IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`DRIL-QUIP,INC.,
`Petitioner
`
`Vs
`
`FMC TECHNOLOGIES, INC.,
`Patent Owner
`
`Patent No. 10,689,921
`Filing Date: Feb. 5, 2019
`Issue Date: June 23, 2020
`
`Title: ONE-PIECE PRODUCTION/ANNULUS BORE STAB WITH INTEGRAL
`FLOW PATHS
`
`Post Grant Review No.: UNASSIGNED
`
`DECLARATION OF BRIAN CHRISTIE
`
`Dril-Quip, Exh. 1006, Page 1 of 14
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`DRIL-QUIP,INC.,
`Petitioner
`
`Vs
`
`FMC TECHNOLOGIES, INC.,
`Patent Owner
`
`Patent No. 10,689,921
`Filing Date: Feb. 5, 2019
`Issue Date: June 23, 2020
`
`Title: ONE-PIECE PRODUCTION/ANNULUS BORE STAB WITH INTEGRAL
`FLOW PATHS
`
`Post Grant Review No.: UNASSIGNED
`
`DECLARATION OF BRIAN CHRISTIE
`
`Dril-Quip, Exh. 1006, Page 1 of 14
`
`
`
`I, Brian Christie, declare as follows:
`
`I. BACKGROUND
`
`I, Brian Christie, hereby declare that the following is true and correct.
`
`I am overthe age of 18, competent to makethis declaration, and I am familiar with
`
`the facts below. I offer this declaration in support of Dril-Quip Inc. (“Dril-Quip”)’s
`
`Petition for Post Grant Review of U.S. Patent No. 10,689,921 (the “’921 Patent’).
`
`The statements madein this Declaration are based on my own personal
`
`knowledgeand experience.
`
`I have almost 40 years of experience in sales administration, with
`
`almost 33 of those years spent as a Sales Administration Managerat Dril-Quip.
`
`I
`
`am currently employed by Dril-Quip as a Sales Administration Manager.
`
`During my tenure as Sales Administration Managerat Dril-Quip,I have
`
`been and am responsibleforall sales quotations, sales orders, tenders, and othersales
`
`documentation of Dril-Quip’s subsea systems.
`
`It is a regular practice of Dril-Quip
`
`for the Sales Administration Manager to review and sign this sales documentation.
`
`Also during my time as Sales Administration Manager, it is and has
`
`been a regular practice of Dril-Quip to keep electronic archives of all sales
`
`documentation.
`
`I keep these documents in a folder on my computer.
`
`Dril-Quip, Exh. 1006, Page 2 of 14
`
`
`
`I was personally involved in the sale of Dril-Quip’s Subsea Tree
`
`Assembly to Mersk Olie OG Gas A.S. (“Maersk”). The Subsea Tree Assembly
`
`design includeda stab sub with integrated fluid flow paths.
`
`The sale to Maersk of this Subsea Tree Assembly for Maersk’s Regnar
`
`field development project (the “Regnar Project’) was Dril-Quip’s first subsea tree
`
`award and an important event in Dril-Quip’s company history. Since the Regnar
`
`Project, this Subsea Tree Assembly design including the stab sub with integrated
`
`fluid flow paths was used for multiple subsequent projects. For example, Dril-Quip
`
`has implemented this stab sub feature in projects for the following customers:
`
`Conoco (CMSIII, 2001-2002), GDF (Anglia, 2002-2003), Exxon Mobil (Arthur,
`
`2003-2004), AGR Peak (Durango, 2011-2012), Tullow (Wissey, 2011-2012), RWE
`
`(Topaz, 2013-2014), Melrose Resources (Kaliakra, 2012-2013), BWE (Tortue,
`
`2017-2018), and BSOG (Midia, 2019-2020). This list is by no means exhaustive; it
`
`is merely a sampling of projects in which the stab sub with integrated fluid flow
`
`paths was implemented.
`
`THE SUBSEA TREE ASSEMBLY WAS ON SALE NO LATER THAN
`FEBRUARY5, 2019
`
`Dril-Quip’s Subsea Tree Assembly was on sale and commercially
`
`available before February 5, 2019.
`
`At the request of Maersk, Dril-Quip began designing the Subsea Tree
`
`Dril-Quip, Exh. 1006, Page 3 of 14
`
`
`
`subsea well, Nils-3. Exhibit 1008 is a Specification for Mudline Suspension/Subsea
`
`Wellhead System, Tubing Hanger, Subsea Tree and Wellhead Protection frame
`
`Components for
`
`[Regnar] Field (“Specification”) dated February 1992 that
`
`Dril-Quip submitted to Maersk. Section 8.0 of the Specification is the specification
`
`for the Subsea Tree Assembly and Section 8.2 includes the specification for the stab
`
`sub componentof the Subsea Tree Assembly. This Specification was drafted near
`
`the time that the Subsea Tree Assembly was designed by Dril-Quipatthe requestof
`
`Maersk by someone with knowledgeof the information. This Specification is kept
`
`in the ordinary course of business at Dril-Quip and as a regularpractice.
`
`The Specification was drafted as a result of a General Service Contract
`
`2173 fully executed as of January 28, 1991, attached hereto as Exhibit 1009.
`
`I
`
`reviewed and executed the General Service Contract on January 21, 1991 on behalf
`
`of Dril-Quip. The General Service Contractis kept in the ordinary course of business
`
`at Dril-Quip and asa regular practice.
`
`THE DESIGN OF THE SUBSEA TREE ASSEMBLY WAS SOLD NO
`LATER THAN FEBRUARY5,2019
`
`11. Dril Quip’s Subsea Tree Assembly wassold before February 5, 2019.
`
`On July 20, 1992, Maersk placed an order to purchase a Subsea Tree
`
`Assembly from Dril-Quip. Exhibit 1011 is a Purchase Order dated July 20, 1992
`
`prepared by Maersk in accordance with the Specification and acknowledged by
`
`Dril-Quip (Exhibit 1008). A purchase order is a commitment to buy authorizing a
`
`Dril-Quip, Exh. 1006, Page 4 of 14
`
`
`
`seller to deliver goods with paymentto be madeata later date. This Purchase Order
`
`is consistent with and similar in format to other purchase orders Dril-Quip has
`
`received from Maersk and other customers. The terms and conditions of Maersk’s
`
`offer are included in the purchase order. The Purchase Orderlists Maersk’s facility
`
`in Esbjerg, Denmark as the shipping address and its office in Copenhagen asits
`
`billing address. It also lists the part descriptions, quantities, and prices, and specifies
`
`a delivery date for January 3, 1993. Dril-Quip has entered into countless purchase
`
`orders with Maersk.
`
`Inthe earlier years, these were standalone purchase orders such
`
`as with the Regnar Project, but ourrelationship later moved to long term (typically
`
`4 year) contracts for purchased goods, against which Maersk would issue purchase
`
`orders or call off orders. All information wasentered into the Purchase Order and
`
`signed by someone with knowledgeofthe information. This sales documentationis
`
`kept in the ordinary course of business at Dril-Quip and as a regularpractice.
`
`On December1, 1992, Dril-Quip issued a Sales Order. Exhibit 1012 is
`
`a Sales Order dated December 1, 1992 prepared by Dril-Quip in response to the
`
`Purchase Order (Exhibit 1011) placed by Maersk. Sales orders are documents
`
`prepared bytheseller and issued to the buyerfor the purposes ofconfirming thesale
`
`of the productsor services involvedin the particular transaction. It typically contains
`
`details about the sale, including the quantity, quality, and price of the purchased
`
`goodsor services. This Sales Orderis consistent with and similar in format to other
`
`Dril-Quip, Exh. 1006, Page 5 of 14
`
`
`
`sale orders prepared by Dril-Quip for Maersk and other customers.
`
`It includes
`
`equipmentcategories, part numbers,part descriptions, part quantities, pricing, and a
`
`delivery date. The pricing was redacted from the executed Sales Order in the
`
`ordinary course of business. Exhibit 1007 is a draft Sales Order thatI prepared at
`
`the time of the sale, which includes the pricing redacted from the executed Sales
`
`Order. Dril-Quip has issued countless sales orders to Maersk. As with the purchase
`
`orders, Dril-Quip initially issued standalone sales orders such as with the Regnar
`
`Project butlater on issued sales orders against long term contracts. This Sales Order
`
`showsthat the Subsea Tree Assembly had a “Tubing Hanger Stab Sub — 4-1/16’
`
`5,000 PSI W.P. with Integral Annulus, D.H.S.V. and Pressure Monitoring Ports.”
`
`Exhibit 1012.
`
`I reviewed and executed the Sales Order on behalf of Dril-Quip. The
`
`Sales Order is keptin the ordinary course of business at Dril-Quip and as a regular
`
`The components ofthe Subsea Tree Assembly including the Stab Sub
`
`had already been built by the date of the Sales Order. They were built at least on or
`
`before December 1, 1992, when they were shipped from Dril-Quip’s plant in
`
`Houston, Texas to Dril-Quip’s Facilities in Aberdeen, Scotland. Exhibit 1013 is a
`
`Packing List showing the components of the Subsea Tree Assembly that were
`
`shipped from Houston, Texas to Aberdeen, Scotland. A packinglist is a detailed
`
`statement prepared bya seller that accompaniesdelivered sold goodsor services, so
`
`Dril-Quip, Exh. 1006, Page 6 of 14
`
`
`
`that the recipient can verify the contents of the sold good orservice. Packinglists
`
`typically include a description, quantity, and weight of the sold goods and services
`
`received. It is a regular businesspractice of Dril-Quip to issue packinglists with its
`
`shipped goods and services. This Packing List is consistent with and similar in
`
`format to other packing lists prepared by Dril-Quip for Maersk and other customers.
`
`This Packing List showsthat the Subsea Tree Assembly had a “Tubing Hanger Stab
`
`Sub — 4-1/16’ 5,000 PSI W.P. with Integral Annulus, D.H.S.V. and Pressure
`
`Monitoring Ports.”” Exhibit 1013.
`
`Following an inspection of the Subsea Tree Assembly Components, a
`
`repair was madeto the Subsea Tree Assembly. Exhibit 1010 is a Repair Letter dated
`
`March 11, 1993 from Dril-Quip to Maersk to inform Maersk of the repair to the
`
`valve block of Part Number 2-899976 for the Regnar Project. The Repair Letter
`
`explains that a repair was madeto plug a mis-located 0.188 Dia. Hole for the pressure
`
`monitor line. Exhibit 1010.
`
`Followingthesale and repair, Dril Quip’s Subsea Tree Assembly was
`
`delivered to the purchaser in 1993 andinstalled thereafter, well before February 5,
`
`2019. The delivery and installation ofthis Subsea Tree Assembly was a major event
`
`in Dril-Quip history, because it was one of Dril-Quip’s first subsea tree awards.
`
`Presently, the Regnar Project well including the Subsea Tree Assembly has produced
`
`for over twenty years.
`
`Dril-Quip, Exh. 1006, Page 7 of 14
`
`
`
`The sales and repair records shown in Exhibits 1007-1013 were
`
`obtained from Dril-Quip’s sales databases. These databasesare kept in the ordinary
`course of business at Dril-Quip andas a regular practice. Information was entered
`
`into the databasenearthetimethatthe sales activity reflected in the documents by—
`or from information transmitted by—someone with knowledge of the information.
`
`Keeping these recordsis a regular practice of Dril-Quip.
`
`THE DESIGN OF THE SUBSEA TREE ASSEMBLY SOLD JULY 20,
`1992
`
`The Subsea Tree Assembly that was built and sold before February 5,
`2019, including the design identified in Exhibits 1007-1013, was built according to
`multiple Computer Aided Design (“CAD”) machine drawings prepared by
`Dril-Quip as part of the sale to Maersk. A description of a sampling of these
`
`drawingsis includedin further detail below.
`
`Exhibit 1014 is a CAD drawingofPart No. 2-800004, portions of which
`
`are reproducedbelow:
`
`Dril-Quip, Exh. 1006, Page 8 of 14
`
`
`
`9182". —
`me -
`
`mes - i
`WY)
`tspay
`Mus LEVae vansa
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`ait oa7 AAWWoeTy|Seo ae
`| ieTRUae=a
`
`ss
`
`
`' ie, ‘aeecceaaay }|feeAATTTTITTa\ ft, oe
`
`
`v=sitet \.
`| =v
`3
`
`
`
`vise.5,000 PSI STUDDED GUTLET
`[— waex-S5 CRA
`1-13/16"-10,000 PSI STUDCED OUTLET
`wee,SS cha
`W/SK-Bt CRA
`eanone Pt sTucceD OUTLET|
`ma
`
`i
`
`Gi
`
`ake
`
`=
`
`
`
`
`
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`LE,
`
`Z
`
`ag
`
`AS!
`500.
`WV
`4-V'5'
`2-3/8" = on
`El
`
`2-1/16"-5.000 PSI STuODED OUTLET—
`W/EX-152 CRA
`
`
`
`
`
`Exhibit 1015 isa CAD drawing ofPart No. 2-800007, portions of which
`
`are reproduced below:
`
`Dril-Quip, Exh. 1006, Page 9 of 14
`
`
`
`IfTTa
`
`=
`
`LI ;
`
`Febetes
`
`
`
`82
`
`‘SSSV onto PORT
`7SSS¥ PORT
`‘SSSV MONITOR my
`— SSSV PORT
`erae
`~ LOW STRESS sTay:
`
`
`
`Pan 2-800007-02-8EV.AN,
`
`
`
`
`
`
`
`
`
`ef ey
`:
`*
`
`ANNULUS CLOSE PORT
`a
`=
`SUBSEA COMPOSITE TREE
`
`7
`
`*
`
`*
`
`_
`
`— ANNULUS: {LOSE PORT
`eas rene Poa
`
`SUBSEA COMPOSITE TREE
`
`SECTION "A-A‘
`
`Exhibit 1016 isa CAD drawing ofPart No. 2-899966,portions of which
`are reproduced below:
`
`
`To INTERSECT ‘wIiH
`yo 38? CORLL KATP
`VERTICAL HOLE
`
`
`A
`
`
`187 CHA, GRILL Xt oP
`VERTICAL HOLE
`TO NTERSECT WITH
`\ |
`
`
`PLLA
`
`
`
`
`
`167 OW. CALL X 44 OF,
`TC NTERSECT wITH
`f
`-
` © Low STRESS STAM: Te. 9 PLCS.
`
`
`
`
`VERTICAL HOLE
`
`287 Ola. OPEL x 4e OF. —/
`To NTERSECT win
`ORL-GUP %
`VERTCAL HOLE
`
`
`
`Exhibit 1018 is a CAD drawing of Part No. 2-899965, reproduced
`
`Dril-Quip, Exh. 1006, Page 10 of 14
`
`
`
`LOW STRESS STAM,
`z
`Onloue
`PIN 2-399965-REV.—
`
`
`
` SECTION ‘A-A*
`
`
`
`
`: [LEE
`CPLYLETPLLLLfe
`
`Exhibit 1019 is a CAD drawing ofPart No. 4-SD-60077, reproduced
`
`Dril-Quip, Exh. 1006, Page 11 of 14
`
`
`
`-eaThUMW[iLis
`aafsFees
`
` Pare errrSeeeoaareas.eseeeemeaepbaPee/aSSSSSHHRESH
`orLERCK
`pssst
`
`a?v
`oORw
`RRSueo
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`00%,
`
`
`
`AV TUBING
`PIN 2-300935-02
`
`=a
`
`12 3/8" SEAL
`ASSEMELY
`PAN a0on1sog
`
`Lhe
`
`
`
`
`
`
`
`ING JOINT
`36" LAND
`PAN 2-300224-02
`
`TREE CaP
`FI 2-B00016-02
`
`=moy
`WELLHEAD
`PIN 2-300225-07
`
`I
`
`5 Se" CASNG
`——- HANGER
`
`WELLHEAD PROTECTRN
`STRICTURE CENTRE ARG
`Pen 4
`
`eee.
`
`i?
`
`hes
`
`_ These CAD drawings, among others, were inspected andcertified by
`Det norske Veritas (DnV), an independent global certification body based out of
`
`Dril-Quip, Exh. 1006, Page 12 of 14
`
`
`
`
`
`
`Oslo, Norway. See DNV GL, https://www.dnvgl.com/ (last visited December Li,
`2020). Exhibit 1017 is a report released on April 13, 1993 by DnV verifying that
`the design of the Subsea Tree Assembly including the CAD drawings of Part Nos.
`2-800004, 2-800007, 2899966, and 2-899965 were reviewed and found in
`
`compliance with Danish Offshore Regulations before Dril-Quip delivered the
`Subsea Tree Assembly to Maersk. These drawings were drafted by Dril-Quip
`engineers near the time that the Subsea Tree Assembly was designed by Dril-Quip
`at the request of Maersk by someone with knowledge of the information.
`
`The CAD drawings and certifications shown in Exhibits 1014-1019
`
`were obtained from Dril-Quip’s sales databases. These databases are kept in the
`ordinary courseof businessat Dril-Quip andas a regularpractice. Information was
`
`entered into the database near the timeofthe sales activity reflected in the documents
`from information transmitted by—someone with knowledge of the
`information.
`
`It is my understandingthatall of these sales and repair records, CAD
`drawings, and certifications were provided to Dr. Brun Hilbert for inspection.
`
`Vv. CONCLUSION
`
`All of the statements madein this declaration of my own knowledge
`are true. All statements made based on information and belief are believed to be
`
`true. Further, these statements are made with the knowledge that willful false
`
`Dril-Quip, Exh. 1006, Page 13 of 14
`
`
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under § 1001 of Title 18 of the United States Code.
`
`Executed on January 29" 2021
`
`Brian Christie
`
`Dril-Quip, Exh. 1006, Page 14 of 14
`
`
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