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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`PETROLEUM GEO-SERVICES INC.,
`Petitioner,
`
`v.
`
`WESTERNGECO, L.L.C.,
`Patent Owner.
`
`
`
`Case IPR2016-00407
`
`Patent No. 6,545,944
`
`
`
`SUPPLEMENTAL DECLARATION OF WALTER S. LYNN, PH.D.
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`
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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 1018
`PGS v. WG
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`
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`Pursuant to 28 U.S.C. § 1746, I, Walter S. Lynn, hereby declare as follows:
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`1.
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`My name is Walter S. Lynn. I am over eighteen years of age, of
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`sound mind, and in all ways qualified and competent to make this declaration. I
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`have personal knowledge of the facts contained in this declaration and they are true
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`and correct.
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`2.
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`I am a Geophysicist specializing in the field of reflection seismology,
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`especially in relation to oil and gas exploration. I am currently the Chief Operating
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`Officer and co-owner of Lynn Inc., a privately-owned independent consulting firm
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`which specializes in multi-azimuth, multi-component, and three-dimensional (3D)
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`seismic acquisition, processing, and interpretation. In addition, I am an Adjunct
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`Professor at the Colorado School of Mines, where I teach a graduate-level course
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`entitled “Seismic Data Processing” each fall semester. As an adjunct professor, I
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`have served on numerous thesis M.S. and Ph.D. committees for students pursuing
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`their master’s and doctorate degrees in the fields of reflection seismology and
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`reservoir characterization.
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`3.
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`I have been a member of the Society of Exploration Geophysicists
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`(“SEG”) for over 40 years (since 1973), and am currently an Honorary Member of
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`SEG. SEG is the largest professional association for exploration geophysics in the
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`world. I was elected President-elect of SEG in 2000 and served as President from
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`September 2001 through October 2002. During this time, SEG had over nineteen
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`2
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`IPR2016-00407
`PGS Supplemental Exhibit 1018
`PGS v. WG
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`
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`thousand members. As President of SEG, I represented SEG worldwide and
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`worked extensively with regional SEG affiliates and with other professional
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`societies in geophysics around the globe.
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`4.
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`I am personally familiar with the series of publications entitled SEG
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`Technical Program Expanded Abstracts (“Expanded Abstracts”). Expanded
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`Abstracts is a print series containing expanded versions of technical papers
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`presented by their authors at SEG’s yearly conferences. Printed volumes of
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`Expanded Abstracts are made publicly available and can be found in the libraries
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`of academic institutions, corporations, and individuals, as well as SEG’s on-line
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`digital library (http://library.seg.org). During the 1980s, including in 1984, printed
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`volumes of Expanded Abstracts were prepared before each conference and
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`distributed to all attendees who registered to attend the technical lectures. Any
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`member or non-member of SEG who wished to register to attend lectures could do
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`so. After each annual SEG conference, the Expanded Abstracts were available for
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`purchase at the SEG bookstore for several years.
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`5.
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`Exhibit 1006 is an article by G.C. Smith entitled Three-Dimensional
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`Air Gun Arrays that appeared in the 1984 volume of Expanded Abstracts according
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`to the SEG library website (http://library.seg.org/doi/abs/10.1190/1.1893953). I
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`believe that, consistent with the SEG’s established practice, Ex. 1006 was publicly
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`3
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`IPR2016-00407
`PGS Supplemental Exhibit 1018
`PGS v. WG
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`
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`available, disseminated to people in the field, and available to a person of ordinary
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`skill in the art no later than 1984.
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`6.
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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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`
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`By: _________________________
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`Dr. Walter S. Lynn
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`4
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`IPR2016-00407
`PGS Supplemental Exhibit 1018
`PGS v. WG
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