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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 IPR2014-01478
`
`Patent 7,293,520
`
`____________
`
`
`
`PATENT OWNER WESTERNGECO L.L.C.’S
`RESPONSES TO PETITIONER’S OBJECTIONS TO EVIDENCE DATED
`AUGUST 14, 2015 AND SUPPLEMENTAL EVIDENCE
`
`
`WESTERNGECO Exhibit 2161, pg. 1
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`WESTERNGECO L.L.C.
`Case IPR2014-01478
`U.S. Patent 7,293,520
`Responses to Objections to Evidence and Supplemental Evidence
`
`
`
`In response to Petitioner’s August 14, 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 2053: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman.1
`
`
`
`Exhibit 2075: Patent Owner submits that Dr. Triantafyllou, the Director of
`
`the Center for Ocean Engineering at MIT, has over 35 years of experience
`
`researching cable mechanics, the hydrodynamics of marine cables, and the control
`
`of marine systems. Dr. Triantafyllou has spent decades studying, researching and
`
`teaching about the mechanics of cables through the water, which includes
`
`streamers and towed arrays, and published over a dozen papers on this topic. See,
`
`e.g., Exhibit 2075, ¶¶ 1-11; Appendix A. Additionally, Dr. Triantafyllou has
`
`published multiple papers on the control of marine systems and Kalman filtering
`
`techniques. Id.
`
`Exhibit 2103: Patent Owner provides Exhibits 2149 and 2150.
`
`
`
`Exhibit 2104: Patent Owner provides Exhibit 2151.
`
`Exhibit 2105: Patent Owner provides Exhibits 2152 and 2153.
`
`
`1 The Second Declaration of Timothy K. Gilman is Exhibit 2148 to this
`proceeding.
`
`
`
`1
`
`WESTERNGECO Exhibit 2161, pg. 2
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`WESTERNGECO L.L.C.
`Case IPR2014-01478
`U.S. Patent 7,293,520
`Responses to Objections to Evidence and Supplemental Evidence
`
`
`Exhibit 2107: Patent Owner provides the Second Declaration of Timothy
`
`
`
`K. Gilman.
`
`
`
`
`
`
`
`Exhibit 2109: Patent Owner provides Exhibit 2154.
`
`Exhibit 2116: Patent Owner provides Exhibit 2155.
`
`Exhibit 2117: Patent Owner provides the Second Declaration of Timothy
`
`K. Gilman and Exhibits 2150, 2156, 2157, 2158, and 2159.
`
`
`
`Exhibit 2119: Patent Owner provides Exhibit 2160.
`
`Exhibit 2120: Patent Owner provides Exhibit 2155.
`
`
`
`
`
`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: August 28, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`2
`
`WESTERNGECO Exhibit 2161, pg. 3
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`
`
`
`
`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: August 28, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`WESTERNGECO Exhibit 2161, pg. 4
`PGS v. WESTERNGECO
`IPR2014-01478

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