Ex parte MYERS et al. - Page 11




          Appeal No. 1999-0444                                                        
          Application No. 08/758,655                                                  


               The Leutwyler reference is not cited to show                           
               the complete invention as claimed.  Leutwyler,                         
               admittedly, runs the packer and perforating gun in a                   
               well on a wireline.  However, the secondary                            
               references to Ross '860 or Council et al '046 or                       
               Crawford '642 show that it is extremely well known                     
               in the art in the last decade to run well tools on                     
               coiled tubing rather than on a wireline because of                     
               many advantages provided by the coiled tubing string                   
               over the wireline, e.g., a coiled tubing having a                      
               greater strength; capable of pushing a downhole tool                   
               in a horizontal or deviated wellbore or conveying                      
               fluid downhole when needed, as evidenced by Ross                       
               '860 or Council et al '046 or Crawford '642.                           
               Like the examiner (page 8 of the answer), we note that                 
          Council '046 states in column 1, lines 17-32 that:                          

                                                                                     
               Although wireline tool operations are still in                         
               wide-spread use, the use of coiled or reeled tubing                    
               is becoming more popular since it enjoys advantages                    
               over wireline in certain operations.  For example,                     
               coiled tubing can be used in connection with highly                    
               deviated or horizontal well completions since the                      
               coiled tubing does not rely on gravity for setting                     
               and retrieval of downhole devices.  Coiled tubing                      
               has also proven to be advantageous from a time and                     
               money saving standpoint in connection with sand                        
               washing, fluid displacement, removal of paraffin,                      
               squeeze cementing, spotting acid, light duty                           
               drilling of cement and the like, fishing operations,                   
               and flow line clean out.  With the recent                              
               availability of large diameter coiled tubing,                          
               increasingly heavier duty well drilling, servicing                     
               and completion operations are possible.                                



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