Appeal 2005-2547
Application 10/134,817
pressure” is not limited to any particular ranges of pressure, but is
customarily so named on the basis of location and function in addition to
pressure. Pump 29 of Venema can reasonably be called a high pressure
pump according to its location and function as well as the pressure drop it
must overcome. Pump 29 is located in the main conveying line that supplies
the water and polymer solution to the Static Mixer and discharge line (see
the Figure). While other pumps, namely, pumps 10 and 21, provide the
pressure required to feed the additives to the mainline, it is the pump 29 that
must provide the bulk of the pressure of conveyance through the Static
Mixer. This is evident from its location in the mainline. Pump 29 must be
capable of overcoming the Static Mixer pressure drop. That drop is at least
20-25 psig (35-40 psia) and can be 40 psig (55 psia). The fact that it must
be able to pressurize to 40-55 psia levels (2.7-3.8 bars), and functions to
convey fluid through the system rather than mix, makes it reasonable to term
it a “high pressure pump” in accordance with the customary language of the
art of horizontal drilling.
Appellant states in passing that Venema illustrates pump 29 as a
centrifugal pump, not a positive displacement pump (Reply Br. 14). But
Appellant offers no evidence that a circle with a “P” within as illustrated by
Venema is commonly used to illustrate a centrifugal pump.
We determine that “high pressure pump” as claimed reasonably
encompasses pump 29 of Venema.
Appellant further contends that the combination of Venema and
Landers is improper because Venema’s polymer-in-water “stabilizer”
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