Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
0Activity
0 of .
Results for:
No results containing your search query
P. 1
Weatherford International et. al. v. Blackhawk Specialty Tools

Weatherford International et. al. v. Blackhawk Specialty Tools

Ratings: (0)|Views: 91|Likes:
Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 4:14-cv-00455: Weatherford International, LLC et. al. v. Blackhawk Specialty Tools, LLC. Filed in U.S. District Court for the Southern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l9Yd for more info.
Official Complaint for Patent Infringement in Civil Action No. 4:14-cv-00455: Weatherford International, LLC et. al. v. Blackhawk Specialty Tools, LLC. Filed in U.S. District Court for the Southern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l9Yd for more info.

More info:

Published by: PriorSmart on Feb 24, 2014
Copyright:Public Domain

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

02/24/2014

pdf

text

original

 
57555569.1
 
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION
WEATHERFORD INTERNATIONAL, LLC and WEATHERFORD/LAMB, INC., Plaintiff, v. BLACKHAWK SPECIALTY TOOLS, LLC, Defendant. § § § § § § § § § § § § Civil Action No. 4:14-cv-00455 JURY TRIAL DEMANDED
ORIGINAL COMPLAINT
Weatherford International, LLC and Weatherford/Lamb, Inc. (collectively, “Weatherford”), for its original complaint of patent infringement against Blackhawk Specialty Tools, LLC, allege as follows:
THE PARTIES
1.
 
Plaintiff Weatherford International, LLC is a Delaware corporation with its  principal place of business in Houston, Texas. 2.
 
Plaintiff Weatherford/Lamb, Inc. is a Delaware corporation with its principal  place of business in Houston, Texas.
 
3.
 
Defendant Blackhawk is a Texas limited liability company having its principal  place of business in Houston, Texas.
JURISDICTION & VENUE
4.
 
This action arises under the patent statutes of the United States, 35 U.S.C. § 271
et seq.
 Accordingly, the Court has federal question jurisdiction over this matter under 28 U.S.C. §§ 1331 and 1338(a).
 
 
57555569.1
 2 5.
 
This Court has specific and general jurisdiction over Blackhawk. 6.
 
Venue is proper in this district under 28 U.S.C. §§ 1391(b) and (c) and 1400(b).
FACTS AND BACKGROUND
Weatherford’s ʼ333 Patent for a Centralizer
 
7.
 
Weatherford is one of the largest oil and gas service providers with a presence in every major oil and gas region in the world. Weatherford specializes in formation evaluation, drilling, well construction, completion, and production. 8.
 
Weatherford developed and patented an improved centralizer designed to keep casing centralized in a well while cement slurry is pumped between the casing and wellbore during drilling operations.
 
9.
 
The patent office issued United States Patent No. 5,575,333 (the ʼ333 patent) on  November 19, 1996 for the invention. The patent office reexamined the ʼ333 patent and issued a
reexamination certificate on November 27, 2007. A
copy of the ʼ333 patent and reexamination
certificate are attached as Exhibit A. 10.
 
Weatherford/Lamb, Inc. owns the ʼ333 patent by assignment.
11.
 
Weatherford International LLC owns exclusive rights to the ʼ333 patent.
12.
 
Weatherford manufactures and sells centralizers covered by the claims of the
ʼ333
 patent under the name Bow Spring Centralizer Sub. These centralizers have been successful in the market since its introduction in 1995, especially for casing strings with ultratight clearance.
 
Blackhawk Infringes
the ʼ333 Patent
 
13.
 
Blackhawk is an oil and gas services provider focused on cementing and well construction. Blackhawk manufactures and markets centralizers that, on information and belief,
are covered by claims of the ʼ333 patent.
 
 
 
57555569.1
 3 14.
 
Blackhawk is managed by a former Weatherford employee who has knowledge of
the ʼ333 patent because he one of the named inventors of the patent and was actively involved in
the procurement and enforcement of the patent. 15.
 
On information and belief, Blackhawk first manufactured the infringing centralizers at least as early as November 2012 and markets the centralizer for use in the offshore market. 16.
 
Weatherford notified Blackhawk of its infringing activities by letter dated April 17, 2013.
Count 1: Patent Infringement
17.
 
Weatherford adopts and incorporates by reference the allegations set forth in  paragraphs 1–16. 18.
 
On information and belief, Blackhawk infringes claims of the ʼ333 patent by
making, using, selling, and offering to sell centralizers for use in drilling operations. 19.
 
On information and belief, Blackhawk was actually aware of the ʼ333 patent and
willfully committed acts of infringement, entitling Weatherford to increased damages under 35 U.S.C. § 284 and to attorneys’ fees and costs incurred in prosecuting this action under 35 U.S.C. § 285. 20.
 
On information and belief, Blackhawk will continue to infringe the claims in the
ʼ333
 patent unless enjoined by this Court. 21.
 
Weatherford has been and will continue to be irreparably harmed by Blackhawk’s infringing acts, requiring the entry of a permanent injunction to prevent Blackhawk’s further
infringement of the ʼ333 patent because Weatherford does not have another adequate remedy at
law.

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->