NOV Downhole Eurasia et. al. v. Drilformance

7/31/2019 NOV Downhole Eurasia et. al. v. Drilformance

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UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXASTYLER DIVISION

(1) NOV Downhole Eurasia Limited, and

(2) National Oilwell DHT, L.P.

Plaintiffs,

(1) DRILFORMANCE LLC.,

Defendant.

Civil Action No. 12-355

JURY DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT

TO THE HONORABLE JUDGE OF SAID COURT:

Plaintiffs, NOV Downhole Eurasia Limited and National Oilwell DHT, L.P.

(collectively “NOV” or “Plaintiffs”) for their Complaint against Defendant Drilformance LLC

(“Drilformance” or “Defendant”) allege as follows:

THE PARTIES

1. Plaintiff NOV Downhole Eurasia Limited (“NOV UK”) is a United Kingdom

company having its principal place of business in Stonehouse, Gloucestershire, England and it is

the successor-in-interest to the assets of ReedHycalog UK, another United Kingdom corporation

with its principal place of business in Stonehouse, Gloucestershire, England.

2. Plaintiff National Oilwell DHT, L.P. a Delaware limited partnership with its

principal place of business in Houston, Texas and the successor-in-interest to the assets of

ReedHycalog, L.P. (“NOV DHT LP”), another Delaware limited partnership with its principal

place of business in Houston, Texas. NOV UK and NOV DHT LP will be collectively referred

to as “NOV” or “Plaintiffs.”

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