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
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.
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.
Weatherford International LLC owns exclusive rights to the ʼ333 patent.
Weatherford manufactures and sells centralizers covered by the claims of the
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.
the ʼ333 Patent
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.