PTAB

IPR2018-01308

Tesco Offshore Services, Inc. v. Weatherford Technology Holdings, LLC

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1. Case Identification

2. Patent Overview

  • Title: Method and Device to Clamp Control Lines to Tubulars
  • Brief Description: The ’637 patent discloses a control line positioning apparatus for use on offshore oil and gas drilling rigs. The apparatus is designed to move a control line toward a tubular pipe string so it can be clamped, and then move it away, facilitating the process of running control lines and tubulars from the rig floor to the ocean floor.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1–3, 14–18, 25–28, and 34–37 under §102

  • Prior Art Relied Upon: Webre (Patent 6,920,931).
  • Core Argument:
    • Prior Art Mapping: Petitioner argued that Webre discloses every element of the challenged claims. Webre’s “Control Line Guide” was asserted to be indistinguishable from the ’637 patent’s claimed apparatus. It allegedly teaches a control line holding assembly movable between a staging position (away from the tubular) and a clamping position (against the tubular), a mounting assembly for connecting the apparatus to the rig structure adjacent to the rig floor, a motive member (hydraulic cylinder) to effect movement, and an arm connecting the holding assembly to the mounting assembly. Petitioner contended that Webre’s figures and description demonstrate a nearly identical configuration and operation to the preferred embodiment of the ’637 patent.
    • Key Aspects: The core of this ground was a direct, element-for-element mapping, supported by annotated figures comparing Webre’s device to the illustrations in the ’637 patent, to show that Webre was an "unquestionable anticipatory reference."

Ground 2: Anticipation of Claims 1–3 and 14–18 under §102

  • Prior Art Relied Upon: Sonnier (Patent 6,131,664).
  • Core Argument:
    • Prior Art Mapping: As an alternative to Webre, Petitioner asserted that Sonnier also anticipates the key apparatus claims. Sonnier was described as disclosing a system for installing control lines on a well, featuring roller guides (the control line holding assembly) powered by hydraulically operated piston-cylinders (the motive member). This assembly is mounted on the rig floor and moves a control line from a lateral position into an axial position against a pipe string. Petitioner argued Sonnier’s disclosure of pillars supporting the guides meets the "arm" limitation and that its operation inherently includes moving between staging and clamping positions as claimed.

Ground 3: Obviousness of Claims 34–37 over Webre in view of McArthur

  • Prior Art Relied Upon: Webre (Patent 6,920,931) and McArthur (Patent 5,062,756).

  • Core Argument:

    • Prior Art Mapping: Petitioner asserted that Webre discloses most elements of method claims 34-37, which relate to a remotely controllable head. To the extent Webre was found not to explicitly teach the “memorizing the position of the head” and remote-control features of claim 34, Petitioner argued McArthur supplied these missing elements. McArthur was described as teaching a remotely controlled pipe handling system that uses a feedback circuit to "memorize and repeat" alignment positions for successively handling pipe sections.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the references to improve the efficiency and safety of Webre’s system. Petitioner argued that since both Webre and McArthur teach automated, hydraulically-powered equipment for handling components on a rig floor, a POSITA would have been motivated to incorporate McArthur's well-known "memorize and repeat" automation into Webre’s control line guide to create a fully automated, repeatable process.
    • Expectation of Success: Success would have been predictable because implementing McArthur's automation feature into Webre's apparatus was merely the application of a known automation technique to a similar system to achieve a predictable improvement in performance. The underlying technologies were compatible and their integration was presented as a straightforward task for a POSITA.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Webre or Sonnier with Haugen (Patent 6,742,596) to add teachings of an automated, interlocked control system, and with Krasnov (Patent 4,791,997) to add specific teachings on mounting handling equipment to the rig floor via locking pins.

4. Key Claim Construction Positions

  • "mounting assembly" / "operatively mounted" (claims 1–3, 14–18, 25–28): Petitioner proposed this be construed as "an assembly that connects the control line holding assembly to the rig and which is located near the rig floor." Petitioner argued against a narrower construction requiring the assembly to be "fixed" to the rig floor, contending this would improperly import a limitation from the specification and render dependent claim 3 (which explicitly requires being "connected to the rig floor") redundant.
  • "arm" (claims 1–3, 14–18, 25–28, 34–37): Petitioner proposed this term be construed broadly as "any structure or structures that connect the control line holding assembly to the mounting assembly." This construction was argued to be consistent with the claim language and the various embodiments shown in the ’637 patent.
  • "memorizing the position of the head" (claims 34–37): Petitioner proposed this be construed as "remembering where the head should go, such as when the head is repeatedly moved toward and away from the drill string." This construction was central to the obviousness argument combining Webre with McArthur.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1–3, 14–18, 25–28, and 34–37 of the ’637 patent as unpatentable.