IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

PRECISION ENERGY SERVICES, INC. Plaintiff, v. THRUBIT, LLC., Defendant.

CIVIL ACTION NO. 4:11-cv-4492

JURY TRIAL DEMANDED

ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT Plaintiff Precision Energy Services, Inc., for its complaint against Defendant ThruBit, LLC., hereby alleges the following: PARTIES 1. Plaintiff Precision Energy Services, Inc. (Precision) is a Delaware corporation

and has a place of business at 515 Post Oak Blvd., Suite 600, Houston, Texas 77027. 2. On information and belief, Defendant ThruBit, LLC. (ThruBit) is a Delaware

limited liability corporation having its principal place of business at 10353 Centrepark Drive, Houston, TX 77043. NATURE OF THE ACTION 3. This is a civil action for patent infringement arising under the patent laws of the

United States, Title 35 of the United States Code.

JURISDICTION AND VENUE 4. 1338(a). 5. This Court has general personal jurisdiction over ThruBit by virtue of Defendant This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 and

having its principal place of business in Houston, Texas. 6. Venue is proper as to Defendant ThruBit in this judicial district pursuant to 28

U.S.C. 1391(b) and (c) and 1400(b) because (i) ThruBit has committed acts of infringement alleged in the Southern District of Texas and (ii) ThruBit has a regular and established place of business in the Southern District of Texas. FACTUAL BACKGROUND 7. Plaintiff is the owner of U.S. Patent No. 7,537,061 (the 061 Patent), entitled

System and Method for Releasing and Retrieving Memory Tool with Wireline in Well Pipe. The 061 Patent was duly and legally issued on May 26, 2009. A true and correct copy of the 061 Patent is attached as Exhibit A. 8. On information and belief, Defendant ThruBit develops, manufactures, and

markets memory tool logging systems and services, including the ThruBit Logging System Level 3 Conveyance and the ThruBit Logging System - Level 4 Conveyance (ThruBits Conveyance Logging Systems and Services). 9. On information and belief, Defendant ThruBit makes, uses, sells, and/or offers for

sale its memory tool logging systems and services, such as the Conveyance Logging Systems and Services, to oil and gas companies.

COUNT I DIRECT INFRINGEMENT OF U.S. PATENT NO. 7,537,061 10. On information and belief, Defendant ThruBit has been and now is directly

infringing one or more claims of the 061 Patent by making, using, selling, and/or offering for sale its memory tool logging systems and services, including ThruBits Conveyance Logging Systems and Services, that infringe one or more claims of the 061 Patent. ThruBit is thus liable for direct infringement of the 061 Patent under 35 U.S.C. 271(a). 11. By letter dated October 24, 2011, Precisions counsel (acting for Precisions

parent Weatherford International, Inc.) placed ThruBit on notice of infringement. A true and correct copy of the letter dated October 24, 2011 is attached as Exhibit B. ThruBit is on notice of infringement at least as early as such written notice of the infringement, to the extent notice is required. 12. To the extent required, Plaintiff has complied with the marking and/or notice

provisions of 35 U.S.C. 287. 13. Pursuant to 35 U.S.C. 284, Precision is entitled to damages adequate to

compensate it for ThruBits infringement of the 061 Patent, but in no event less than a reasonable royalty. 14. On information and belief, ThruBits infringement of the 061 Patent has been

and continues to be willful. PRAYER FOR RELIEF WHEREFORE, Precision prays that this Court: A. B. Issue a final injunction against the continuing infringement; Enter a judgment in favor of Precision that Defendant ThruBit has directly

infringed the 061 Patent;

C.

Enter a judgment in favor of Precision that Defendants infringement of the 061

Patent has been and continues to be willful; D. Award Precision its damages (including pre-filing damages), costs, expenses,

prejudgment and post-judgment interest, and post-judgment royalties for Defendants direct infringement of the 061 Patent as provided under 35 U.S.C. 284; E. Award Precision enhanced damages, up to and including trebling Precisions

damages pursuant to 35 U.S.C. 284 for Defendants willful infringement of the 061 Patent; F. Award Precision its costs of suit and reasonable attorneys fees pursuant to 35

U.S.C. 285 due to the exceptional nature of this case, or as otherwise permitted by law; and G. Award Precision such other relief as to which Precision is justly entitled. DEMAND FOR JURY TRIAL Precision, under Federal Rule of Civil Procedure Rule 38, requests a trial by jury of any issues so triable by right.

Respectfully submitted, By: /s/ J. David Cabello J. David Cabello Attorney-in-charge Texas State Bar No. 03574500 S.D. TX Federal I.D. No. 3514 Wong, Cabello, Lutsch, Rutherford & Brucculeri, LLP 20333 State Hwy. 249 Suite 600 Houston, Texas 77070 Telephone: (832) 446-2400 Facsimile: (832) 446-2424 Attorney for Plaintiff Precision Energy Services, Inc. Of Counsel: Wong, Cabello, Lutsch, Rutherford & Brucculeri LLP