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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————————
`
`PETROLEUM GEO-SERVICES INC.,
`Petitioner
`
`v.
`
`WESTERNGECO LLC
`Patent Owner
`
`———————————
`
`Cases
`
`IPR2014-01475 (U.S. Patent No. 7,162,967)
`IPR2014-01477 (U.S. Patent No. 7,080,607)
`IPR2014-01478 (U.S. Patent No. 7,293,520)
`
`
`———————————
`
`DECLARATION OF TIMOTHY K. GILMAN
`
`
`
`Pursuant to 28 U.S.C. § 1746, I, Timothy K. Gilman, the undersigned,
`
`hereby declare as follows:
`
`1.
`
`My name is Timothy K. Gilman. I am over eighteen years of
`
`age, of sound mind, and in all ways qualified and competent to make this
`
`declaration. I have personal knowledge of the facts contained in this declaration
`
`and they are true and correct.
`
`
`
`
`
`
`WESTERNGECO Exhibit 2137, pg. 1
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`
`
`2.
`
`I am a partner in the law firm of Kirkland & Ellis, L.L.P.,
`
`counsel for WesternGeco L.L.C. (“WesternGeco”).
`
`3.
`
`Exhibit 2059 is a true and correct copy of the deposition of
`
`John Thompson dated October 26, 2011 from WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.).
`
`4.
`
`Exhibit 2060 is a true and correct copy of Exhibit 4 to the
`
`deposition of John Thompson dated October 26, 2011 from WesternGeco L.L.C. v.
`
`ION Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.), an email with
`
`the subject line “ION Press Release” dated June 22, 2009.
`
`5.
`
`Exhibit 2061 is a true and correct copy of Exhibit 3 to the
`
`deposition of John Thompson dated October 26, 2011 from WesternGeco L.L.C. v.
`
`ION Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.), a press release
`
`entitled “ION Files Patent Infringement Lawsuit Against WesternGeco.”
`
`6.
`
`Exhibit 2064 is a true and correct copy of excerpts from Multi
`
`Klient AS’ “Application for Permit to Conduct Geological or Geophysical
`
`Exploration for Mineral Resources or Scientific Research on the Outer Continental
`
`Shelf,” which can be found on the U.S. Department of the Interior Bureau of
`
`Ocean Energy Management website (last accessed 3/31/15).
`
`7.
`
`Exhibit 2067 is a true and correct copy of Exhibit 14 to the
`
`deposition of John Thompson dated October 26, 2011 from WesternGeco L.L.C. v.
`
`
`
`
`2
`
`WESTERNGECO Exhibit 2137, pg. 2
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`
`
`ION Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.), a document
`
`entitled “Issues Summary ION v. WesternGeco U.S. Law Suit Related to Lateral
`
`Steering of Marine Seismic Streamers.”
`
`8.
`
`Exhibit 2069 is a true and correct copy of European Patent No.
`
`EP 1850151B1.
`
`9.
`
`Exhibit 2070 is a true and correct copy of an opposition to
`
`EP1850151 filed by ION Geophysical Corporation.
`
`10.
`
`Exhibit 2072 is a true and correct copy of ION’s Geophysical
`
`Corporation’s Statement of Grounds of Appeal related to European Patent No. EP
`
`1850151.
`
`11.
`
`Exhibit 2083 is a true and correct copy of Dr. Simon
`
`Bittleston’s trial testimony from the trial in WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.)..
`
`12.
`
`Exhibit 2084 is a true and correct copy of PTX 73, an exhibit
`
`that was admitted into evidence during the trial in WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.).
`
`13.
`
`Exhibit 2085 is a true and correct copy of excerpts from the
`
`deposition transcript of Oyvind Hillesund dated October 20, 2010.
`
`
`
`
`3
`
`WESTERNGECO Exhibit 2137, pg. 3
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`
`
`14.
`
`Exhibit 2086 is a true and correct copy of Dr. John Leonard’s
`
`trial demonstrative number 8 from the trial in WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.).
`
`15.
`
`Exhibit 2087 is a true and correct copy of excerpts from Dr.
`
`John Leonard’s trial testimony from the trial in WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.).
`
`16.
`
`Exhibit 2096 is a true and correct copy of an Unopposed Notice
`
`of Application for Issuance of Letter of Request dated April 13, 2011 from
`
`WesternGeco L.L.C. v. ION Geophysical Corp., et al., Civ. No. 4:09-cv-01827
`
`(S.D. Tex.).
`
`17.
`
`Exhibit 2097 is a true and correct copy of a Letter of Request
`
`dated April 20, 2011 from WesternGeco L.L.C. v. ION Geophysical Corp., et al.,
`
`Civ. No. 4:09-cv-01827 (S.D. Tex.).
`
`18.
`
`Exhibit 2100 is a true and correct copy of excerpts from Robin
`
`Walker’s trial testimony from the trial in WesternGeco L.L.C. v. ION Geophysical
`
`Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.).
`
`19.
`
`Exhibit 2103 is a true and correct copy of PTX 214, an exhibit
`
`that was admitted into evidence during the trial in WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.)
`
`
`
`
`4
`
`WESTERNGECO Exhibit 2137, pg. 4
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`
`
`20.
`
`Exhibit 2104 is a true and correct copy of PTX 309, an exhibit
`
`that was admitted into evidence during the trial in WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.)
`
`21.
`
`Exhibit 2105 is a true and correct copy of PTX 398, an exhibit
`
`that was admitted into evidence during the trial in WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.)
`
`22.
`
`Exhibit 2106 is a true and correct copy of excerpts from
`
`Raymond Sims’ trial testimony from the trial in WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.).
`
`23.
`
`Exhibit 2109 is a true and correct copy of PTX 95, an exhibit
`
`that was admitted into evidence during the trial in WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.)
`
`24.
`
`Exhibit 2118 is a true and correct copy of PTX 257, an exhibit
`
`that was admitted into evidence during the trial in WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.)
`
`25.
`
`Exhibit 2119 is a true and correct copy of PTX 315, an exhibit
`
`that was admitted into evidence during the trial in WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.)
`
`
`
`
`5
`
`WESTERNGECO Exhibit 2137, pg. 5
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`
`
`26.
`
`Exhibit 2120 is a true and correct copy of PTX 543, an exhibit
`
`that was admitted into evidence during the trial in WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.)
`
`27.
`
`Exhibit 2121 is a true and correct copy of the jury trial verdict
`
`form in WesternGeco L.L.C. v. ION Geophysical Corp., et al., Civ. No. 4:09-cv-
`
`01827 (S.D. Tex.)
`
`28.
`
`Exhibit 2123 is a true and correct copy of Raymond Sims’ trial
`
`exhibits used during the trial in WesternGeco L.L.C. v. ION Geophysical Corp., et
`
`al., Civ. No. 4:09-cv-01827 (S.D. Tex.)
`
`29.
`
`Exhibit 2124 is a true and correct copy of excerpts from
`
`Kenneth Williamson’s trial testimony from the trial in WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.).
`
`30.
`
`Exhibit 2125 is a true and correct copy of excerpts from
`
`Kenneth Williamson’s trial testimony from the trial in WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.).
`
`31.
`
`Exhibit 2140 is a true and correct copy of excerpts from Charles
`
`Ledet’s trial testimony from the trial in WesternGeco L.L.C. v. ION Geophysical
`
`Corp., et al., Civ. No. 4:09-cv-01827 (S.D. Tex.).
`
`32.
`
`I hereby declare that all statements made herein of my own
`
`knowledge are true and that all statements made on information and belief are
`
`
`
`
`6
`
`WESTERNGECO Exhibit 2137, pg. 6
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`
`
`believed to be true; and further that these statements were made with the
`
`knowledge that willful false statements and the like so made are punishable by fine
`
`or imprisonment, or both, under Section 1001 of Title 18 of the United States Code
`
`and that such willful false statements may jeopardize the results of these
`
`proceedings.
`
`33.
`
`I declare under penalty of perjury under the laws of the United
`
`States of America that the foregoing is true and correct.
`
`
`
`
`August 7, 2015
`New York, New York
`
`
`
`
`
`
`
`
`
`
`
`
`7
`
`WESTERNGECO Exhibit 2137, pg. 7
`PGS v. WESTERNGECO
`IPR2014-01478

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