`
`
`
`
`
`
`
`
`
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 004
`
`

`

` 
`
`Lisa J. Moyles (admitted pro hac vice)
`Connecticut State Bar No. 425652
`Jason M. Rockman (admitted pro hac vice)
`New York Bar No. 4450953
`MOYLES IP, LLC
`One Enterprise Drive, Suite 428
`Shelton, CT 06484
`Telephone: (203) 428-4420
`Email: lmoyles@moylesip.com
`Email: jrockman@moylesip.com
`
`Attorneys for Plaintiffs DynaEnergetics Europe
`GmbH and DynaEnergetics US, Inc.
`
`
`
`
`
`
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 005
`
`

`

`EXHIBIT A – ’161 Patent Claim Chart
`
`The initial contentions set forth herein are Plaintiffs’ current contentions and are based on their current understanding of the
`
`evidence and facts. Because discovery has not commenced in this case, Plaintiffs reserve the right to amend, supplement, and modify
`
`the contentions set forth herein as this litigation progresses and in accordance with the Federal and Local Rules and the Court’s Order
`
`Governing Proceedings. As used herein, “Accused Product” refers to the Hunting H-1™ Perforating Gun System accused of
`
`infringement in Plaintiffs’ Amended Complaint, and any other products or systems made or sold by Defendant that are comparable in
`
` 
`
`structure or function to the H-1™ Perforating Gun System.
`
`
`
`
`
`1
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 006
`
`

`

`
`
`US 10,429,161
`Claim 1
`1[pre] A perforation gun
`system comprising:
`
`Defendant’s H-1® Perforating Gun System
`
`
` 
`
`
`See, e.g., http://www.hunting-intl.com/media/3091949/HT_H-
`1%20Perforating%20Gun%20System_Tri-Fold_2019.1.3.pdf
`
`
`
`
`2
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 007
`
`

`

`US 10,429,161
`Claim 1
`1[a] a gun carrier;
`
`Defendant’s H-1® Perforating Gun System
`
`
` 
`
`Gun Carrier 
`(Body)
`
`
`See, e.g., https://www.perforators.org/wp-content/uploads/2016/05/IPS-16-22.pdf at 7.
`
`
`
`
`
`
`3
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 008
`
`

`

`1[b] a first connector
`comprising a coupler for
`providing energetic coupling
`between a detonator and a
`detonation cord, and at least
`one directional locking fin for
`locking the first connector
`within the gun carrier; and
`
`The H-1 includes a first connector—“deto transfer puck” (see annotated product illustration
`below)—that energetically couples a detonator and detonation cord and is positioned in the gun
`carrier. The transfer puck also includes a directional locking fin for locking the deto transfer puck
`within the gun carrier:
`
` 
`
`Directional locking fin 
`
`Deto Transfer Puck 240 
`(First Connector)
`
`Gun Carrier (Body)
`
`Detonating 
`Cord
`
`Energetic 
`Coupling
`
`Detonator
`
`
`
`
`
`
`
`4
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 009
`
`

`

`US 10,429,161
`Claim 1
`
`Defendant’s H-1® Perforating Gun System
`
`
` 
`
`Directional locking fin 
`
`Energetic 
`Coupling
`
`Deto Transfer Puck 240 
`(First Connector)
`
`
`See, e.g., https://www.perforators.org/wp-content/uploads/2016/05/IPS-16-22.pdf at 7, 9.
`See U.S. Pat. No. 10,273,788 (describing H-1 system), Figs. 5 and 20D
`
`
`
`
`
`5
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 010
`
`

`

`Defendant’s H-1® Perforating Gun System
`
`The H-1 includes a second connector—detonating cord “retainer” (see annotated product
`illustration below)—that is positioned in the gun carrier, spaced apart from the first connector, and
`configured for positioning and terminating the detonation cord in the perforation gun system:
`
` 
`
`US 10,429,161
`Claim 1
`1[c] at least one second
`connector positioned in the
`gun carrier spaced apart from
`the first connector, wherein
`the second connector is
`configured for terminating the
`detonation cord in the
`perforation gun system,
`
`
`See, e.g., https://www.perforators.org/wp-content/uploads/2016/05/IPS-16-22.pdf at 7, 9.
`
`
`
`6
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 011
`
`

`

`US 10,429,161
`Claim 1
`1[d] wherein at least one of
`the first and second
`connectors receive electrical
`connections therethrough.
`
`Defendant’s H-1® Perforating Gun System
`
`The first connector (i.e., deto transfer puck) in the H-1 receives an electrical connection
`therethrough (see annotated product illustration below), between the cartridge (detonator) and
`charge tube:
`
` 
`
`
`See, e.g., https://www.perforators.org/wp-content/uploads/2016/05/IPS-16-22.pdf at 7, 9.
`
`
`
`
`Conductive interface between 
`deto transfer puck and charge tube
`
`
`The second connector of the H-1 gun system identified above is injection molded.
`
`Defendant’s H-1® Perforating Gun System
`
`
`
`
`
`
`US 10,429,161
`Claim 4
`4. The perforation gun
`system of claim 1, wherein at
`least one of the first connector
`and the second connector is
`injection molded.
`
`
`
`
`7
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 012
`
`

`

`
`See Claim 1[pre]
`
`See Claim 1[a]
`
`See Claim 1[b]
`
`
`See Claim 1[c]
`
`See Claim 1[d]
`
`
`US 10,429,161
`Claim 20
`20[pre] A perforation gun
`system comprising:
`
`20[a] a gun carrier;
`
`20[b] a first connector for
`providing energetic coupling
`between a detonator and a
`detonation cord, the first
`connector positioned in the
`gun carrier; and
`
`20[c] at least one second
`connector positioned in the
`gun carrier spaced apart from
`the first connector, wherein
`the second connector is
`configured for terminating the
`detonation cord in the
`perforation gun system,
`
`20[d] wherein at least one of
`the first and second
`connectors receive electrical
`connections therethrough.
`
`
`
`
`
`
`
`
`
`
`
`
`Defendant’s H-1® Perforating Gun System
`
` 
`
`8
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 013
`
`

`

`EXHIBIT B – ’938 Patent Claim Chart
`
`The initial contentions set forth herein are Plaintiffs’ current contentions and are based on their current understanding of the
`
`evidence and facts. Because discovery has not commenced in this case, Plaintiffs reserve the right to amend, supplement, and modify
`
`the contentions set forth herein as this litigation progresses and in accordance with the Federal and Local Rules and the Court’s Order
`
`Governing Proceedings. As used herein, “Accused Product” refers to the Hunting H-1™ Perforating Gun System accused of
`
`infringement in Plaintiffs’ Amended Complaint, and any other products or systems made or sold by Defendant that are comparable in
`
` 
`
`structure or function to the H-1™ Perforating Gun System.
`
`
`
`
`
`1
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 014
`
`

`

`US 10,472,938
`Claim 1
`1[pre] A perforating
`gun, comprising:
`
`
`Defendant’s H-1® Perforating Gun System
`
`
`
` 
`
`
`See, e.g., http://www.hunting-intl.com/media/3091949/HT_H-
`1%20Perforating%20Gun%20System_Tri-Fold_2019.1.3.pdf
`
`
`
`
`
`
`1[a] an outer gun
`carrier;
`
`
`See, e.g., https://www.perforators.org/wp-content/uploads/2016/05/IPS-16-22.pdf at 7.
`
`
`2
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 015
`
`

`

`US 10,472,938
`Claim 1
`1[b] a charge holder
`positioned within the
`outer gun carrier and
`including at least one
`shaped charge;
`
`Defendant’s H-1® Perforating Gun System
`
`
`
`H‐1:
`
` 
`
`See, e.g., https://www.perforators.org/wp-content/uploads/2016/05/IPS-16-22.pdf at 7, 9.
`
`
`
`
`3
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 016
`
`

`

`1[c] a detonator
`contained entirely within
`the outer gun carrier, the
`detonator including
`
`The ControlFire Cartridge (CFC) is received within a baffle within the outer gun carrier and extends into
`the deto transfer puck (see annotated product illustrations below):
`
`
` 
`
`
`
`
`
`4
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 017
`
`

`

`US 10,472,938
`Claim 1
`
`Defendant’s H-1® Perforating Gun System
`
`
` 
`
`
`See, e.g., https://www.perforators.org/wp-content/uploads/2016/05/IPS-16-22.pdf at 7, 9.
`
`See U.S. Pat. No. 10,273,788 (describing H-1 system), Figs. 5 and 20D.
`
`
`
`
`5
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 018
`
`

`

`US 10,472,938
`Claim 1
`1[d] a detonator body
`containing detonator
`components,
`
`Defendant’s H-1® Perforating Gun System
`
`The CFC of the H-1 perforating gun system includes a detonator body housing detonator components
`such as a switch and explosive leads:
`
`
`
`
`
` 
`
`
`See, e.g., US Department of Transportation, Classification of Explosives, Tracking No. 2016100087,
`dated Jan. 13, 2017, ControlFire Cartridge Assembly Detonator Family, Product Number 1356, at 2.
`
`
`
`
`
`6
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 019
`
`

`

`US 10,472,938
`Claim 1
`1[e] a wireless signal-in
`connector,
`
`Defendant’s H-1® Perforating Gun System
`
`
`
` 
`
`
`See, e.g., US Department of Transportation, Classification of Explosives, Tracking No. 2016100087,
`dated Jan. 13, 2017, ControlFire Cartridge Assembly Detonator Family, Product Number 1356, at 2.
`
`
`
`
`
`7
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 020
`
`

`

`US 10,472,938
`Claim 1
`1[f] a wireless through
`wire connector,
`
`
`
`Defendant’s H-1® Perforating Gun System
`
`
` 
`
`
`See, e.g., US Department of Transportation, Classification of Explosives, Tracking No. 2016100087,
`dated Jan. 13, 2017, ControlFire Cartridge Assembly Detonator Family, Product Number 1356, at 2.
`
`
`
`
`
`
`8
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 021
`
`

`

`US 10,472,938
`Claim 1
`1[g] and a wireless
`ground contact
`connector, and
`
`
`
`
`Defendant’s H-1® Perforating Gun System
`
`
` 
`
`
`See, e.g., US Department of Transportation, Classification of Explosives, Tracking No. 2016100087,
`dated Jan. 13, 2017, ControlFire Cartridge Assembly Detonator Family, Product Number 1356, at 2.
`
`
`
`
`9
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 022
`
`

`

`Defendant’s H-1® Perforating Gun System
`
`
` 
`
`US 10,472,938
`Claim 1
`1[h] an insulator
`electrically isolating the
`wireless signal-in
`connector from the
`wireless through wire
`connector; and,
`
`
`
`
`See, e.g., US Department of Transportation, Classification of Explosives, Tracking No. 2016100087,
`dated Jan. 13, 2017, ControlFire Cartridge Assembly Detonator Family, Product Number 1356, at 2.
`
`
`
`
`
`
`10
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 023
`
`

`

`Defendant’s H-1® Perforating Gun System
`
`
` 
`
`US 10,472,938
`Claim 1
`1[i] a bulkhead, wherein
`the bulkhead includes a
`contact pin in wireless
`electrical contact with
`the wireless signal-in
`connector,
`
`
`
`
`See, e.g., US Department of Transportation, Classification of Explosives, Tracking No. 2016100087,
`dated Jan. 13, 2017, ControlFire Cartridge Assembly Detonator Family, Product Number 1356, at 2.
`
`
`
`
`11
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 024
`
`

`

`US 10,472,938
`Claim 1
`1[j] wherein at least a
`portion of the bulkhead
`is contained within a
`tandem seal adapter,
`
`
`
`Defendant’s H-1® Perforating Gun System
`
`
` 
`
`
`
`See, e.g., US Department of Transportation, Classification of Explosives, Tracking No. 2016100087,
`dated Jan. 13, 2017, ControlFire Cartridge Assembly Detonator Family, Product Number 1356, at 2.
`
`
`
`
`
`
`12
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 025
`
`

`

`Defendant’s H-1® Perforating Gun System
`
`
` 
`
`US 10,472,938
`Claim 1
`1[k] and the wireless
`ground contact
`connector is in wireless
`electrical contact with
`the tandem seal adapter.
`
`
`
`
`See, e.g., US Department of Transportation, Classification of Explosives, Tracking No. 2016100087,
`dated Jan. 13, 2017, ControlFire Cartridge Assembly Detonator Family, Product Number 1356, at 2.
` 
`
`
`
` 
`
`13
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 026
`
`

`

`Defendant’s H-1® Perforating Gun System
`
`The H-1 gun system has a top connector, i.e., the deto transfer puck and bulkhead, where the portion of
`the CFC labeled “detonator” in the schematic is positioned within the top connector.
`
` 
`
`US 10,472,938
`Claim 5
`5. The perforating gun
`of claim 1, further
`comprising a top
`connector, wherein the
`detonator is positioned
`within the top connector.
`
`
`
`
` 
` 
`
`14
`
`
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 027
`
`

`

`US 10,472,938
`Claim 7
`7. The perforating gun
`of claim 1, wherein the
`detonator includes a
`signal-in wire
`electrically connected to
`the wireless signal-in
`connector and a ground
`wire electrically
`connected to the
`wireless ground contact
`connector.
`
`
` 
`US 10,472,938
`Claim 8
`8. The perforating gun
`of claim 1, wherein the
`detonator is configured
`for being electrically
`contactably received
`within the perforating
`gun without using a
`wired electrical
`connection, and the
`wireless signal-in
`connector, the wireless
`through-wire connector,
`and the wireless ground
`contact connector
`together are configured
`to replace the wired
`
`See claims 1[e], 1[g], and 1[k] above.
`
`
`
`Defendant’s H-1® Perforating Gun System
`
`
`
`
` 
`
`Defendant’s H-1® Perforating Gun System
`
`The CFC of the H-1 gun system is configured to be inserted on site without wiring.
`
`
`15
`
`
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 028
`
`

`

`US 10,472,938
`Claim 8
`electrical connection and
`to complete an electrical
`connection merely by
`contact.
`
`
` 
`US 10,472,938
`Claim 9
`9[pre] A modular
`detonator, comprising:
`
`9[a] a detonator body
`containing detonator
`components;
`9[b] a wireless signal-in
`connector;
`9[c] a wireless through
`wire connector;
`9[d] a wireless ground
`contact connector;
`9[e] a signal-in wire
`electrically connecting
`at least in part the
`wireless signal-in
`connector to at least one
`of the detonator
`components; and,
`9[f] an insulator
`electrically isolating the
`wireless signal-in
`connector from the
`
` 
`
`Defendant’s H-1® Perforating Gun System
`
`
`
`Defendant’s H-1® Perforating Gun System
`
`
`See claim 1[c] above
`
`
`See claim 1[d] above
`
`
`See claim 1[e] above
`
`See claim 1[f] above
`
`See claim 1[g] above
`
`See claims 1[e], 1[g], and 1[k] above.
`
`
`See claim 1[h] above
`
`16
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 029
`
`

`

`Defendant’s H-1® Perforating Gun System
`
`
` 
`
`See claim 1[i] above
`
`See claim 1[k] above
`
`US 10,472,938
`Claim 9
`wireless through wire
`connector, wherein
`9[g] the wireless signal-
`in connector is
`configured for making
`wireless electrical
`contact with an electrical
`contact of a bulkhead
`assembly contained at
`least in part within a
`tandem seal adapter
`when the modular
`detonator is received
`within a gun assembly
`of a perforating gun
`system, and
`9[h] the wireless ground
`contact connector is
`configured for making
`wireless electrical
`contact with the tandem
`seal adapter when the
`modular detonator is
`received within the gun
`assembly of the
`perforating gun system.
`
`
` 
`
`17
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 030
`
`

`

`US 10,472,938
`Claim 10
`10. The modular
`detonator of claim 9,
`further comprising a
`detonating cord
`connecting portion,
`wherein the detonating
`cord connecting portion
`is sized to retain a
`detonating cord and
`positioned to
`energetically couple the
`detonating cord to the
`detonator.
`
`
` 
` 
`US 10,472,938
`Claim 11
`11. The modular
`detonator of claim 9, the
`modular detonator
`further comprising a
`ground wire electrically
`
`Defendant’s H-1® Perforating Gun System
`
`The deto transfer puck of the H-1 gun system has a detonating cord connecting portion.
`
`
` 
`
`Energetic 
`Coupling
`
`Deto Transfer Puck 240 
`(First Connector)
`
`
`
`
`
`See claims 1 and 7 above.
`
`
`
`Defendant’s H-1® Perforating Gun System
`
`
`
`
`18
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 031
`
`

`

`Defendant’s H-1® Perforating Gun System
`
`
` 
`
`See claims 1 and 8 above.
`
`
`
`Defendant’s H-1® Perforating Gun System
`
`
`
`
`US 10,472,938
`Claim 11
`connected to the
`wireless ground contact
`connector.
`
`
` 
` 
`US 10,472,938
`Claim 12
`12. The modular
`detonator of claim 9,
`wherein the modular
`detonator is configured
`for being electrically
`contactably received
`within the gun assembly
`of the perforating gun
`system without using a
`wired electrical
`connection, and the
`wireless signal-in
`connector, the wireless
`through-wire connector,
`and the wireless ground
`contact connector
`together are configured
`to replace the wired
`electrical connection and
`to complete an electrical
`connection merely by
`contact.
`
`
`19
`
`Hunting Titan, Inc.
`Ex. 1006
`Pg. 032
`
`

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