Transocean Offshore Deepwater Drilling, Inc. v. Maersk Drilling Usa, Inc.

699 F.3d 1340 (2012)

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Nature of the Case

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Facts

Conventional drilling rigs use a derrick with a single drawworks and thus can only raise or lower one component at a time. P sought to improve the efficiency of this time-consuming process using the 'dual-activity' drilling apparatus disclosed in the patents-in-suit. The patents recite a derrick with both a main and an auxiliary advancing station, each of which can separately assemble drill strings and lower components to the seafloor. Each advancing station has a drawworks for raising and lowering the drill string and a top drive for rotating the drill string. While the auxiliary advancing station drills and cases the first portion of the borehole, the main advancing station lowers the blowout preventer. The auxiliary advancing station then retracts the drill string and supports the main advancing station by preparing lengths of drill string in advance. P's patents disclose a pipe handling system, also called a transfer assembly, which allows the transfer of casing, drill string, and other components between the two advancing stations and from the advancing stations to storage areas. Transocean asserted the '781 patent, the '851 patent, and the '069 patent against D. In Transocean I, the district court granted D's motion for summary judgment of obviousness, concluding that the asserted claims would have been obvious over the combination of two prior art references: U.K. patent application Horn and U.S. Patent Lund. The court also granted D's motion for summary judgment that the asserted claims were not enabled because the specification does not adequately describe the claim limitations relating to the pipe transfer assembly. On appeal, the district court was reversed. A jury found that D failed to prove that the asserted claims would have been obvious or that they were not enabled. It made findings that the prior art failed to disclose every element of the asserted claims and that each of seven objective factors indicated nonobviousness. The jury awarded $15 million in compensatory damages. The district court granted D's motions for judgment as a matter of law (JMOL) that the asserted claims are invalid as obvious and not enabled, that Maersk did not infringe, and that P is not entitled to damages. The court granted D's motion for a new trial under Rule 59. P appealed.