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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PETROLEUM GEO-SERVICES INC.,
`Petitioner,
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`v.
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`WESTERNGECO, L.L.C.,
`Patent Owner.
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`Case IPR2016-00407
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`Patent No. 6,545,944
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`DECLARATION OF SANJIV P. LAUD
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`IPR2016-00407
`PGS Supplemental Exhibit 1017
`PGS v. WG
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`Pursuant to 28 U.S.C. § 1746, I, Sanjiv P. Laud, hereby declare as follows:
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`1. My name is Sanjiv P. Laud. I am over eighteen years of age, of sound
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`mind, and in all ways qualified and competent to make this declaration. I have
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`personal knowledge of the facts contained in this declaration and they are true and
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`correct.
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`2.
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`I am an associate in the law firm of Williams & Connolly LLP,
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`counsel for Petroleum Geo-Services, Inc. (“PGS”). I am a member in good
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`standing of the Bar of the State of Minnesota and the Bar of the District of
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`Columbia.
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`3.
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`Exhibit 1006 is a true and correct copy of an article by G.C. Smith
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`entitled Three-Dimensional Air Gun Arrays, as it appeared in the 1984 volume of
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`SEG Technical Program Expanded Abstracts, and was downloaded from the SEG
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`(Society of Exploration Geophysicists) website at the following URL:
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`http://library.seg.org/doi/abs/10.1190/1.1893953.
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`4.
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`Exhibit 1019, submitted herewith, is an electronic scanned image of
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`Ex. 1006 as it originally appeared in print. The printed volume bears a copyright
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`date of 1984. Id. at 3. Librarians at Williams & Connolly LLP obtained Ex. 1019
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`from the Geology and Geophysics Library at the University of Wisconsin-
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`Madison.
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`2
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`IPR2016-00407
`PGS Supplemental Exhibit 1017
`PGS v. WG
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`5.
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`Exhibit 1008 is a true and correct copy of a book written by Brian J.
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`Evans and edited by David V. Fitterman and William H. Dragoset Jr. entitled A
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`Handbook for Seismic Data Acquisition in Exploration (1997).
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`6.
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`Exhibit 1009 is a true and correct copy of an article by Bill Pramik
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`entitled Marine Vibroseis: Shaking Up the Industry, as it appeared in the
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`November 2013 issue (Volume 31, Issue 11) of First Break journal, and as
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`accessible on the EAGE (European Association of Geoscientists & Engineers)
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`website at the following URL: http://fb.eage.org/publication/content?id=71796.
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`7.
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`I hereby declare that all statements made herein of my own
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`knowledge are true and that all statements made on information and belief are
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`believed to be true; and further that these statements are made with the knowledge
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`that willful false statements and the like so made are punishable by fine or
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`imprisonment, or both, under Section 1001 of Title 18 of the United States Code
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`and that such willful false statements may jeopardize the results of these
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`proceedings.
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`I declare under penalty of perjury under the laws of the United States of
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`America that the foregoing is true and correct.
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`Date: August 2, 2016
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`By:
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`Sanjiv P. Laud
`Williams & Connolly LLP
`725 Twelfth St. NW
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`3
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`IPR2016-00407
`PGS Supplemental Exhibit 1017
`PGS v. WG
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`Washington, DC 20005
`Phone: 202-434-5279
`Facsimile: 202-434-5029
`E-mail: slaud@wc.com
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`4
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`IPR2016-00407
`PGS Supplemental Exhibit 1017
`PGS v. WG
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