UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`HUNTING TITAN, INC.
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`Petitioner
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`v.
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`DYNAENERGETICS EUROPE GMBH
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`Patent Owner
`____________
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`Case PGR 2020-00080
`Patent 10,472,938
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`____________
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`DECLARATION OF JOHN RODGERS, Ph.D.
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`DynaEnergetics Europe GmbH
`Ex. 2002
`Page 1 of 142
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`_____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`HUNTING TITAN, INC.
`
`Petitioner
`
`v.
`
`DYNAENERGETICS EUROPE GMBH
`
`Patent Owner
`____________
`
`Case PGR 2020-00080
`Patent 10,472,938
`
`____________
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`DECLARATION OF JOHN RODGERS, Ph.D.
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`DynaEnergetics Europe GmbH
`Ex. 2002
`Page 1 of 142
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`I, John Rodgers, hereby declare as follows:
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`PGR2020-00080
`U.S. Patent No. 10,472,938
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`I.
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`Background
`1.
`I have been retained by Patent Owner, DynaEnergetics Europe GmbH
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`(“DynaEnergetics”) in connection with the above-captioned Post Grant Review
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`(“PGR”) proceeding involving U.S. Patent No. 10,472,938 (“the ’938 Patent”) (Ex.
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`1001).
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`2.
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`I have been asked by DynaEnergetics to offer opinions regarding the
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`’938 Patent and the grounds on which Hunting Titan, Inc. (“Petitioner”) challenges
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`Claims 1-20 of the ’938 Patent, as set forth in the Petition for PGR (“the Petition”),1
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`including Petitioner’s asserted prior art references, positions regarding invalidity of
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`the challenged claims, and evidence submitted with the Petition. This declaration
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`sets forth the opinions I have reached to date regarding these matters.
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`3.
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`I am being compensated by DynaEnergetics at my standard hourly
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`consulting rate of $230 per hour for my time spent on this matter. My compensation
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`is not contingent on the outcome of the IPR or on the substance of my opinions.
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`4.
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`I have no financial interest in Petitioner or DynaEnergetics.
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`
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` 1
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` Hunting Titan, Inc. v. DynaEnergetics GmbH & Co. KG, Paper 1 (PTAB Aug. 12,
`2020).
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`II. Education and Work History
`5.
`I have a B.S.E. in mechanical engineering and materials science and a
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`second major in mathematics from Duke University. I have a M.S. from the
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`Massachusetts Institute of Technology (“MIT”) and a Ph.D. from MIT, both from
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`the Department of Aeronautics and Astronautics. In my research and academics at
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`MIT, I worked with active material systems and their application to structural
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`actuation and vibration control. Much of the work involved the development of
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`actuation systems for helicopter vibration control and other industrial and defense
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`applications. In addition, I worked on the development of novel piezoelectric
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`material systems for use in actuation and sensing applications.
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`6.
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`I am a professional engineer licensed in Texas, North Dakota, and
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`Connecticut and have over fifteen years of experience in the oilfield industry. I
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`founded and have worked in my engineering consulting business, Starboard
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`Innovations, LLC, since 2000. In my career, I have worked on a wide variety of
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`applications across many industries, though the bulk of my work has come in the
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`development of downhole tools. I have developed new mechanical tools and
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`software tools focused on a variety of different downhole applications. Several of
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`the tools focused on measuring and analyzing the dynamic response of downhole
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`tools and the surrounding wellbore and formation. Other tools that I have developed
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`involved mechanical actuation systems such as firing heads, frac sleeves, cementing
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`sleeves, and plugging devices. One example was a through-tubing bridge plug,
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`designed for high expansion-ratio applications, which is now a product used in the
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`field. Another design involved an autonomous, self-navigating wellbore plug with
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`the option for dissolvable components. I have developed or worked on downhole
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`tool designs for several other applications
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`including: acoustic
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`telemetry,
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`measurements while drilling (MWD), test valves, fracture and cementing sleeves,
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`and wireline fluid sensing. My involvement with many of these development
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`projects included designing, performing engineering analyses and simulations,
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`developing manufacturing processes, building prototypes, running qualification
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`tests, and supporting field trials.
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`7. More specifically, the largest part of my oilfield experience has come
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`in the area of perforating technology. I have worked extensively with Halliburton’s
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`Jet Research Center (JRC) over this time. This work has included heading several
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`failure investigations and leading a decade-long effort to better understand the
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`dynamic response of the perforating gun string, wellbore, and formation to the
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`detonation of shaped charges during perforating. I have developed modeling and
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`simulation tools to predict the dynamic response of these systems. I have designed,
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`qualified, and fabricated a perforation evaluation tool for measuring the dynamic
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`pressures, loads, accelerations, and temperature within the gun string, adjacent to
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`detonating explosives. I have also helped to design or redesign a number of firing
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`head systems for actuating tubing-conveyed guns.
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`8.
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`In the course of the above projects, I worked on-site at JRC with testing
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`perforating gun systems. I worked with explosives technicians in the gun-loading
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`shop and witnessed the loading of charges, detonating cord, and RED detonators in
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`preparation for live explosive tests. I am familiar with many of the safety procedures
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`used in the gun-loading environment, in the handling of the loaded guns, and the
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`firing of the guns. I have worked on instrumenting guns for collecting data from the
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`detonation, including direct measurements of the deformation of the gun carriers and
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`the internal pressure due to the blast. I have supported numerous field trials
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`including the providing of instrumentation and downhole tool prototypes,
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`performing the forensic examination of guns and gun system elements returned from
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`the field, and performing analysis on field data.
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`9.
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`I have developed finite element analysis (FEA) methods for simulating
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`the detonation of perforating gun detonation. The efforts have focused on
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`understanding the behavior of novel gun system geometries, identifying potential
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`failure modes for the gun carriers and other components of the system, evaluating
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`the damage caused to nearby loaded guns with select-fire detonations occur in
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`adjacent zones, evaluating shaped-charge interactions, and optimizing detonation
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`timing in independently-controlled firing systems to minimize shock loading.
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`10.
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`I am the sole and/or contributing author of over fifteen publications
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`relating to this field. A comprehensive list of publications is in my attached
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`curriculum vitae. I am a member of the Society of Petroleum Engineers (SPE) and
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`American Society of Mechanical Engineers (ASME).
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`11.
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`I have been named as an inventor on over thirty U.S. Patents. A
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`comprehensive list of my patents is contained in my attached C.V. A number of
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`these patents involve developments related to the perforating projects described
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`above.
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`12. Attached as Appendix A is a copy of my current C.V. further
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`elaborating on my professional background and qualifications.
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`III. Materials Considered
`13.
`In forming my opinions, I have reviewed the ʼ938 Patent and its
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`prosecution history. I have reviewed and considered the references cited by the
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`Petitioner, the Petition itself, the Declaration of Robert Parrott (Ex. 1007) submitted
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`with the Petition, and other documents and information as set forth in this
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`declaration. I have also been consulting with DynaEnergetics and its attorneys on
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`the creation of 3D computer-aided design (CAD) models to illustrate systems
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`described in certain of the references relied upon by the Petition in this proceeding.
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`I have described those models in this declaration and have included illustrations.
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`14.
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`In reaching my opinions, I have relied upon my experience in the field
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`and also considered the viewpoint of a person of ordinary skill in the art (“POSITA”)
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`at the time of the earliest claimed priority date of the ’938 Patent. As explained
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`below, I am familiar with the level of a person of ordinary skill in the art regarding
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`the technology at issue as of that time.
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`IV. Overview of the Technology
`15. The technology at issue relates to oil and gas wellbore perforating
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`equipment, specifically perforating guns and methods of assembly thereof.
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`Perforating guns are specialized assemblies that include explosives and are deployed
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`into oil and gas wells where the explosives are detonated to “perforate” hydrocarbon-
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`containing underground formations, for extracting fossil fuels and natural gas from
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`the underground formations.
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`16. More specifically, the perforating process involves carrying explosive
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`charges downhole (into the well) and positioning them at a desired depth in order to
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`open up communication to the rock and embedded hydrocarbons upon detonation of
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`the explosives. The shaped charges open up tunnels through the wellbore casing
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`lining the well and radially outward into the surrounding formation. The perforation
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`tunnels act as conduits through which reservoir fluids flow from the formation into
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`the wellbore and up to the surface during the production phase of the well. Each
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`perforation creates a channel that allows the oil and/or gas to leave the rock and enter
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`the oil or gas well. The same tunnels can be used during hydraulic fracturing and
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`stimulation processes to aid in freeing the hydrocarbons from the formation.
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`17. Perforating guns are the vessels used to transport and deliver the
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`explosive shaped charges within the wellbore and they come in a variety of sizes and
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`configurations. Operators may install a particular type of well equipment to
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`accommodate a perforation system that is suitable for a specific reservoir based on
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`its characteristics. Many factors are considered in the design and selection of the
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`gun system and other elements of the gun string—the assembly of tools threaded
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`end-to-end that make up the full system used to perforate the wellbore. The design
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`must factor in the objectives of maximizing communication with the surrounding
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`reservoir over a desired interval or length (i.e., the pay zone), the system and
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`operational costs, and safety and reliability. Safety is always the utmost concern for
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`all personnel handling these highly energetic materials.
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`18. Perforating guns are typically loaded with explosive shaped charges
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`and deployed into underground wellbores deep below the surface. Once in the proper
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`position, the charges are detonated, and the resulting explosions radiate outward
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`from the perforating gun assembly, pierce the wellbore casing, go through the
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`cement sheath, and perforate the surrounding formation, facilitating the flow of
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`hydrocarbons from the formation and into the wellbore:
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`19. Further detail of a single gun assembly is shown in the following figure.
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`A gun assembly is shown with a portion of the gun carrier cut away to expose the
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`explosive shaped charges within. The lower part of the figure further cuts through
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`the interior components. The primary elements are the shaped charges which are
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`supported in receptacles in a loading tube. The loading tube is typically made of
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`steel and the receptacles are machined into the loading tube. The detonating cord is
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`a thin rope-like material that runs from end to end of the gun assembly making
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`contact with the back side of each shaped charge along the way. The detonating cord
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`provides the ballistic transfer of the detonation so that the shaped charges detonate
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`in sequence from one end to the other. In conventional perforating guns like the one
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`shown in the figure below, the detonating cord extends through the perforation gun
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`and transfers ballistic energy to a detonating cord of an adjacent gun (not shown
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`below) through a tandem connector joining the guns.
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`20. Referring again to the figure above, the gun body or carrier is a pressure
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`housing, much like a pipe, that protects the explosives from the wellbore
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`environment and delivers them to the desired location in the wellbore for firing. The
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`carrier has a threaded, sealed tandem connector on each end to complete and seal the
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`assembly where one or more guns are to be stacked for perforating a longer interval
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`or length of the wellbore. As will be discussed further below, separate guns may be
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`detonated at different times or may be detonated in the same perforating event.
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`21.
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`In the conventional perforating gun design, the shaped charges are
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`positioned within a charge holder tube that sets the linear spacing and azimuthal
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`orientation (i.e., the angular position around the circumference), together referred to
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`as the shot phasing, to achieve a desired shot pattern. Different shot phasing patterns
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`are illustrated in the previous figure in paragraph 18 above for the three guns. Each
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`of the charge cases are mounted within the receptacles in the charge tube. The gun
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`carrier is typically fabricated with “scallops”—circular recesses on the outer surface
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`of the gun carrier that align precisely with the internal shaped charges. Upon
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`assembly, the orientation of shaped charges in the loading tube inside the gun carrier
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`must align with the scallop pattern machined into the carrier.
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`22.
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`In the figure below, a photo of the outside of a gun carrier is shown
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`after detonation of the shaped charges. The lighter-colored circles are the scallops
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`machined into the steel carrier, fabricated from a type of steel pipe. The dark circles
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`within each scallop are the exit holes left by the charge detonation. Around the edges
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`of the exit holes, the metal is pushed outward leaving sharp burrs of hard steel. The
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`purpose of the scallops is to recess those burrs so that they do not extend beyond the
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`outer diameter of the gun carrier. Without scallops, the burrs could drag along the
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`wall of the wellbore casing when the spent guns are removed from the wellbore,
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`degrading the casing integrity.
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`23. The shot phasing is a critical aspect of a gun design that is selected by
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`a completions engineer to optimize perforation performance and thus, the eventual
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`hydrocarbon production from the well. The phasing for a conventional gun is fixed
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`by the design and manufacture of the loading tube and carrier components. The
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`loading tube is designed to fit inside a particular carrier and to hold a specific charge.
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`Both are designed and built for a particular shot phasing pattern. As shown below,
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`three guns are illustrated in the string.
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`In the first and third of the guns, a 0-degree shot phasing is shown in which all shots
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`are oriented in the same direction and with a constant linear spacing (e.g., 13 shots
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`per meter). In the middle gun, the shot phasing is a spiral pattern with each
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`successive charge oriented 60 degrees from the last (e.g., 0°, 60°, 120°, …) and with
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`a constant linear spacing (e.g., 20 shots per meter).
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`24. A detonator is a critical component of a perforating gun that initiates
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`the ballistic chain of events resulting in detonation of the shaped charges. The
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`detonator, upon receiving an electric signal or current or a pressure increase
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`(depending upon the type of firing system) from the surface, starts the explosive
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`chain reaction which transfers along the detonating cord from the detonator to the
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`shaped charges via the detonating cord. As shown previously, each gun assembly
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`may have a separate length of detonating cord. Absent a separate ballistic or
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`explosive element, intimate contact is required to ensure detonation transfer from
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`detonator to detonating cord. Providing a confined space also helps to ensure a
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`reliable energetic coupling.
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`25. When perforating guns are conveyed into the wellbore using a wireline,
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`which is a cable that holds the weight of the string and also provides electrical
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`connectivity, then a wired connection can be made directly from the surface to the
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`detonator located within or near the guns. To detonate charges in a perforating gun,
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`equipment operators can relay an electrical signal or current from the surface via
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`electrical wires to one or more detonators within a string of perforating guns.
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`26. Selective perforating (or detonation) is the practice of firing a subset of
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`the perforating guns on a single string. With selective perforation, equipment
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`operators can perforate one zone or interval of a wellbore, move the perforating gun
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`string, and then perforate a second zone. This process provides efficiency gains and
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`cost savings to the operator during the well completion process. Selective or select-
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`fire systems also require more advanced technology to safely and efficiently send
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`the firing commands to the detonators in each subset of the gun string. Modern firing
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`systems use digital communication with each detonator having a unique digital
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`address. This enables commands to be safely and reliably sent to a single detonator
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`and for operating status and other information to be communicated back to surface.
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`This also eliminates the possibility of stray signals inadvertently causing a
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`detonation.
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`27.
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` In the development of oil fields, the design of each well completion
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`tends to be fairly unique as the nature of the Earth’s crust and the nature and
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`distribution of the hydrocarbons trapped within it tend to vary greatly from well to
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`well. This variation means that every perforating job is unique. Service companies
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`and perforating gun providers have developed gun systems in order to meet the wide
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`variety of specific needs for each wellbore encountered. Gun carriers are made in
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`different diameters and with differing pressure ratings. Shaped charges are designed
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`in a wide range of sizes and with differing penetration characteristics. For example,
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`some charges are designed to create a deep, narrow tunnel while others are designed
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`to create a shallow, wide tunnel. In conventional perforating guns, the charge
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`loading tubes and carriers are also built with a variety of different, fixed shot
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`patterns, i.e., charge phasing. In conventional gun systems, the loading tubes and
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`carriers are factory-built metal tubes that must be selected in advance and delivered
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`to the local shop location for each upcoming perforating job. The phasing is
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`important because it can be used to optimize the fractures that develop in the rock
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`from the perforating and subsequent fracking operations. Each gun that is to be used
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`must have the right combination of components to work as designed.
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`28. Once a gun system is selected, the next challenge is delivering the guns
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`to the wellsite and then down into the well for detonation. Historically, the
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`components have been delivered to a regional gun shop where the dangerous and
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`tedious job of gun loading is performed. Trained technicians must load the charges
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`and detonating cord into the loading tubes and insert them into the carriers. With
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`select-fire systems, the gun assembly process also includes a wiring aspect. As
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`shown below, the loading tube subassembly may be delivered to the loading shop.
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`29. As shown below, the loading tube, made of thin steel, has cut-outs sized
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`to hold a specific shaped charge design. The charges are inserted into the cut-outs
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`and locked in place. The detonating cord is then positioned across the back end of
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`each charge to ensure ballistic transfer will occur as the detonation progresses along
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`the length of the gun. Once all charges are loaded, the loading tube can be inserted
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`into the carrier.
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`Ex. 2005 at 40.
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`30. The entire loading process requires attention to safety protocols given
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`the energetic materials involved. The explosives require specialized handling,
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`storage, and transportation that must meet local regulations. If the assembly is not
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`done correctly, the gun may not fire properly, resulting in a misfire. For example,
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`the ballistic chain can be broken if the detonating cord is damaged at some point
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`along the loading tube. Once a gun is loaded, it is transferred to the wellbore site
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`without a detonator connected to other explosive components, to eliminate any risk
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`of an unplanned detonation of the detonating cord and/or shaped charges. As a result,
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`the gun assembly process must be continued at the well site, again requiring an array
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`of safety and regulatory requirements to be met.
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`31. Once at the well site, the critical step is connecting the detonator and
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`the electrical system to the loaded guns. To do this, a firing sub is used to house the
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`detonator and interface with the wireline that conveys the guns into the well and
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`provides electrical communication to the surface. For example, Petitioner’s Gun
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`Loading Manual (Ex. 2004) and User Manual (Ex. 2005) illustrate and describe
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`assembly and wiring procedure for conventional perforation gun systems. In the
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`figure below, the firing sub on the right is shown as it interfaces the gun.
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`Ex. 2004 at 15.
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`32. The electrical wires and the detonating cord from the gun must be
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`pulled into the firing sub and out through a port in the side wall called a port plug.
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`Next, the electrical connections are made to the detonator, followed by the ballistic
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`connection to the detonating cord as illustrated in the figure below. Traditional
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`detonators are prone to radio-frequency interference and static electricity that could
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`create stray voltages in the wiring of the gun system and in a worst case, cause a
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`detonator to fire unintentionally. As an extra safety precaution, the detonator is
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`temporarily housed in a section of pipe clamped to the side of the gun while electrical
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`connections are made. All radio communications are silenced during critical steps in
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`the operation and all wellsite operations are ceased until the armed guns are safely
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`located at least 200 feet deep in the wellbore. Ex. 2008 at 5. The safety pipe or
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`blasting cap chamber clamped to the gun is illustrated in the figure below.
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`Ex. 2004 at 23.
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`33. Wire connections are made up using electrician’s tools including wire
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`cutters, wire strippers, and crimp connectors, following the industry standard
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`Electrically Arming Before Ballistically Arming (“EBBA”) protocol. Connections
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`are made between the detonator (housed in the pipe), the switch, and the wires
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`running to the gun. The figures below illustrate the connections.
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`Ex. 2004 at 25.
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`Ex. 2005 at 43.
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`34.
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` Once the electrical connections have been tested, the detonator is
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`attached to the detonating cord, completing the ballistic system. The components are
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`pushed into the firing sub through the port plug opening. The port plug can then be
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`installed to seal the opening and finalize the assembly process as illustrated below.
`
`Ex. 2004 at 28.
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`
`
`35. The conventional process of assembling and arming wireline guns is
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`tedious, dangerous, and rife with opportunities for errors that can cause misfires.
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`Every electrical connection must be properly made and care must be taken to avoid
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`pinched wires or shorts to the steel of the firing sub and guns. This leaves many
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`opportunities for miswiring or other electrical integrity issues that can disable a gun
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`such that it will not fire when commanded. The two most common causes for
`
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`
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`DynaEnergetics Europe GmbH
`Ex. 2002
`Page 21 of 142
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`
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`misfires during wireline perforating operations have historically been wiring issues
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`PGR2020-00080
`U.S. Patent No. 10,472,938
`
`
`and leaking o-ring seals, such as on the port plug. Ex. 2008 at 6.
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`V. The ʼ938 Patent
`36. The ʼ938 Patent is generally directed to a perforating gun and methods
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`of assembly thereof in the oil and gas perforating industry. As explained above, key
`
`benefits of the invention claimed in the ʼ938 Patent include providing factory
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`assembled modular components and simplifying electrical assembly of perforation
`
`gun strings at a wellbore site to enhance reliability and safety. Representative Claim
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`1 of the ʼ938 Patent, which shares many of the same features as Claim 9, recites,
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`with reference to Figure 32 below:
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`1. A perforating gun, comprising:
`
`an outer gun carrier;
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`a charge holder positioned within the outer gun carrier and including at
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`least one shaped charge;
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`a detonator contained entirely within the outer gun carrier, the
`
`detonator including
`
`a detonator body containing detonator components,
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`a wireless signal-in connector, a wireless through wire connector,
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`and a wireless ground contact connector, and
`
`
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`DynaEnergetics Europe GmbH
`Ex. 2002
`Page 22 of 142
`
`
`
`PGR2020-00080
`U.S. Patent No. 10,472,938
`
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`an insulator electrically isolating the wireless signal-in connector from
`
`the wireless through wire connector; and,
`
`a bulkhead, wherein the bulkhead includes a contact pin in wireless
`
`electrical contact with the wireless signal-in connector, wherein
`
`at least a portion of the bulkhead is contained within a tandem seal
`
`adapter, and the wireless ground contact connector is in wireless electrical
`
`contact with the tandem seal adapter.
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`
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`
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`DynaEnergetics Europe GmbH
`Ex. 2002
`Page 23 of 142
`
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`PGR2020-00080
`U.S. Patent No. 10,472,938
`
`
`
`
`
`
`37. Representative Claim 13 of the ʼ938 Patent recites, with reference to
`
`the Figure 32 above and the Figure 18 below:
`
`13. A method for assembling a perforation gun system, comprising:
`
`(a) inserting a charge holder within a hollow interior of an outer gun
`
`carrier, wherein the charge holder includes a detonating cord connected
`
`to the charge holder and at least one shaped charge;
`
`(b) inserting a top connector into the outer gun carrier adjacent to the
`
`charge holder, the top connector comprising a hollow channel;
`
`
`
`
`
`
`DynaEnergetics Europe GmbH
`Ex. 2002
`Page 24 of 142
`
`
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`PGR2020-00080
`U.S. Patent No. 10,472,938
`
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`(c) inserting a detonator into the hollow channel of the top connector,
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`the detonator including
`
`a detonator body containing detonator components,
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`a wireless signal in connector, a wireless through wire
`
`connector, and a wireless ground contact connector, and
`
`an insulator electrically isolating the wireless signal in connector
`
`from the wireless through wire connector;
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`(d) connecting a through wire to the wireless through wire connector;
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`(e) energetically coupling the detonating cord to the detonator; and,
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`(f) transporting the perforation gun system to a wellbore site, wherein
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`at least one of steps (a), (b), and (d) is performed before transporting
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`the perforation gun system, and step (c) is performed at the wellbore
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`site.
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`DynaEnergetics Europe GmbH
`Ex. 2002
`Page 25 of 142
`
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`PGR2020-00080
`U.S. Patent No. 10,472,938
`
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`VI. Construction of Claim Terms
`38.
`I understand that claim terms in a post grant review should be accorded
`
`their ordinary and customary meaning as understood by one of ordinary skill in the
`
`art at the time of the invention in light of the patent specification and the prosecution
`
`history pertaining to the patent.
`
`39.
`
`I am aware and understand that the Petition sets forth proposed
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`constructions for a number of limitations of the challenged claims. I do not agree
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`that proposed constructions are necessary or appropriate for every term, except as
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`specifically addressed below.
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`DynaEnergetics Europe GmbH
`Ex. 2002
`Page 26 of 142
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`PGR2020-00080
`U.S. Patent No. 10,472,938
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`1.
` “tandem seal adapter”
`40. The term “tandem seal adapter” is not a common or accepted industry
`
`term. However, the term is well-defined and described in the claims and
`
`specification, and a POSITA would understand from the plain language of Claims 1
`
`and 9 that a tandem seal adapter (“TSA”) is a component that creates a seal between
`
`two gun housings and provides a channel to receive or accommodate a bulkhead.
`
`41. The ’938 Patent specification and figures support this understanding of
`
`a POSITA. For example, the ‘938 patent explains that “[t]he tandem seal adapter 48
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`is configured to seal the inner components within the carrier 12 from the outside
`
`environment, using sealing means 60 (shown herein as o-rings). Thus, the tandem
`
`seal adapter 48 seals the gun assemblies from each other.” Ex. 1001, 7:55-8:5. This
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`establishes that the TSA is a component that creates a seal between two gun
`
`housings. The seals are positioned to prevent fluid leakage from the wellbore
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`through the threaded connection between two adjacent carriers that could flood
`
`either gun.
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`42. The ʼ938 Patent further describes “the tandem seal adapter 48 . . . fully
`
`contains the bulkhead assembly 58” (Ex. 1001, 7:55-8:5), this “pin connector
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`assembly including the bulkhead 124 . . . is positioned within the tandem seal adapter
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`48,” (id., 8:28-39) and “pushing in a bulkhead (element 58 in FIG. 19) onto [sic –
`
`
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`
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`DynaEnergetics Europe GmbH
`Ex. 2002
`Page 27 of 142
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`
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`into] the tandem seal adapter” (id., 10:1-14). This establishes that the TSA provides
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`PGR2020-00080
`U.S. Patent No. 10,472,938
`
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`a channel or through hole to accommodate a bulkhead.
`
`43. The figures of the ʼ938 Patent further support a POSITA’s
`
`understanding that the TSA 48 provides a seal between adjacent gun housings
`
`through o-rings 60, and also provides a channel (outlined in green below) to receive
`
`a bulkhead 58, as illustrated by exemplary Figure 19 below:
`
`44. A POSITA would therefore understand that the term “tandem seal
`
`adapter” as used in the ’938 Patent means “a component that creates a seal between
`
`adjacent gun housings and provides a channel to receive a bulkhead.”
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`
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`DynaEnergetics Europe GmbH
`Ex. 2002
`Page 28 of 142
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`PGR2020-00080
`U.S. Patent No. 10,472,938
`
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`2.
`“bulkhead”
`45. The term “bulkhead,” on the other hand, is a common and accepted
`
`industry term, and it is generally understood to include a device that pressure isolates
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`adjacent guns and passes an electrical signal between the adjacent guns.
`
`46. The ’938 Patent, including the specification, figures, and Claims 1 and
`
`9 describe the bulkhead exactly as understood and used in the industry. So while a
`
`construction is not strictly necessary, because the term is used throughout the cited
`
`art in slightly different ways, it is important to specify that “bulkhead” means “a
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`component that seals adjacent guns (when positioned within the TSA) and provides
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`for electrically connecting adjacent guns.”
`
`47. For example, the ʼ938 Patent explains that “the tande
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