throbber
The Commissioner of Patents
`Gatineau, Quebec.
`
`Dear Sir:
`
`PCT Application
`
`( E21B 43/117 (2006.01) )
`Examiner Colin Watts
`
`Re: Serial No:
`Owner:
`Title:
`
`Filed:
`
`2,933,756
`HUNTING TITAN, INC.
`BOX BY PIN PERFORATING
`METHODS
`May 22,2015
`
`industry
`
`GUN SYSTEM AND
`
`lncustr.s
`
`AlM/J
`
`Y/M/D
`
`AMENDMENT
`
`With respect
`
`C004390803
`to the Examiner's Action dated May 25, 2017, Applicant
`files an
`
`1IIIIi~llili~illilllllllllllllll 2°1~~:~~
`
`CIPO
`
`OPIC
`
`Amendment in response thereto, as follows:
`
`IN THE DESCRIPTION
`
`Page 12, after 2nd line of Figure 19E, insert --- Figure 19F is a detail from the cross-
`
`section view .... shown in Figure 19C. ---
`
`Page 14, after 2nd line of Figure 26F,
`
`insert n _ Figure 26G is an axial cross-section
`
`view .... as indicated in Figure 26C. ---.
`
`Please delete description pages 12 and 14 as filed and insert new description pages 12
`
`and 14 enclosed.
`
`IN THE CLAIMS
`
`Amend Claims IS, 19, 22, 52 and 74 as set forth in the copy of these five claims
`
`attached as an Appendix. A complete set of claims 1 - 75 is filed.
`
`... 2
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`IN THE DRAWINGS
`
`Drawing Sheet 8/32, cancel "FIG. 13A".
`
`Drawing Sheet 9/32, renumber "FIGS. 13B - 13F" as new FIGS. 13A - 13E.
`
`Delete drawing sheets 8/32 and 9/32 containing the above noted FIGS. and insert newly
`
`amended drawing pages 8/32 and 9/32. Amendments are shown in red and cirled on the copy.
`
`REMARKS
`
`Applicant acknowledges with appreciation the thorough review of the application by the
`
`Examiner.
`
`DESCRIPTION
`
`Applicant has inserted brief references to FIGS. 19F and 26G shown in the drawings but
`
`not set forth in the brief description of the drawings.
`
`DRAWINGS
`
`Applicant has deleted Figure 13A and renumbered Figures 13B to 13F as new Figures
`
`13A - 13E for consistency with the brief description of these Figures.
`
`CLAIMS
`
`As noted above, Applicant has amended certain claims, namely, claims 15, 19 22, 52
`
`and 74, but has enclosed a new and complete set of the claims 1 - 75.
`
`OBJECTION
`
`As Applicant appreciates the Action,
`
`the Examiner has adopted the reasoning and
`
`analysis of the IPRP in rejecting various claims as anticipated, and all claims 1 to 75 as lacking
`
`invention or obviousness.
`
`... 3
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`

`As Applicant appreciates the IPRP, the more significant art cited appears as follows:
`
`- 3 -
`
`US 2012/0199352 Al to Lanclos et al.
`US 5,392,860 A to Ross
`US 2013/0118342 Al to Tassaroli
`US 4,650009 A to McClure et al.
`US 2008/0047716 Al to McKee et al.
`US 2005/0229805 Al to Myers Jr. et al.
`US 201110042069 Al to Bailey et al.
`US 2,216,359 A to Spencer
`US 2008/0047456 Al to Li et al.
`US 2007/0084336 Al to Neves
`
`Regarding Claim 1:
`
`Lanclos does not disclose inserting a cartridge into a perforating gun as claimed.
`
`Instead, Lanclos discusses a cartridge that "can be inserted within the annular cartridge
`
`sub 68 for easy assembly". (Paragraph 22) Lanclos describes that cartridge sub 68 is "coupled
`
`in series with the downstream perforating gun 622 , " (Id.)
`
`Regarding Claim 5:
`
`Lanclos does not disclose wherein at least one of the electrical contacts is a pin adapted
`
`to engage a socket.
`
`Instead,
`
`the cited portion of Lanclos in the IPRP discloses a coaxial
`
`connector, not a pin.
`
`Regarding Claim 48:
`
`Lanclos does not disclose a perforating gun body comprising a substantially cylindrical
`
`tube; and upper end of the tube having internal threads; a lower end of the tube having external
`
`threads; wherein the lower end has a smaller diameter than the upper end.
`
`Instead Lanclos
`
`discloses a standard perforating gun 14 having internal threads at both ends as identified in the
`
`red boxes in the annotated figure below.
`
`Items 42, 15, 14, and 40 in Figure 2 of Lanclos are
`
`... 4
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`- 4 -
`
`not a perforating gun body as claimed. Instead, they are "upper connection sub 42", "connecting
`
`subs 15", "perforating gun 14", and "firing head 40." Lanclos describes these as separate
`
`components performing separate functions. What is claimed here is a perforating gun body
`
`analogous to the body indicated by reference numeral 14 in Lanclos but with additional novel
`
`features. Regarding the threading and sizing of the ends that had previously not been used
`
`because perforating gun body walls are typically not thick enough to support both internal and
`
`external threads. That is the reason why systems like Lanclos teach a perforating gun body with
`
`internal threads and subs with external threads, because the subs are made from machined billets
`
`while the gun bodies are made from tubes.
`
`FIG. 2
`(PRIOR ART)
`
`J.
`
`I
`
`36
`
`TO FIG.2'CONTINU£DJ
`
`... 5
`
`a:
`
`1.6 -
`
`15 "
`
`10
`
`1.2
`
`'6
`
`·21.
`
`____J
`
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`

`

`Regarding Claim 54:
`
`- 5 -
`
`Lanclos does not disclose a detonator proximate the upper end of the cartridge.
`
`Item
`
`78 cited by the IPRP is not a detonator but is a "ground lead."
`
`(Paragraph 23).
`
`Regarding Claim 52:
`
`Claim 52 has been amended to make the perforating gun body an element of the claim.
`
`No perforating gun body is disclosed by Ross.
`
`Regarding Claims 74-75:
`
`Claim 74 has been amended to make clear that the claimed detonating cord bore is
`
`straight and circular. Further,
`
`item 48 of McClure is not a detonator but, rather, a shaped
`
`charge initiated by the detonating cord 24. Additionally, since the detonating core "bore" of
`
`McClure has no central axis, it's central axis cannot be offset by 35 degrees from the detonator
`
`bore axis.
`
`OBVIOUSNESS
`
`Regarding Claim 9:
`
`It would not have been obvious to one of ordinary skill in the art to transport the loaded
`
`perforating gun of Lanclos to a well site because Lanclos's device would not be safe to transport
`
`according to relevant explosive handling laws and regulations because Lanclos's device attaches
`
`a detonator to the explosive load directly, providing no electrical shunt.
`
`Regarding Claim 10:
`
`It would not have been obvious to thread the perforating gun bodies of Lanclos together
`
`because that would render Lanclos non-functional. Lanclos requires a cartridge sub 68 to
`
`... 6
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`- 6 -
`
`contain the detonator and switch. Without the sub, there would be no place to put the cartridge
`
`of Lanclos. Further, neither Lanclos nor any other cited art suggests perforating guns having
`
`internal and external threads on opposite ends. Accordingly, the modification of Lanclos to
`
`reach the claimed limitations requires multiple levels of innovation.
`
`Regarding Claim 11:
`
`Lanclos does not disclose the manufacture of a perforating gun body having internal
`
`threads on one end and corresponding external
`
`threads on the other, as claimed.
`
`Instead,
`
`Lanclos teaches away by using a standard perforating gun 14 having internal threads at both
`
`ends, as identified in the red boxes in the annotated figure above.
`
`Items 42, 15, 14, and 40 in
`
`Figure 2 of Lanclos are not a perforating gun body as claimed.
`
`Instead,
`
`they are "upper
`
`connection sub 42", "connecting subs 15", "perforating gun 14", and "firing head 40". Lanclos
`
`describes these as separate components performing separate functions. What is claimed here is
`
`a perforating gun body analogous to the body indicated by reference numeral 14 in Lanclos but
`
`with additional novel features. Regarding the threading and sizing of the ends,
`
`these had
`
`previously not been used because perforating gun body walls are typically not thick enough to
`
`support both internal and external threads. That is the reason why systems like Lanclos teach
`
`a perforating gun body with internal threads and subs with external threads, because the subs
`
`are made from machined billets while the gun bodies are made from tubes.
`
`Regarding Claim 15:
`
`Claim 15 has been amended to make clear that the external threads are formed
`
`after the fitting is affixed to the metallic tube.
`
`... 7
`
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`

`Regarding Claim 18:
`
`- 7 -
`
`Lanclos does not disclose a perforating gun body having internal threads on one end and
`
`external threads on the other, as claimed.
`
`Instead, Lanclos teaches away by using a standard
`
`perforating gun 14 having internal threads at both ends, as identified in the red boxes in the
`
`annotated figure above.
`
`Items 42, 15, 14, and 40 in Figure 2 of Lanclos are not a perforating
`
`gun body as claimed.
`
`Instead,
`
`they are "upper connection sub 42", "connecting subs 15",
`
`"perforating gun 14", and "firing head 40". Lanclos describes these as separate components
`
`performing separate functions. What is claimed here is a perforating gun body analogous to the
`
`body indicated by reference numeral 14 in Lanclos but with additional novel features. Regarding
`
`the threading and sizing of the ends, these had previously not been used because perforating gun
`
`body walls are typically not thick enough to support both internal and external threads. That
`
`is the reason why systems like Lanclos teach a perforating gun body with internal threads and
`
`subs with external threads, because the subs are made from machined billets while the gun
`
`bodies are made from tubes.
`
`Regarding Claim 19:
`
`Claim 19 has been amended to require that the switch be a positive control electronic
`
`switch as discussed in the specification.
`
`Regarding claim 22:
`
`Contact 76 of Lanclos is not proximate to the detonator 88.
`
`It is at the opposite end of
`
`the cartridge. The cited paragraph (22) of Lanclos does not discuss contacting the loading tubes
`
`at all.
`
`Instead, Lanclos shows an electrical wire making contact, not the loading tube 622.
`
`... 8
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`

`Regarding Claim 24:
`
`- 8 -
`
`Lanclos does not disclose end fittings on a charge loading tube.
`
`In fact, Lanclos does
`
`not discuss charge loading tubes or their relevance to Lanclos's invention at all.
`
`Instead,
`
`Lanclos describes "an attachment sub 138 ... for attachment and electrical connection between
`
`the perforating gun 62 and the wire line 132". An attachment sub is not an end fitting on a
`
`charge loading tube within a perforating gun.
`
`Regarding Claim 49:
`
`Lanclos does not disclose claim 48 as discussed above.
`
`It does not disclose claim 49 for
`
`the same reasons.
`
`Regarding Claim 63:
`
`Lanclos does not teach or suggest threaded cartridge assemblies in any way. The mere
`
`fact that Lanclos knew threads exist is not enough to render their use on the cartridge of Lanclos
`
`obvious.
`
`Regarding Claim 64:
`
`Tassaroli does not teach the upper and lower end fittings of a charge holder comprising
`
`an insulating material about their outer circumference.
`
`Instead, Tassaroli teaches a plurality of
`
`"metal centering clips 500" abut the outer circumference of the end fittings. (Figure 2, paragraph
`
`80). Tassaroli goes on to teach "the physical pressure of the metal centering dips [sic] (500) on
`
`the inside wall of the gun (1) electrically connects the carrier (2) to ground".
`
`(paragraph 84).
`
`Accordingly, Tassaroli teaches directly away from the claimed invention because Tassaroli
`
`... 9
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`- 9 -
`
`explicitly teaches electrically connecting the charge tube to the gun body using end fittings.
`
`In
`
`contrast, the claimed invention electrically insulates the charge holder from the gun tube using
`
`insulating fittings.
`
`Regarding Claim 65:
`
`Nothing in Tassaroli
`
`teaches electrically connecting either item 300 (insert) or 400
`
`{tubular insert} to the charge holder. Given that the charge holder of Tassaroli is electrically
`
`grounded, providing a further connection to ground through the end fittings would be pointless.
`
`Regarding Claims 12 and 13:
`
`As discussed above,Lanclos does not teach the method of claim 11. Further, nothing
`
`in Lanclos or McKee teaches or suggests that swaging and threading of perforating gun bodies
`
`would be desirable for any reason.
`
`Regarding Claims 16 - 17:
`
`Bailey merely discloses the possibility of welding joints to pipe.
`
`It does not teach or
`
`suggest the appropriateness, desirability, or possibility of welding fittings to perforating guns.
`
`Lanclos teaches away from welding fittings on perforating guns because it
`
`teaches the
`
`desirability of removing the various components for service.
`
`Regarding Claim 23:
`
`Lanclos does not teach the system of claim 19 as discussed above.
`
`It would not have
`
`been obvious to combine Lanclos with Spencer, Tassaroli, or Li to reach the claimed invention
`
`because Lanclos does not use a charge loading tube as an electrical conductor.
`
`Instead, Lanclos
`
`... 10
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`- 10 -
`
`uses wires as shown in Figure 3. Accordingly, there is no reason to insulate a charge loading
`
`tube in the system taught by Lanclos.
`
`Spencer cannot teach an insulator between a shaped charge loading tube and a gun body
`
`because Spencer has no shaped charges and no shaped charge loading tube.
`
`Instead, Spencer
`
`is directed to "gun perforators ... for the purpose of firing bullets through the casing".
`
`Tassaroli does not teach an insulator between the charge loading tube and the gun body,
`
`instead it teaches electrically connecting the two as discussed regarding claim 64. Tassaroli
`
`teaches a plurality of "metal centering clips 500" about the outer circumference of the end
`
`fittings (Figure 2, paragraph 80). Tassaroli goes on to teach "the physical pressure of the metal
`
`centering dips [sic] (500) on the inside wall of the gun (1) electrically connects the carrier (2)
`
`to ground".
`
`(Paragraph 84). Accordingly, Tassaroli teaches directly away from the claimed
`
`invention because Tassaroli explicitly teaches electrically connecting the charge tube to the gun
`
`body using end fittings.
`
`In contrast,
`
`the claimed invention electrically insulates the charge
`
`holder from the gun tube using insulating fittings.
`
`Regarding Claim 26:
`
`Lanclos does not teach the system of claim 19, as discussed above. Spencer cannot
`
`teach an insulator on an apex end of a shaped charge because Spencer has no shaped charges.
`
`Instead, Spencer is directed to "gun perforators ... for the purpose of firing bullets through the
`
`casing" .
`
`... 11
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`Regarding Claims 29 - 33:
`
`- 11 -
`
`Lanclos and Spencer do not
`
`teach the system of claim 23, as discussed above.
`
`Accordingly, they cannot teach claims which depend from claim 23.
`
`Regarding Claim 27:
`
`Tassaroli does not teach insulating fittings on an open end of a plurality of shaped
`
`charges as claimed. Tassaroli
`
`teaches nothing about fittings on shaped charges.
`
`Instead,
`
`Tassaroli teaches an end fitting on a charge carrier. A charge carrier is not a shaped charge and
`
`is certainly not a plurality of shaped charges. Accordingly, end fitting 100 of Tassaroli cannot
`
`be an insulating fitting on a shaped charge.
`
`Regarding Claim 59:
`
`Claim 59 requires that the first electrical contact proximate the upper end of the cartridge
`
`comprises a conductive end cap. A single element described in a single way by Tassaroli cannot
`
`teach both an insulating end cap and a conductive end cap, as purported in the IPRP. Tassaroli
`
`does not teach a conductive end cap in any regard.
`
`Instead, it teaches conductive clips on an
`
`insulating end cap. Neither of these are related to the claimed cartridge and neither Tassaroli
`
`or Lanclos provide any teaching or motivation as to how the insulating/conductive end fittings
`
`on a charge tube of Tassaroli could work on the claimed cartridge.
`
`Regarding Claim 60:
`
`Lanclos and Tassaroli do not
`
`teach the cartridge of claim 59 as discussed above.
`
`Further, the clip 500 of Tassaroli is not a compression spring because it is not compressed in
`
`use, but is rather operates in a beam action.
`
`... 12
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`Regarding claim 61:
`
`- 12 -
`
`Tassaroli does not teach that the retractable contact (RC) shown in Figure 1 is either
`
`insulated from or in electrical contact with anything. Accordingly, Tassaroli does not teach an
`
`insulated feed through pin.
`
`Regarding Claim 28:
`
`Lanclos does not teach the system of claim 19, as discussed above.
`
`It would not have
`
`been obvious to combine Lanclos with Li to reach the claimed invention because Lanclos does
`
`not use a charge loading tube as an electrical conductor.
`
`Instead, Laclos uses wires a shown in
`
`Figure 3. Accordingly, there is no reason to insulate a charge loading tube in the system taught
`
`by Lanclos
`
`Regarding Claim 25:
`
`Lanclos does not teach the system of claim 19, as discussed above.
`
`It would not have
`
`been obvious to combine Lanclos with Spencer to reach the claimed invention because Lanclos
`
`does not use a charge loading tube as an electrical conductor.
`
`Instead, Lanclos uses wires as
`
`shown in Figure 3. Accordingly, there is no reason to insulate a charge loading tube in the
`
`system taught by Lanclos.
`
`Spencer cannot teach an insulated cap on an upper or lower end fitting of a shaped
`
`charge loading tube because Spencer has no shaped charges and no shaped charge loading tube.
`
`Instead, Spencer is directed to "gun perforators ... for the purpose of firing bullets through the
`
`casing" .
`
`... 13
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`Regarding Claim 35:
`
`- 13 -
`
`Tassaroli does not teach an insulator between the loading tube and the gun body. Instead
`
`it teaches electrically connecting the two, as discussed regarding claim 64. Tassaroli teaches a
`
`plurality of "metal centering clips 500" about
`
`the outer circumference of the end fittings.
`
`(Figure 2, paragraph 80). Tassaroli goes on to teach "the physical pressure of the metal
`
`centering dips [sic] (500) on the inside wall of the gun (1) electrically connects the carrier (2)
`
`to ground".
`
`(Paragraph 84). Accordingly, Tassaroli teaches directly away from the claimed
`
`invention because Tassaroli explicitly teaches electrically connecting the charge tube to the gun
`
`body using end fittings.
`
`In contrast,
`
`the claimed invention electrically insulates the charge
`
`holder from the gun tube using insulating fittings.
`
`Regarding Claim 36:
`
`Tassaroli and Lanclos do not teach the limitations of claim 35 as discussed above.
`
`Regarding Claim 37:
`
`Tassaroli and Lanclos do not teach the limitations of claim 35 as discussed above.
`
`Further, Lanclos does not teach anything about contacts with loading tubes because it does not
`
`teach loading tubes,
`
`it only teaches perforating guns and a cartridge sub.
`
`Regarding Claim 38:
`
`Tassaroli and Lanclos do not teach the limitations of claim 35, as discussed above.
`
`Further, Lanclos does not teach anything about fittings on loading tubes because it does not teach
`
`loading tubes, it only teaches perforating guns and a cartridge sub.
`
`... 14
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`v t
`
`Regarding Claim 41;
`
`- 14 -
`
`Tassaroli and Lanclos do not teach the limitations of claim 35, as discussed above.
`
`Further, Tassaroli does not teach insulating fittings on an open end of a plurality of shaped
`
`charges as claimed. Tassaroli
`
`teaches nothing about fittings on shaped charges.
`
`Instead,
`
`Tassaroli teaches an end fitting on a charge carrier. A charge carrier is not a shaped charge and
`
`is certainly not a plurality of shaped charges. Accordingly, end fitting 100 of Tassaroli cannot
`
`be an insulating fitting on a shaped charge.
`
`Regarding Claim 43:
`
`Tassaroli and Lanclos do not teach the limitations of claim 35 as discussed above.
`
`Regarding Claim 44:
`
`Tassaroli and Lanclos do not teach the limitations of claims 35 and 43 as discussed
`
`above.
`
`above.
`
`Regarding Claim 45:
`
`Tassaroli and Lanclos do not teach the limitations of claims 35 and 44 as discussed
`
`Regarding Claim 46:
`
`Tassaroli and Lanclos do not teach the limitations of claims 35 and 43 as discussed
`
`above. Further Lanclos does not disclose wherein at least one of the electrical contacts is a pin
`
`adapted to engage a socket.
`
`Instead, the cited portion of Lanclos discloses a coaxial connector,
`
`not a pin.
`
`... 15
`
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`Regarding Claim 47:
`
`- 15 -
`
`Tassaroli and Lanclos do not teach the limitations of claims 35 and 46 as discussed
`
`above.
`
`Regarding Claims 50 and 51;
`
`Lanclos does not teach the system of claim 48 as discussed above.
`
`It would not have
`
`been obvious to combine Lanclos with Neves to reach the claimed invention because Lanclos
`
`does not teach using a shaped charge loading tube or shaped charge holder.
`
`Regarding Claim 53:
`
`Claim 52 has been amended to make the perforating gun body an element of the claim.
`
`No perforating gun body is disclosed by Ross.
`
`Regarding Claim 57:
`
`Ross does not teach two electrical contacts at one end in Figure 4. The description
`
`accompanying Figure 4 states "Insulator pellet 135 further includes electrical contacts 154 and
`
`156, and tester fuse 158, which has leads which are soldered to electrical contacts 154 and 156".
`
`(Ross, 8:8-11). The specification also states "tester fuse 158 is positioned diagonally between
`
`electrical contacts 154 and 156, to which it is soldered".
`
`(Ross, 8:49-50). Figure 4 of Ross is
`
`clearly mislabelled since the test fuse 158 is clearly soldered between contacts on the left and
`
`right side of the drawing, as depicted below.
`
`... 16
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`- 16 -
`
`Regarding Claim 58:
`
`Ross does not teach two electrical contacts on one end of a cartridge as described above
`
`with regard to claim 57.
`
`Regarding Claim 62:
`
`Lanclos does not disclose claim 54 as discussed above.
`
`Item 78 cited by the IPRP is not
`
`a detonator but is a "ground lead".
`
`(Paragraph 23).
`
`Regarding Claims 68 - 73:
`
`Tassaroli does not disclose the loading tube of claim 65 as discussed above.
`
`Regarding Claim 39:
`
`Tassaroli and Lanclos do not teach the limitations of claims 35 or 38, as discussed
`
`above. Lanclos does not teach anything about fittings on loading tubes because it does not teach
`
`... 17
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`- 17 -
`
`loading tubes, it only teaches perforating guns and a cartridge sub. Further Spencer cannot teach
`
`an insulating end cap between a shaped charge loading tube and a gun body because Spencer has
`
`no shaped charges and no shaped charge loading tube.
`
`Instead, Spencer is directed to "gun
`
`perforators ... for the purpose of firing bullets through the casing".
`
`Regarding Claim 40:
`
`Tassaroli and Lanclos do not teach the limitations of claims 35 or 38 as discussed above.
`
`Lanclos does not teach anything about fittings on loading tubes because it does not teach loading
`
`tubes, it only teaches perforating guns and a cartridge sub. Further Spencer cannot teach an
`
`insulating end cap between a shaped charge loading tube and gun body because Spencer has no
`
`shaped charges and no shaped charge loading tube.
`
`Instead, Spencer is directed to "gun
`
`perforators ... for the purpose of firing bullets through the casing".
`
`Regarding Claim 40:
`
`Tassaroli and Lanclos do not teach the limitations of claim 35 as discussed above.
`
`Lanclos does not teach anything about fittings on loading tubes because it does not teach loading
`
`tubes it only teaches perforating guns and a cartridge sub. Further, Spencer cannot teach an
`
`insulator on a shaped charge because Spencer has no shaped charges and no shaped charge
`
`loading tube. Instead, Spencer is directed to "gun perforators ... for the purpose of firing bullets
`
`through the casing".
`
`Regarding Claim 42:
`
`Tassaroli and Lanclos do not teach the limitations of claim 35 as discussed above.
`
`... 18
`
`CA 2933756 2017-11-23
`
`DynaEnergetics Europe GmbH
`Ex. 2014
`Page 17 of 18
`
`

`

`,.
`
`- 18 -
`
`Reconsideration of the application is believed to be in order.
`
`Respectfully submitted
`HUNTING TITAN, INC.
`
`By:
`
`---i.:.....-_~!....---=--A--~-------
`
`November 23, 2017
`
`225 Metcalfe Street
`Suite 700
`Ottawa, Ontario, K2P IP9
`
`ea
`Ends.
`
`CA 2933756 2017-11-23
`
`DynaEnergetics Europe GmbH
`Ex. 2014
`Page 18 of 18
`
`

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