UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION National Oilwell Varco, L.P.

, Plaintiff, Civil Action No. 11-3307 v. T3 Energy Services, Inc., JURY DEMANDED Defendant.

COMPLAINT FOR PATENT INFRINGEMENT

TO THE HONORABLE JUDGE OF SAID COURT: Plaintiff, National Oilwell Varco, L.P. (Plaintiff or NOV) for its Complaint against Defendant T3 Energy Services, Inc. (Defendant or T3) alleges as follows: THE PARTIES 1. Plaintiff NOV is a Delaware limited partnership with its principal place of

business in Houston, Texas. NOV is one of the worlds leading manufacturers of blowout preventers that are used when drilling and operating oil and gas wells. 2. Defendant T3 is a Delaware corporation with its principal place of business in

Houston, Texas. T3 also manufactures blowout preventers and competes with NOV, and other entities, in the blowout preventer market. T3s registered agent for service of process is Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808. JURISDICTION 3. This Court has subject matter jurisdiction pursuant to 28 U.S.C. . 1331 and

1338(a) because this action arises under the patent laws of the United States, Title 35, United

States Code, including 35 U.S.C. 271 et seq. The Court has personal jurisdiction over the Defendant in that the Defendant has established minimum contacts with the forum. Upon information and belief, Defendant has manufactured, leased, used, sold and/or offered for sale infringing blowout preventers in Texas, including in this judicial district. The exercise of jurisdiction over the Defendant would not offend traditional notions of fair play and substantial justice. VENUE 4. Venue is proper in this district pursuant to 28 U.S.C. 1331, 1338(a), 1391(b),

(c) and (d) and 1400(b). INFRINGEMENT OF U.S. PATENT NO. 7,814,979 5. On October 19, 2010, United States Patent No. 7,814,979 entitled Blowout

Preventers and Methods of Use (the 979 patent) was duly and legally issued to inventors Frank Springett and James Brugman All rights and interest in the 979 patent have been

assigned to the Plaintiff. A true and correct copy of the 979 patent is attached hereto as Exhibit A. 6. Upon information and belief, Defendant has infringed and continues to infringe

the 979 patent. The infringing acts of Defendant include at least the manufacture, use, sale, and/or offer for sale of infringing blowout preventers, such as the blowout preventers marketed by Defendant that include the what T3 refers to as SAR blades. Defendant is liable for infringement of the 979 patent pursuant to 35 U.S.C. 271. 7. Defendants acts of infringement have caused damage to Plaintiff, and Plaintiff is

entitled to recover from Defendant the damages sustained by Plaintiff as a result of Defendants wrongful acts in an amount subject to proof at trial. Defendants infringement of Plaintiffs rights under the 979 patent will continue to damage Plaintiffs business, causing irreparable harm, for which there is no adequate remedy at law, unless defendant is enjoined by this Court.

-2-

JURY DEMAND 8. Plaintiff hereby demands a jury trial on all issues and claims so triable. PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment and seeks relief against Defendant as follows: (a) (b) (c) For judgment that the 979 patent has been and/or continues to be infringed by Defendant; For an accounting of all damages sustained by Plaintiff as the result of Defendants acts of infringement; For a permanent injunction enjoining the aforesaid acts of infringement by Defendant, its officers, agents, servants, employees, subsidiaries and attorneys, and those persons acting in concert with the Defendant, including related individuals and entities, customers, representatives, OEMs, dealers, distributors and importers; For actual damages together with prejudgment interest, according to proof, For an award of attorneys fees pursuant to 35 U.S.C. 285 or as otherwise permitted by law; For all costs of suit; and For such other and further relief as the Court may deem just and proper.

(d) (e) (f) (g)

DATED: September 8, 2011

Respectfully submitted, By: /s/ Danny L. Williams Danny L. Williams Attorney-in-Charge State Bar No. 21518050 Southern District of Texas No. 406 J. Mike Amerson State Bar No. 01150025 Southern District of Texas No. 12480 Matthew R. Rodgers State Bar No. 24041802 Southern District of Texas No. 37378 WILLIAMS, MORGAN & AMERSON, P.C. 10333 Richmond Avenue, Suite #1100 Houston, Texas 77042

-3-

Telephone: (713) 934-7000 Facsimile: (713) 934-7011 E-Mail: danny@wmalaw.com E-Mail: mike@wmalaw.com ATTORNEYS FOR PLAINTIFF

-4-