UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 234
`
`PETROLEUM GEO-SERVICES, )
` )
` Petitioner, ) Case No.
` ) IPR2014-00687,
` vs. ) -00688, -00689
` )
`WESTERNGECO, )
` )
` Patent Owner. )
`-----------------------------x
`
` DEPOSITION OF BRIAN EVANS, PH.D.
` Volume II
` Washington, D.C.
` Friday, February 6, 2015
`
`Reported by:
` Lori J. Goodin, RPR, CLR, CRR,
` Realtime Systems Administrator
`Job No. 90107
`
`TSG Reporting - Worldwide
`(877) 702-9580
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`PGS v. WESTERNGECO (IPR2014-00689)
`WESTERNGECO Exhibit 2040, pg. 1
`
`

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`A P P E A R A N C E S:
`
` WILLIAMS & CONNOLLY
` Attorneys for Petitioner
` 725 Twelfth Street, Northwest
` Washington, D.C. 20005
` BY: DAVID BERL, ESQUIRE
` THOMAS FLETCHER, ESQUIRE
` ALEC SWAFFORD, ESQUIRE.
` JESSAMYN BERNIKER, ESQUIRE
`
`
`
`
`
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` PETROLEUM GEO-SERVICES, INC.
` IN HOUSE/CORPORATE COUNSEL
` 15150 Memorial Drive
` Houston, Texas 77079
` BY: KEVIN HART, ESQUIRE
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` February 6, 2015
` 8:41 a.m.
`
` Deposition of, BRIAN EVANS,
` PH.D., held at the offices of Williams and
` Connolly, LLP, 725 Twelfth Street,
` Northwest, Washington, D.C., before Lori J.
` Goodin, RPR, CLR, CRR, Realtime Systems
` Administrator, and a Notary Public in and
` for the District of Columbia.
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`Page 238
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` APPEARANCES CONTINUED:
`
` OBLON MCCLELLAND MAIER & NEUSTADT
` Attorneys for Patent owner
` 1940 Duke Street
` Alexandria, Virginia 22314
` BY: SCOTT MCKEOWN, ESQUIRE
` CHRISTOPHER BULLARD, ESQUIRE
`
`
`
`- AND -
`
` KIRKLAND & ELLIS
` Attorneys for Patent owner
` 300 North LaSalle
` Chicago, Illinois 60654
` BY: SIMEON PAPACOSTAS, ESQUIRE
` ROBERT LEONARD, ESQUIRE
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` B. Evans, Ph.D.
` BRIAN J. EVANS, PH.D.,
` a witness called for examination, having been
` previously duly sworn, was examined and
` testified further as follows:
` CONTINUED EXAMINATION 08:41
` BY MR. MCKEOWN: 08:41
` Q. Good morning. We are back on the 08:41
` record. I think everyone that was here 08:41
` yesterday -- do we need to enter an appearance? 08:41
` MR. BERL: Yes, Alec Swafford from 08:41
` Williams & Connolly is also here today, and 08:41
` Chris Suarez is no longer here today. 08:41
` MR. MCKEOWN: Okay. 08:41
` BY MR. MCKEOWN: 08:41
` Q. We've got some notes here. 08:41
` A. Yes. 08:41
` Q. I was just going to propose marking 08:41
` those as exhibits just for purposes of marking 08:41
` them. If you are done with these pages. 08:42
` A. Yes. 08:42
` Q. I think we left off at 2052. So. 08:42
` (Exhibits 2053, 2054 and 2055, 08:42
` notes, marked for identification.) 08:42
` BY MR. MCKEOWN: 08:43
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`PGS v. WESTERNGECO (IPR2014-00689)
`WESTERNGECO Exhibit 2040, pg. 2
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`

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` B. Evans, Ph.D.
` Q. Dr. Evans, did you talk about your 08:43
` testimony with your attorneys since we broke 08:43
` yesterday? 08:43
` A. No. 08:43
` Q. Have you looked at any documents? 08:43
` A. Well, just looked at mine on -- 08:43
` Q. You have reviewed your -- 08:43
` A. My report. 08:43
` Q. Okay. Anything else? 08:43
` A. No. 08:43
` Q. Okay. 08:43
` A. My reports. 08:43
` Q. I just want to go back to an example 08:43
` we talked about yesterday that I wasn't quite 08:43
` clear on. 08:43
` We talked about a hypothetical 08:43
` example of where a vessel was towing two 08:43
` streamers with a minimum separation of 08:43
` 75 meters, I believe it was. 08:43
` Do you recall that? 08:43
` A. Uh-huh. 08:43
` Q. And the question was -- I will wait 08:43
` for you. Okay. 08:44
` The question was whether or not in 08:44
`
`Page 241
`
` B. Evans, Ph.D.
` to the position of the streamers in that 08:45
` example? 08:45
` A. It is calculating a correction to 08:45
` the position, predicted position, of the 08:45
` streamer positioning devices which are mounted 08:45
` on the streamer and, therefore, inferred that 08:45
` that is the streamer position, predicted 08:45
` position. 08:45
` Q. And in that example, how much would 08:45
` the streamers be moved? 08:45
` A. Can you remind me of the example, 08:45
` please? 08:45
` Q. So, the example is we have a 08:45
` separation distance of 75 meters between two 08:45
` streamers. The minimum separation in the 08:46
` system is set at 75 meters. Again this is 08:46
` using the system of Workman. 08:46
` So, the question is, in that 08:46
` arrangement, how much are the streamers moved? 08:46
` MR. BERL: Objection. 08:46
` BY MR. MCKEOWN: 08:47
` Q. Just so we are clear this is a 08:47
` hypothetical. What aspect of your declaration 08:47
` are you looking at? 08:47
`
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` B. Evans, Ph.D.
` that arrangement using the Workman system, if 08:44
` the minimum distance were 75 and the separation 08:44
` between the streamers was 75, whether or not 08:44
` Workman was calculating a position. Do you 08:44
` remember that? 08:44
` MR. BERL: Objection. 08:44
` THE WITNESS: What do you mean by 08:44
` calculating a position? 08:44
` BY MR. MCKEOWN: 08:44
` Q. Well, I think you had said that 08:44
` Workman was continuously calculating a 08:44
` position. Is that right? 08:44
` A. I said the Kalman filter was 08:44
` continuously calculating. 08:44
` Q. Okay. Continuously calculating the 08:44
` position. Is that a position correction or 08:44
` just a position? 08:44
` A. The Kalman filter takes past 08:44
` positions to predict a future. The next 08:44
` position that the positional location devices 08:45
` on the streamer and guns and on the vessel 08:45
` itself, are predicted to be at a certain point 08:45
` in time. 08:45
` Q. And is it calculating a correction 08:45
`
`Page 242
`
` B. Evans, Ph.D.
` A. So, sorry. You have broken my line 08:47
` of thought. Let me get it right. The, what 08:47
` you are asking me is that in a situation where 08:48
` you have the two streamers being towed, 08:48
` 75 meters separation, and the minimum 08:48
` separation is 75 meters, Workman's disclosure 08:48
` requires a minimum allowable separation between 08:48
` streamer cables. 08:48
` And provided you maintain that 08:48
` minimum allowable separation distance between 08:48
` adjacent streamers which is done to avoid 08:48
` entanglement, that would be adequate. 08:48
` Q. So, they -- 08:49
` A. Because it is the value. 08:49
` Q. So, in that example they would not 08:49
` be moved? 08:49
` A. They would not be moved on that 08:49
` example, because that is a precise value they 08:49
` don't need to be moved. 08:49
` Q. Would your answer change if the 08:49
` streamers became separated by 90 meters? 08:49
` MR. BERL: Objection. 08:49
` THE WITNESS: So, being clear about 08:49
` your question. 08:49
`
`TSG Reporting - Worldwide
`(877) 702-9580
`
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`
`PGS v. WESTERNGECO (IPR2014-00689)
`WESTERNGECO Exhibit 2040, pg. 3
`
`

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` B. Evans, Ph.D.
` BY MR. MCKEOWN: 08:49
` Q. Uh-huh. 08:49
` A. If there is no movement of -- 08:49
` Q. So, same -- 08:49
` A. Positioning devices. I'm asking you 08:49
` the question. 08:49
` Q. Yes. I'm reiterating it. The same 08:49
` minimum threshold is 75 meters, but now the 08:49
` streamers are 90 meters apart. 08:49
` MR. BERL: Objection. 08:49
` THE WITNESS: So, the question is 08:50
` when there is a, it is on the threshold 08:50
` value but has not exceeded the threshold 08:50
` value, but now they have moved further, 08:50
` 90 meters apart after a period of time -- 08:50
` sorry? 08:50
` BY MR. MCKEOWN: 08:50
` Q. Yes. So, the minimum is still 75. 08:50
` But now the distance between the streamers. 08:50
` A. Well the minimum 75 is set. 08:51
` Q. Exactly. 08:51
` A. As a threshold value. 08:51
` Q. Right. In the hypothetical that is 08:51
` set, so different actual situation with the 08:51
`
`Page 245
`
` B. Evans, Ph.D.
` A. I have told you preplotted values 08:52
` then determine where they should be. 08:52
` Q. But that wasn't the question. I'm 08:52
` not asking about whether you might preplot 08:52
` things and move them based upon that; I'm 08:52
` asking would they be moved based upon the 08:52
` threshold set up that Workman teaches? 08:52
` A. If they were greater than the 08:52
` minimum separation -- 08:52
` Q. Exactly. 08:52
` A. -- they wouldn't be expected to be 08:52
` moved unless, based on the minimum separation 08:52
` they wouldn't be expected to be moved -- 08:52
` Q. Okay. 08:52
` A. -- unless they have to go to a 08:52
` preplotted value. 08:52
` Q. So, they would not be moved based 08:52
` upon the threshold. But if there was some 08:52
` other system to move them, they would be moved. 08:52
` A. Correct. 08:52
` Q. Okay. We also talked a little bit 08:52
` yesterday about Kalman filters. 08:52
` And I think you stated, and correct 08:52
` me if I'm wrong, but that as to the specific 08:52
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` B. Evans, Ph.D.
` streamers, they have now moved to 90 meters 08:51
` apart. 08:51
` Would the system correct them in any 08:51
` way as to position? 08:51
` MR. BERL: Objection. 08:51
` THE WITNESS: Workman tells us that 08:51
` all they have to be is within that minimum 08:51
` threshold value. 08:51
` BY MR. MCKEOWN: 08:51
` Q. So that is a no, they would not be 08:51
` moved? 08:51
` A. So, they could potentially be moved 08:51
` if required by preplotted values, predicted, a 08:51
` comparison between predicted and preplotted 08:51
` values, then they may be moved. 08:51
` Q. My question isn't whether they might 08:51
` be moved, my question is whether they would be 08:51
` moved based upon exceeding that threshold. 08:51
` A. Is that a new question? 08:51
` Q. No. So, we are saying they are at 08:51
` 90 meters, so they are farther apart than 75, 08:51
` so they haven't violated the threshold. Would 08:52
` they move based upon that threshold. So that 08:52
` is a no? 08:52
`
`Page 246
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` B. Evans, Ph.D.
` internal operations of a Kalman filter that is 08:52
` proprietary technology that you would not be 08:53
` aware of. Is that accurate? 08:53
` A. Could you repeat that, please? 08:53
` Q. You testified yesterday that the 08:53
` internal operation of a Kalman filter is based 08:53
` upon proprietary code. Do you agree with that? 08:53
` MR. BERL: Objection. 08:53
` THE WITNESS: The Kalman filter has 08:53
` many forms. And only those people who are 08:53
` privy to the computation in any 08:53
` contractor's computer would have access to 08:53
` that proprietary code. 08:53
` No one outside of them, even within 08:54
` the company, there is a high probability no 08:54
` one outside of the operators would have 08:54
` access to that code. It is commercial in 08:54
` confidence. 08:54
` BY MR. MCKEOWN: 08:54
` Q. Okay. Let's look at paragraph -- 08:54
` well, it is Page 21 of the '520 declaration. 08:54
` A. All right. 08:55
` Q. Is that graphic there, is that from 08:55
` your textbook? Or is that something you 08:55
`
`TSG Reporting - Worldwide
`(877) 702-9580
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`PGS v. WESTERNGECO (IPR2014-00689)
`WESTERNGECO Exhibit 2040, pg. 4
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` B. Evans, Ph.D.
` generated on your own? 08:55
` MR. BERL: Objection. 08:55
` THE WITNESS: I drew that graphic 08:55
` based on my experience, and passed it on 08:55
` for someone else to draw for me. 08:55
` BY MR. MCKEOWN: 08:55
` Q. Okay. 08:55
` A. Because I'm not an artist. 08:55
` Q. The, in the paragraph above that 08:55
` figure there is a, well, I guess it is one 08:55
` sentence paragraph. It states, "During a turn 08:55
` centripedal and other forces on a streamer 08:55
` generate force, et cetera." 08:55
` What did you mean by other forces? 08:55
` MR. BERL: Objection. 08:56
` THE WITNESS: So, my understanding 08:56
` is that you are asking me what other forces 08:56
` other than centripedal -- 08:56
` Q. Correct. 08:56
` A. -- are generated. A centripedal 08:56
` force is the factor of orthogonal force 08:56
` directions. 08:56
` That means two forces with an angle 08:56
` produce a third dominant force. 08:56
`
`Page 249
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` B. Evans, Ph.D.
` speed, all of the standard issues that you find 08:59
` when towing a cable as typically explained in 08:59
` hydrodynamics. Hydrographical journals, often 08:59
` refer to these terms. 08:59
` Q. When you say text, are you referring 08:59
` to your textbook? Just so I'm clear. 08:59
` A. Any textbook. 08:59
` Q. Any textbook? 08:59
` A. On hydrodynamics will explain that 08:59
` concept. 08:59
` Q. Okay. 08:59
` A. Naval architect would explain it to 08:59
` you. 08:59
` Q. I just wanted to be clear on that. 08:59
` A. I'm not a naval architect. 08:59
` Q. Okay. 08:59
` A. So, I simply stopped it there. 08:59
` Q. Let's go to Page 60. 08:59
` A. 60. 08:59
` Q. There is some, well, I will wait for 08:59
` you to get there. So, this section talks about 09:00
` construction of relevant claim terms. 09:00
` Can you describe how you construed 09:00
` claim terms for this patent? 09:00
`
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` B. Evans, Ph.D.
` The centripedal force results, in 08:57
` this case, from a streamer, a heavy cable, 08:57
` being towed at a certain velocity in a certain 08:57
` direction. 08:57
` And that is, as we know from 08:57
` Workman, is a function of cross currents, how 08:57
` the cable moves laterally. 08:57
` The lateral movement is exacerbated 08:57
` when a turn is invoked, and as we make the 08:57
` turn, the innermost cable tends to move at a 08:57
` velocity slower than the outermost cable, which 08:57
` is common sense. When you have two strings in 08:57
` water and you pull them at different radii, the 08:58
` innermost, if they are pulled at the same 08:58
` velocity, the innermost has forces acting upon 08:58
` it which are quite different from those forces 08:58
` on the outer as a function of the radius of 08:58
` curvature and also the velocity of tow. 08:58
` This results in a narrowing of any 08:58
` two towed streamers. In the text I refer to 08:58
` this as compression. 08:58
` And the other forces I refer to are 08:58
` those other vectorial forces resulting from 08:58
` changes in angle, changes in relative vessel 08:58
`
`Page 250
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` B. Evans, Ph.D.
` MR. BERL: Objection. 09:00
` THE WITNESS: So, could you please 09:00
` restate it or rephrase it? 09:00
` BY MR. MCKEOWN: 09:00
` Q. Sure. In section, or, excuse me. 09:00
` On Page 60 there is a section entitled 09:00
` Construction of Relevant Claim Terms. 09:00
` A. Yes. 09:00
` Q. I'm asking what was the process that 09:00
` you went through to construe claim terms? 09:00
` MR. BERL: Objection. 09:00
` THE WITNESS: What do you mean by 09:00
` construe? 09:00
` BY MR. MCKEOWN: 09:01
` Q. Well I'm just using the language 09:01
` that is in your report. 09:01
` A. I ask you what do you mean by 09:01
` construe. 09:01
` Q. Do you have an understanding of 09:01
` construe. 09:01
` MR. BERL: Objection. 09:01
` THE WITNESS: Could you give me a 09:01
` different word. 09:01
` BY MR. MCKEOWN: 09:01
`
`TSG Reporting - Worldwide
`(877) 702-9580
`
`5
`
`PGS v. WESTERNGECO (IPR2014-00689)
`WESTERNGECO Exhibit 2040, pg. 5
`
`

`

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` B. Evans, Ph.D.
` Q. I'm talking about the word that is 09:01
` in your report. Do you not have an 09:01
` understanding of that? 09:01
` MR. BERL: Objection. 09:01
` BY MR. MCKEOWN: 09:01
` Q. So, construction, do you understand 09:01
` what that means, heading B? 09:01
` A. Sorry, can you repeat the question, 09:01
` please? 09:01
` Q. In heading B it says Construction of 09:01
` Relevant Claim Terms. Do you see that? 09:01
` A. Yes. 09:01
` Q. I'm asking what process you went 09:01
` through to construe claim terms. 09:01
` MR. BERL: Objection. 09:01
` THE WITNESS: Based on my reading of 09:02
` the '520 patent claims and specification, I 09:02
` have used the standard known as the 09:02
` broadest reasonable interpretation. 09:02
` I have used this standard to 09:02
` construe the claim terms relevant to the 09:02
` validity analysis presented in this opinion 09:02
` from the perspective of the person of skill 09:02
` in the art. 09:02
`
`Page 253
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` B. Evans, Ph.D.
` Q. Yes. That was a statement you made 09:05
` yesterday about mine sweeping. 09:05
` A. My understanding, having gathered 09:05
` information from a multiplicity of sources, 09:05
` including at least one movie, black and white, 09:05
` since I was not around, alive, during the 09:05
` Second World War, so, I have no personal 09:06
` experience of being involved in the Second 09:06
` World War. 09:06
` So, my understanding from this input 09:06
` information is that they were able to tow 09:06
` paravanes at different lateral offsets for use 09:06
` in clearing mines and also experiments with 09:06
` submarine detection. 09:06
` What I read is the fact that vessel 09:06
` speed, paravane rudder angle, offset distance 09:07
` from the towing vessel, paravane vessel speed, 09:07
` which is separate from tow vessel speed and is 09:07
` a vector of tow vessel speed, and angle of tow, 09:07
` these were input data to move a paravane around 09:07
` for mine detection. 09:07
` Q. What do you mean by lateral offset? 09:07
` A. Lateral offset is the distance, 09:07
` because it is an offset distance, that a towed 09:08
`
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` B. Evans, Ph.D.
` BY MR. MCKEOWN: 09:02
` Q. Is that the only publication you 09:02
` used to understand the claim terms? 09:03
` MR. BERL: Objection. 09:03
` THE WITNESS: Which claim terms were 09:03
` you referring to? 09:03
` BY MR. MCKEOWN: 09:03
` Q. Any of them? Pick one. Streamer 09:03
` positioning devices as shown is the first one. 09:03
` A. I have used a number of different 09:03
` publications and included my own interpretation, 09:03
` based on my own person experiences and 09:03
` disclosures I interpret from different 09:04
` publications. 09:04
` Q. Okay. I want to go back to another 09:04
` topic we talked about yesterday. I think you, 09:04
` we were talking about lateral steering and you 09:04
` had mentioned some World War II mine sweeping 09:04
` that you were aware of. 09:04
` Can you explain how lateral steering 09:04
` was done in that context? 09:04
` A. So your question is asking me how 09:05
` they performed lateral steering in World War 09:05
` II. Is that correct? 09:05
`
`Page 254
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` B. Evans, Ph.D.
` vehicle would be from the line immediately 09:08
` behind the towed vessel that is the lateral 09:08
` offset distance. 09:08
` Q. You mentioned a paravane. What is 09:08
` that? 09:08
` A. Are we still at '520? 09:08
` Q. Well we are talking generally now. 09:08
` A. Oh, general. 09:08
` Q. Yes. 09:08
` A. Okay. 09:08
` Q. What document are you looking at 09:09
` there? 09:09
` A. Which question do you want me to 09:09
` answer. 09:10
` Q. I was asking you what paravane meant 09:10
` in your description of the World War II 09:10
` technology and you are looking at a reference 09:10
` there. 09:10
` A. I'm looking at a Hedberg reference. 09:10
` Q. Was that from World War II? 09:10
` A. It was derived, I would say it was 09:10
` technology that was available to Hedberg in, 09:10
` from World War II and he applied that 09:10
` technology, that is paravane technology, to 09:10
`
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`TSG Reporting - Worldwide
`(877) 702-9580
`
`6
`
`PGS v. WESTERNGECO (IPR2014-00689)
`WESTERNGECO Exhibit 2040, pg. 6
`
`

`

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` B. Evans, Ph.D.
` lateral steering of at least three streamers. 09:10
` Q. And where is the paravane located in 09:10
` Hedberg? Is that at the front end of the 09:10
` streamer? 09:10
` A. Figure 2 of Hedberg shows paravanes 09:10
` 18A and 18C. Figure 8 shows paravanes 81A and 09:11
` 81C. 09:11
` Figure 10 shows paravanes 94, 09:11
` Figure 11 shows paravanes 94. Figure 12 show 09:11
` paravanes 94, which could be construed, could 09:11
` be interpreted as being in Figure 8 in the 09:11
` same, along the same streamer, 4C, laterally 09:11
` offset from the tow line. The central tow 09:12
` direction. 09:12
` Q. What do you mean by could be 09:12
` construed? 09:12
` A. That is my terminology. I am 09:12
` interpreting that the paravanes shown in 09:12
` Figure 12 could be placed as the same cable on 09:12
` Figure 8 offset by distance from the tow line 09:12
` which would be preplotted as Line 26 in 09:12
` Figure 8. 09:12
` Q. Have you ever seen that type of 09:12
` arrangement in practice? 09:12
`
`Page 257
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` B. Evans, Ph.D.
` field, you, and the paravanes are dived to 09:14
` ten meters water depth, no one sees the 09:14
` paravanes. You can only see the surface 09:14
` water displacement as a function of tow 09:14
` buoy 96. 09:14
` I have observed tow buoys along the 09:14
` surface; 19, approximately 1976 I was on a 09:14
` vessel where equipment was placed in the 09:14
` water. I do not remember, that was a 09:15
` Norwegian vessel and they attempted to 09:15
` place trailing equipment in the water in 09:15
` exactly the like manner of Figure 12. 09:15
` I do remember advising them that 09:15
` their equipment was not up to present day 09:15
` technology of 1976. But they went ahead 09:15
` and the work didn't last very long because 09:15
` the, I was representing a, an oil and gas 09:15
` company in the North Sea and I personally 09:16
` called a halt to the operation. 09:16
`