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UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`
`
`
`
`
`PETROLEUM GEO-SERVICES INC.
`
`Petitioner,
`
`v.
`
`WESTERNGECO L.L.C.
`
`Patent Owner.
`______________
`
`Case IPR2014-00689
`
`Patent 7,293,520
`
`____________
`
`
`
`PATENT OWNER WESTERNGECO L.L.C.’S
`RESPONSES TO PETITIONER’S OBJECTIONS TO EVIDENCE DATED
`MARCH 27, 2015 AND SUPPLEMENTAL EVIDENCE
`
`
`WESTERNGECO Exhibit 2167, pg. 1
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`WESTERNGECO L.L.C.
`Case IPR2014-00689
`U.S. Patent 7,293,520
`Responses to Objections to Evidence and Supplemental Evidence
`
`
`
`In response to Petitioner’s March 27, 2015 Objections to Evidence, Patent
`
`
`
`
`
`Owner WesternGeco L.L.C. (“WesternGeco” or “Patent Owner”) hereby responds,
`
`on an exhibit-by-exhibit basis, as follows:
`
`
`
`Exhibit 2046: Patent Owner provides the Declaration of Michael L. Kiklis
`
`and Exhibit 2127. 1
`
`
`
`Exhibit 2050: Patent Owner provides the Declaration of Michael L. Kiklis
`
`and Exhibit 2106.2
`
`Exhibit 2051: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman3, the Declaration of Michael L. Kiklis, and Exhibit 2107.
`
`
`
`Exhibit 2052: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman.
`
`
`
`Exhibit 2054: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman.
`
`1 The Declaration of Michael L. Kiklis is Exhibit 2105 to this proceeding.
`2 Exhibits 2106, 2107, 2108, 2113, and 2118–2123 are excerpts of the certified
`copy of the trial transcript in WesternGeco L.L.C. v. Ion Geophysical Corporation,
`Civil Action No. 4:09-CV-01827. A certified copy of the entire trial transcript is
`located at the office of Oblon, McClelland, Maier & Neustadt L.L.P. and can be
`made available for inspection by Petroleum Geo-Services Inc. (“PGS”) upon
`reasonable notice.
`3 The Second Declaration of Timothy K. Gilman is Exhibit 2101 to this
`proceeding.
`
`
`
`1
`
`WESTERNGECO Exhibit 2167, pg. 2
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`WESTERNGECO L.L.C.
`Case IPR2014-00689
`U.S. Patent 7,293,520
`Responses to Objections to Evidence and Supplemental Evidence
`
`
`Exhibit 2055: Patent Owner provides the Second Declaration of Timothy
`
`
`
`K. Gilman, the Declaration of Michael L. Kiklis, and Exhibit 2108.
`
`
`
`Exhibit 2061: Patent Owner provides the Declaration of Michael L. Kiklis
`
`and Exhibit 2109.
`
`
`
`Exhibit 2062: Patent Owner provides the Declaration of Michael L. Kiklis
`
`and Exhibit 2110.
`
`Exhibit 2071: Patent Owner provides the Declaration of Michael L. Kiklis.
`
`Exhibit 2072: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman.
`
`Exhibit 2073: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman.
`
`Exhibit 2074: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman and Exhibit 2102.
`
`Exhibit 2076: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman.
`
`
`
`Exhibit 2077: Patent Owner provides the Corrected Declaration of Robin
`
`C. Walker (Exhibit 2103), adding paragraphs 51 and 52.
`
`Exhibit 2078: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman, the Declaration of Michael L. Kiklis, and Exhibit 2113.
`
`
`
`2
`
`WESTERNGECO Exhibit 2167, pg. 3
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`WESTERNGECO L.L.C.
`Case IPR2014-00689
`U.S. Patent 7,293,520
`Responses to Objections to Evidence and Supplemental Evidence
`
`
`Exhibit 2079: Patent Owner provides the Supplemental Declaration of
`
`
`
`Robin C. Walker.4
`
`
`
`Exhibit 2080: Patent Owner provides the Supplemental Declaration of
`
`Robin C. Walker.
`
`
`
`Exhibit 2081: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman, the Declaration of Michael L. Kiklis, and Exhibits 2114 and 2115.
`
`
`
`Exhibit 2082: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman, the Declaration of Michael L. Kiklis, and Exhibit 2116.
`
`
`
`Exhibit 2083: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman, the Declaration of Michael L. Kiklis, and Exhibits 2117 and 2118.
`
`
`
`Exhibit 2084: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman, the Declaration of Michael L. Kiklis, and Exhibit 2119.
`
`
`
`Exhibit 2085: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman.
`
`Exhibit 2086: Patent Owner provides the Supplemental Declaration of
`
`Robin C. Walker.
`
`
`4 The Supplemental Declaration of Robin C. Walker is Exhibit 2104 to this
`proceeding.
`
`
`
`3
`
`WESTERNGECO Exhibit 2167, pg. 4
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`WESTERNGECO L.L.C.
`Case IPR2014-00689
`U.S. Patent 7,293,520
`Responses to Objections to Evidence and Supplemental Evidence
`
`
`Exhibit 2087: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman, the Declaration of Michael L. Kiklis, and Exhibit 2120.
`
`Exhibit 2088: Patent Owner provides the Supplemental Declaration of
`
`Robin C. Walker.
`
`Exhibit 2089: Patent Owner provides the Supplemental Declaration of
`
`Robin C. Walker.
`
`Exhibit 2090: Patent Owner provides the Supplemental Declaration of
`
`Robin C. Walker.
`
`Exhibit 2091: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman and the Supplemental Declaration of Robin C. Walker.
`
`Exhibit 2092: Patent Owner provides the Supplemental Declaration of
`
`Robin C. Walker.
`
`Exhibit 2093: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman, the Supplemental Declaration of Robin C. Walker, the Declaration of
`
`Michael L. Kiklis, and Exhibit 2121.
`
`Exhibit 2094: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman, the Supplemental Declaration of Robin C. Walker, the Declaration of
`
`Michael L. Kiklis, and Exhibit 2121.
`
`
`
`4
`
`WESTERNGECO Exhibit 2167, pg. 5
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`WESTERNGECO L.L.C.
`Case IPR2014-00689
`U.S. Patent 7,293,520
`Responses to Objections to Evidence and Supplemental Evidence
`
`
`Exhibit 2095: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman, the Declaration of Michael L. Kiklis, and Exhibits 2115, 2122, 2123,
`
`2124, and 2125.
`
`Exhibit 2096: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman.
`
`Exhibit 2097: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman, the Declaration of Michael L. Kiklis, and Exhibit 2126.
`
`Exhibit 2098: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman, the Declaration of Michael L. Kiklis, and Exhibit 2121.
`
`Exhibit 2099: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman.
`
`Exhibit 2100: Patent Owner provides the Supplemental Declaration of
`
`Robin C. Walker.
`
`Respectfully submitted,
`
`Oblon, McClelland, Maier &
`Neustadt, LLP
`
`
`
`/Michael L. Kiklis/
`Michael L. Kiklis (Reg. No. 38,939)
`Attorney for Patent Owner
`WESTERNGECO L.L.C.
`
`
`
`
`Dated: April 9, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`5
`
`WESTERNGECO Exhibit 2167, pg. 6
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the above-captioned Responses to
`
`Objections to Evidence and Supplemental Evidence were served by delivering
`
`copies via electronic means upon the following attorneys of record for Petitioner:
`
`David Berl
`dberl@wc.com
`
`Jessamyn Berniker
`jberniker@wc.com
`
`Thomas S. Fletcher
`tfletcher@wc.com
`
`Christopher Suarez
`csuarez@wc.com
`
`
`
`
`
`
`
`/Michael L. Kiklis/
`Michael L. Kiklis (Reg. No. 38,939)
`Attorney for Patent Owner
`
`WESTERNGECO L.L.C.
`
`
`
`
`
`Dated: April 9, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`WESTERNGECO Exhibit 2167, pg. 7
`PGS v. WESTERNGECO
`IPR2014-00689

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