Impulse Downhole Solutions Ltd. v. Downhole Well Solutions, LLC

CourtDistrict Court, S.D. Texas
DecidedDecember 23, 2024
Docket4:23-cv-02954
StatusUnknown

This text of Impulse Downhole Solutions Ltd. v. Downhole Well Solutions, LLC (Impulse Downhole Solutions Ltd. v. Downhole Well Solutions, LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Impulse Downhole Solutions Ltd. v. Downhole Well Solutions, LLC, (S.D. Tex. 2024).

Opinion

UNITED STATES DISTRICT COURT December 23, 2024 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION

IMPULSE DOWNHOLE SOLUTIONS § LTD., et al., § § Plaintiffs, § § VS. § CIVIL ACTION NO. 4:23-CV-2954 § DOWNHOLE WELL SOLUTIONS, LLC, § § Defendant. §

MEMORANDUM & ORDER Before the Court are the claim construction briefs filed by parties in this patent infringement suit. On November 26, 2024, the Court held a hearing, in accordance with Markman v. Westview Instruments, Inc., 517 U.S. 370 (1996), during which the parties presented argument in support of their proposed constructions. After considering the arguments of counsel, the evidence, and the applicable law, the Court finds that the disputed claims of the patents-in-suit should be construed as set forth herein. I. BACKGROUND

Plaintiff Impulse Downhole Solutions LTD (“Impulse”) brought this case alleging infringement of U.S. Patent Nos. 9,637,976 (“the ’976 Patent”), 9,765,584 (“the ’584 Patent”), 10,633,920 (“the ’920 Patent”), 10,648,265 (“the ’265 Patent”), and 11,268,337 (“the ’337 Patent”) against Defendant Downhole Well Solutions, LLC (“DWS”). The asserted patents relate to friction reduction tools used in directional oil drilling. There are two types of oil drilling: vertical drilling and directional drilling. In vertical drilling, the drill string extends downward, perpendicular to the earth’s surface, until it reaches the oil deposit. 1 However, when an oil rig cannot be positioned directly over an oil deposit, directional drilling is necessary. In directional drilling, the drill string extends both vertically and horizontally to reach the oil deposit. One challenge with directional drilling is that it can cause friction between the drilling string and the interior of the wellbore as the drilling string moves horizontally. This friction can

slow or stymie drilling progress. Friction can be mitigated by vibrating the drill string. Tools that produce this mitigating vibration are called friction reduction tools. Friction reduction tools produce vibrational pulses by varying the pressure of the drilling fluid running through the drill string. However, vibrating the string with rhythmic pressure patterns can interfere with other equipment, such as measurement and logging sensors that are also part of the drill string. As a result, irregular or polyrhythmic vibrations are desirable. Patents ’976 and ’584 describe friction reduction tools that create irregular or polyrhythmic pressure patterns to achieve the desired vibrations. This is done through two related mechanical processes that affect the flow of the drilling fluid: (1) the interaction between the rotor and stator

and (2) the interaction between the flow head and flow restrictor. The remaining three patents, the ’920, ’265, and ’337 Patents, all claim priority to the same provisional application. Additionally, the ’337 Patent is a continuation of the ’265 Patent. This family of patents allows for selective activation of friction reduction tools once the tools are downhole. The selective activation described in the ’920, ’265, and ’337 Patents is triggered by dropping a ball or other projectile into the drill string from the surface. The projectile comes to rest on a ball catch seat. The projectile stops the fluid from flowing through the central passage of the tool, directing fluid around the ball catch. This altered fluid flow, in turn, triggers the friction reduction tool.

2 II. APPLICABLE LAW A. Claim Construction Claim construction is a matter of law, and the task of determining the proper construction of disputed terms therefore lies with the Court. Markman v. Westview Instruments, Inc., 517 U.S. 370, 384 (1996). The goal of a Markman hearing is to arrive at the ordinary and customary meaning

of claim terms in the eyes of a person of ordinary skill in the art (“POSITA”). Phillips v. AWH Corp., 415 F.3d 1303, 1313 (Fed. Cir. 2005). There are only two exceptions to the ordinary meaning rule: “1) when a patentee sets out a definition and acts as his own lexicographer, or 2) when the patentee disavows the full scope of a claim term either in the specification or during prosecution.” Thorner v. Sony Computer Ent. Am. LLC, 669 F.3d 1362, 1365 (Fed. Cir. 2012). a. Readily Apparent Meaning In some instances, this inquiry is quite straightforward. That is, where ordinary meaning is “readily apparent even to lay judges,” district courts merely apply “the widely accepted meaning” of the terms, perhaps with the aid of “general purpose dictionaries.” Phillips, 415 F.3d at 1313;

see also Mentor H/S, Inc. v. Med. Device Alliance, Inc., 244 F.3d 1365, 1380 (Fed. Cir. 2001) (finding no error in the lower court’s refusal to construe “irrigating” and “frictional heat”); Biotec Biologische Naturverpackungen GmbH & Co. KG v. Biocorp, Inc., 249 F.3d 1341, 1349 (Fed. Cir. 2001) (finding no error in non-construction of “melting”). Indeed, “[a] district court is not obligated to construe terms with ordinary meanings, lest trial courts be inundated with requests to parse the meaning of every word in the asserted claims.” Shell Glob. Sols. (US) Inc. v. RMS Eng’g, Inc., 782 F. Supp. 2d 317, 334 (S.D. Tex. 2011) (Ellison, J.). b. Intrinsic Evidence

3 In most cases, though, claim terms have a particular meaning that may not be readily apparent. See Phillips, 415 F.3d at 1341. In such a scenario, courts look first to intrinsic evidence and assess whether such evidence clearly and unambiguously defines the disputed terms. Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576, 1585 (Fed. Cir. 1996). “Such intrinsic evidence is the most significant source of the legally operative meaning of disputed claim language.” Id. at 1582;

Personalized Media Commc’ns, LLC v. Apple Inc., 952 F.3d 1336, 1340 (Fed. Cir. 2020) (“When construing claim terms, we first look to, and primarily rely on, the intrinsic evidence . . . which is usually dispositive.” (quoting Sunovion Pharms., Inc. v. Teva Pharms. USA, Inc., 731 F.3d 1271, 1276 (Fed. Cir. 2013))). Intrinsic evidence includes the claims themselves, the specification, and the prosecution history. Phillips, 415 F.3d at 1314. i. Claim Language An examination of the intrinsic evidence begins with the claim language. Immunex Corp. v. Sanofi-Aventis U.S. LLC, 977 F.3d 1212, 1218 (Fed. Cir. 2020). The claims themselves can provide substantial guidance as to the meaning of terms. Phillips, 415 F.3d at 1314. The context

in which a term is used in the asserted claim can be instructive, and “other claims of the patent in question, both asserted and unasserted, can also be valuable sources of enlightenment as to the meaning of a claim term.” Id. Claim terms are most often used consistently throughout a patent, and so the usage of a term in one claim can often illuminate the meaning of the same term in other claims. Id. ii. Specification Claims, however, do not stand alone and “must be read in view of the specification, of which they are a part.” Markman v.

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