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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
`___________________________________________________
` Case No. IPR 2016-00407
` U.S. Patent Number 6,545,944
`
` VIDEOTAPED EXAMINATION OF RALPH STEPHEN, Ph.D.
`
` New York, New York
` Friday, November 18, 2016
`
`Reported by:
`JESSICA WAACK, RDR, CRR, CCRR, CCR-NJ, NYACR, NYRCR
`Job No: 115142
`
`TSG Reporting - Worldwide - 877-702-9580
`
`IPR2016-00407
`PGS Exhibit 1023
`PGS v. WG
`
`

`
`Page 2
`
`Page 3
`
` A P P E A R A N C E S
`
`WILLIAMS & CONNOLLY
`Attorneys for the Petitioner
`By: David Krinsky, Esq.
` Sanjiv Laud, Esq.
` Trisha Jhunjhnuwala, Esq.
`725 Twelfth Street Northwest
`Washington, DC 20005
`
`OBLON McCLELLAND MAIER & NEUSTADT
`Attorneys for the Patent Owner
`By: Michael Kiklis, Esq.
`1940 Duke Street
`Alexandria, VA 22314
`
`KIRKLAND & ELLIS
`Attorneys for the Patent Owner
`By: Timothy Gilman, Esq.
` Saunak Desai, Esq.
`601 Lexington Avenue
`New York, NY 10022
`
`ALSO PRESENT:
`Kevin M. Hart, Petroleum Geo-Services, Inc.
`
`Page 5
`
` INDEX TO EXHIBITS
` WITNESS: RALPH STEPHEN, PHD
` Friday, November 18, 2016
` MARKED DESCRIPTION PAGE
`Exhibit 1022 Rendition of figures
` depicted on the right-hand
` side of Figure 1-A and 1-B 28
`
` ** Exhibit attached to original transcript **
`
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` R. STEPHEN, PhD
` Friday, November 18, 2016
` 9:05 a.m.
`
` VIDEOTAPED EXAMINATION OF
`RALPH STEPHEN, PHD, held at the offices of
`Kirkland & Ellis, 601 Lexington
`Avenue, New York, New York, before
`Jessica R. Waack, Registered Professional
`Reporter, Registered Merit Reporter,
`Registered Diplomate Reporter, Certified
`Realtime Reporter, California Certified
`Realtime Reporter, Certified Court Reporter
`in New Jersey, New York Association
`Certified Reporter, New York Realtime Court
`Reporter and Notary Public of the State of
`New York.
`
`Page 4
`
` INDEX TO EXAMINATION
` Friday, November 18, 2016
`WITNESS: RALPH STEPHEN, PHD
`EXAMINATION PAGE
` BY MR. KRINSKY 7
`
` -o0o-
` INFORMATION REQUESTED
` None
`
` WITNESS INSTRUCTED NOT TO ANSWER
` None
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`2 (Pages 2 to 5)
`TSG Reporting - Worldwide - 877-702-9580
`
`IPR2016-00407
`PGS Exhibit 1023
`PGS v. WG
`
`

`
`Page 6
` INDEX TO PREVIOUSLY MARKED EXHIBITS
` WITNESS: RALPH STEPHEN, PHD
` Friday, November 18, 2016
` MARKED DESCRIPTION PAGE
`Exhibit 1001 de Kok patent 9
`Exhibit 1003 Silverman reference 115
`Exhibit 1004 Itria reference 90
`Exhibit 2003 Declaration of 8
` Dr. Stephen
`Exhibit 2009 Silverman patent 166
` referenced in
` Dr. Stephen's
` declaration
`
` --o0o--
`
`Page 8
`
` R. STEPHEN, PhD
` Q. Is there any reason why you can't
` testify fully and truthfully today?
` A. No.
` Q. You're not under the influence of
` alcohol?
` A. Correct.
` Q. Are you on any medication that
` would interfere with your ability to testify?
` A. Not that would interfere with my
` ability to testify, no.
` Q. Okay. I'm going to hand you an
` exhibit that has been previously marked as
` Exhibit 2003.
` This is your declaration, correct?
` A. Yes, that's correct.
` Q. And this is a document that you
` submitted under oath in this proceeding?
` A. Yes, that's correct.
` Q. Turn to page 109.
` A. Excuse me. Yes.
` Q. Is that your signature?
` A. Yes, that is my signature.
` Q. Okay. Are you aware of, sitting
` here right now, of any errors in your
`
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`Page 7
`
` R. STEPHEN, PhD
` November 18, 2016 9:05 a.m.
` R A L P H S T E P H E N
` called as a witness herein,
` having been first duly sworn on
` oath, was examined and
` testified as follows:
` EXAMINATION
` BY MR. KRINSKY:
` Q. Good morning, Dr. Stephen.
` A. Good morning, sir.
` Q. We've met before, but my name is
` David Krinsky.
` Have you been deposed before?
` A. No.
` Q. But you attended the deposition of
` Dr. Lynn, correct?
` A. That's correct.
` Q. So you have a general sense of how
` this works?
` A. Yes.
` Q. I'll be asking questions, and you
` understand that you're obligated to answer
` them truthfully?
` A. Yes.
`
`Page 9
`
` R. STEPHEN, PhD
` declaration testimony that you need to
` correct?
` A. There are about a half dozen
` typographical errors that don't affect the
` substance of the document.
` Q. So nothing substantive that you're
` aware of?
` A. That's correct.
` Q. I'm also going to hand you
` Exhibit 1001, the de Kok patent.
` And you understand that this is
` the patent at issue in this proceeding?
` A. Yes.
` Q. I'd like to direct your attention
` first -- and feel free to refer to your
` declaration whenever you need to --
` A. Thank you.
` Q. -- but I'm going to start by
` focussing on the patent.
` I'd like to turn your attention to
` the figure just on the front of the patent,
` which is -- I guess it's replicated a little
` bit bigger on the next page, Figures 1-A and
` 1-B?
`
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`3 (Pages 6 to 9)
`TSG Reporting - Worldwide - 877-702-9580
`
`IPR2016-00407
`PGS Exhibit 1023
`PGS v. WG
`
`

`
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`Page 10
`
` R. STEPHEN, PhD
` A. Yes.
` Q. And can you just explain at a high
` level what Figure 1-A depicts?
` A. Well, there are two halves to
` Figure 1-A. The left side shows a graph with
` the horizontal axis as time, and the vertical
` axis is depth increasing downward. Time is
` increasing to the right.
` And it shows two circular symbols
` that are intended to represent point sources
` or air guns in a marine environment.
` It shows these sources are two
` depths, D-1 and D-2. The source at D-1 is
` being excited times T-1, which is earlier than
` T-2, which is the time that the source of
` depth of T-2 would be excited.
` And then on the right side, it's
` summarizing how hypothetical wave fronts from
` those two sources would appear on another
` graph that has time still increasing to the
` right, but now the vertical axis is the
` amplitude of the impulse excited by the
` sources.
` Q. Okay. And let me stop you there
`
`Page 12
`
` R. STEPHEN, PhD
` than it already is, Figure 1-A depicts the
` activation of two source elements that make up
` one source, and Figure 1-B depicts the
` activation of two other source elements that
` together make up a second source; is that
` accurate?
` MR. KIKLIS: Objection. Form.
` THE WITNESS: Yes, that's correct.
` BY MR. KRINSKY:
` Q. And I want to focus you on the
` activation of the elements of source -- of the
` first source depicted in Figure 1-A. To be
` clear, the elements of Source 1 are separated
` in depth, but not separated linearly, correct?
` A. As depicted in this diagram, the
` point is they're at two different depths --
` correct? -- and not at different locations
` horizontally.
` Q. The fact that they're depicted in
` the figure horizontally is because one is
` fired after the other, but it is a time axis?
` A. Correct.
` Q. And the activation times of those
` source elements are chosen in this embodiment
`
`Page 11
`
` R. STEPHEN, PhD
` and ask a few specific follow-up questions.
` So what this depicts is the
` activation of one thing, one air gun, for
` example, followed by the activation of another
` air gun that is deeper?
` A. That's correct. I mean, the
` activations are being chosen specifically to
` distinguish -- excuse me.
` The activations are being
` implemented to separate simultaneous sources.
` Q. But the so-called simultaneous
` sources are not the two air guns; these are
` elements of one source?
` A. These are the elements of one
` source, that is correct.
` Q. I think you said "sources" in a
` previous answer. You meant source elements?
` A. A second source is shown in 1-B.
` Q. Right.
` A. So the whole -- the whole picture
` on this page is showing two sources.
` Q. Okay. But just to make sure that
` we are using the same terminology, because
` otherwise this is going to get more confusing
`
`Page 13
`
` R. STEPHEN, PhD
` of the de Kok patent so that the impulses from
` the first source and -- excuse me -- from the
` first source element and the second source
` element constructively interfere?
` MR. KIKLIS: Objection. Form.
` THE WITNESS: Would you repeat the
` question, please?
` BY MR. KRINSKY:
` Q. Sure. That may not have been
` worded well. The downward going energy of the
` two source elements reinforce one another,
` correct?
` A. Yes. Given the delay between T-1
` and T-2 -- correct? -- then they would be
` reinforced.
` Q. Right. In this embodiment, the
` delay between T-1 and T-2 is selected so that
` T-2 -- or, rather, the second source element
` labeled 103 is activated at the same time the
` energy from the first element, 101, arrives at
` the second element?
` A. That's correct.
` Q. And this results in a constructive
` reinforcement of that energy in the downward
`
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`4 (Pages 10 to 13)
`TSG Reporting - Worldwide - 877-702-9580
`
`IPR2016-00407
`PGS Exhibit 1023
`PGS v. WG
`
`

`
`Page 14
`
` R. STEPHEN, PhD
` direction, correct?
` MR. KIKLIS: Objection. Form.
` THE WITNESS: Yes, that's correct.
` BY MR. KRINSKY:
` Q. And looking at the right hand of
` Figure 1-A, the amplitude as a function of
` time, the combined energy in the downward
` direction of sources 101 and 103 corresponds
` to the comparatively large vertical spike at
` TR = 0, correct?
` MR. KIKLIS: Objection. Form.
` THE WITNESS: Yes, that's correct.
` BY MR. KRINSKY:
` Q. What are the two downward going
` spikes in that same figure on the right hand
` of Figure 1-A?
` A. They're the source elements -- the
` wave fronts corresponding to source elements
` 101 and 103 that reflects from the free
` surface.
` Q. In other words, the ghosts?
` A. Yes.
` Q. And the timing of the activation
` of the two source elements is such that the
`
`Page 16
`
` R. STEPHEN, PhD
` well, strike that. Let me ask a predicate
` question.
` The amplitude as a function of
` time graph on the right-hand side of
` Figure 1-A represents in schematic form what a
` receiver would detect given the activation
` depicted on the left-hand side of Figure 1-A.
` Is that --
` MR. KIKLIS: Objection.
` BY MR. KRINSKY:
` Q. -- is that right?
` MR. KIKLIS: Objection. Form.
` THE WITNESS: The diagram on the
` right side of Figure 1-A shows the
` relative time separation between the
` three arrivals, the reinforced ghosts
` and the two unreinforced -- the
` reinforced direct and the two
` unreinforced ghosts at a receiver
` directly below the sources.
` BY MR. KRINSKY:
` Q. At a receiver below the sources?
` A. Yes.
` Q. In this type of seismic surveyor,
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`Page 15
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` R. STEPHEN, PhD
` ghosts arrive at two different times?
` A. That's not correct.
` Q. Why is that not correct?
` A. The times of the two source
` elements is set up to provide constructive
` interference of the downgoing wave spike at
` TR = 0.
` The delay of 2T-1 and 2T-2 you see
` on the right-hand figure is due to the
` propagation time from the source to the free
` surface and back down again.
` There's no control over the timing
` of 2T-1 and 2T-2 -- the number two in front of
` each case.
` MR. KIKLIS: Just a point.
` (Discussion held off the
` record.)
` BY MR. KRINSKY:
` Q. In this particular example, 2T-1
` and 2T-2 are not equal quantities, correct?
` A. That is correct.
` Q. And the energy that went from the
` first source element to the surface then to
` the sea floor and then to the receiver --
`
`Page 17
`
` R. STEPHEN, PhD
` are there receivers that are positioned deep
` in the water underneath the sources?
` MR. KIKLIS: Objection. Form.
` THE WITNESS: So there's perhaps
` some confusion over what's meant by
` "survey" and what they're trying to show
` in the patent.
` In that seismic survey, either on
` land or in marine, there's sources near
` the surface, and then there's typically
` a line or an aerial array of receivers
` also near the surface.
` In this description of the -- in
` the patent -- in this figure that we're
` discussing in the patent, these time
` delays are computed as they would appear
` at an imaginary, fictional receiver
` directly below the sources.
` If the receiver were at the
` surface horizontally separated from the
` surfaces, you wouldn't get this pattern
` of time delays from the direct wave.
` BY MR. KRINSKY:
` Q. I see. You would get a -- what
`
`5 (Pages 14 to 17)
`TSG Reporting - Worldwide - 877-702-9580
`
`IPR2016-00407
`PGS Exhibit 1023
`PGS v. WG
`
`

`
`Page 18
`
` R. STEPHEN, PhD
` pattern of time delays would you see -- or
` would you get?
` A. I haven't been asked to compute
` that.
` Q. Let's move on to Figure 1-B for a
` moment. Figure 1-B, the first source -- well,
` perhaps I shouldn't use the word -- term
` "first," because there is some ambiguity about
` depth.
` But the source labelled No. 7,
` which is the deeper source activated before
` the source element labeled 105 -- and I've now
` bungled enough of this question. Let me just
` start from the beginning.
` The source element labeled 107
` activates before the source element labeled
` 105 on the left-hand side of Figure 1-B,
` correct?
` A. That is correct. There is a delay
` between firing of the source at D-1 and -- D-2
` and the source at D-1. And that enables the
` separation of this source from the source in
` Figure 1-A.
` Q. Right. And the delay time is
`
`Page 20
`
` R. STEPHEN, PhD
` without reflecting off the sea surface, those
` two wave fronts are not reinforcing each
` other, correct?
` A. That is correct.
` Q. And the wave fronts that reach the
` surface and then reflect downwards, those do
` reinforce one another in this example,
` correct?
` A. The delay time between the two
` sources is chosen specifically so that the
` upward propagating energy from these sources
` will coincide at the surface, yes.
` Q. Okay. And the upward going energy
` from source element 107 reaches source element
` 105 at the same time source 105 -- I'm
` sorry -- source element 105 is activated,
` correct?
` A. That is correct.
` Q. And then that constructively
` reinforced wave front reflects off the surface
` and then travels back downwards, correct?
` A. Yes.
` Q. And, at that point, it has a
` negative polarity -- correct? -- after it is
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` R. STEPHEN, PhD
` chosen so that in this case, the upward going
` wave fronts constructively reinforce one
` another, correct?
` A. That is correct.
` Q. And the downward going wave fronts
` are not reinforcing one another, so they
` arrive at two different times, correct?
` A. Your terminology is confusing. I
` don't understand your question.
` Q. Okay. The downward going wave
` fronts from each of these source elements do
` not reinforce one another, correct?
` MR. KIKLIS: Objection.
` THE WITNESS: It's not a
` specific-enough question.
` BY MR. KRINSKY:
` Q. Is the difficulty that you're
` having the difference between a downward
` direct energy source and a downward ghost?
` A. Correct.
` Q. Okay. And I apologize for the
` confusion.
` The direct downward energy going
` from each of these source elements downward
`
`Page 21
`
` R. STEPHEN, PhD
` reflected?
` A. Yes.
` Q. Which is depicted in the right
` side of Figure 1-B as a comparatively larger
` downward spike at TR = 0, correct?
` A. That is correct. And the delays
` that have been introduced between these two
` sources at these different depths are selected
` to change the polarity of the strongest
` downgoing signal to enable source separation.
` Q. Why don't we talk for a moment
` about source separation.
` How are the sources depicted in
` Figure 1-A and 1-B separated in this
` embodiment of de Kok?
` A. Which embodiment are you referring
` to?
` Q. In Figure 1-A and 1-B.
` A. Would you repeat the question,
` please?
` Q. Sure. You referred an answer or
` two ago to the concept that time delay between
` source element 107 and 105 was selected to
` enable the separation of the source depicted
`
`6 (Pages 18 to 21)
`TSG Reporting - Worldwide - 877-702-9580
`
`IPR2016-00407
`PGS Exhibit 1023
`PGS v. WG
`
`

`
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`Page 22
`
` R. STEPHEN, PhD
` in 1-B from the source depicted in 1-A,
` correct?
` I just want to make sure we're on
` the same page.
` A. Yes, that's correct.
` Q. And my question to you is: How
` are the sources then separated?
` MR. KIKLIS: Objection. Form.
` THE WITNESS: So Figure 1-A shows
` one source with two source elements, and
` Figure 1-B shows another source with two
` source elements.
` And that is shown on the
` right-hand side by controlling the
` delays between the firing times of the
` two receivers -- two sources, rather, in
` each case.
` You can change the polarity or the
` direction of particle motion so in
` Figure 1-A you're able to exact positive
` polarity. You can see the largest
` amplitude spike is positive.
` Figure 1-B, the largest amplitude spike
` is negative.
`
`Page 24
`
` R. STEPHEN, PhD
` And once you're able to control
` the polarity of impulsive sources, that leads
` to a methodology for separating those sources
` through -- after multiple firings.
` So, in this case, in Figure 2, the
` right-hand diagram, I chose that S-1,
` Source 1, is -- being fired alternately from
` source transmission to source transmission, is
` first being fired with a positive polarity and
` then with a negative polarity. The P and N
` refer to positive and negative polarities.
` And there's a long sequence of
` source transmissions here, as many as -- a
` large number, 10 or 20 different separate
` transmissions depicted in that figure.
` I'm not finished.
` Q. I apologize.
` A. And Source 2, there's no change in
` polarity. It's always being fired with a
` positive polarity.
` So it's important to understand
` that each of the segments in those two
` diagrams corresponding S-1 and S-2 is a
` complete transmission.
`
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` R. STEPHEN, PhD
` So the insight of de Kok, the
` genius of de Kok's patent is that you
` can control the polarity of the
` downgoing signal by varying the delay
` time -- the delays of the shot times
` between sources at different depths.
` And if you can control the
` polarity, then that leads through other
` figures explained in de Kok to a scheme
` for separating the two sources from one
` another.
` BY MR. KRINSKY:
` Q. When you say that leads through
` other figures explained in de Kok for a scheme
` separating two sources from one another, are
` you referring, for example, to the scheme
` depicted in de Kok's Figure 2?
` A. Yes.
` Q. Can you please explain, for the
` record, de Kok's Figure 2 as it relates to
` your prior answer?
` A. So Figure 1 describes a technology
` that was disclosed by de Kok to control the
` polarity of impulsive sources.
`
`Page 25
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` R. STEPHEN, PhD
` So the time -- they don't indicate
` the time here, but as described in the
` embodiment, the time in a source transmission,
` this is something, like, multiple seconds, 10,
` 20, 30 seconds for each of those blocks.
` So the data from both sources is
` being acquired -- is being acquired at the
` receiver array at the same time.
` So in post-processing, you can
` separate the contributions from -- to a sound
` that's just traveled along paths from S-1 to
` sounds that have just traveled along paths to
` S-2 by summing the receptions from a number of
` separate transmissions.
` So if you just added the
` receptions over a number of those transmission
` sequences, you could see that because S-1 is
` alternating a positive and a negative, that
` you would end up canceling contributions from
` S-1.
` Because S-2 is not changing
` polarity when you add them together, the
` contributions for S-2 would not cancel. In
` fact, they would add. They would
`
`7 (Pages 22 to 25)
`TSG Reporting - Worldwide - 877-702-9580
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`IPR2016-00407
`PGS Exhibit 1023
`PGS v. WG
`
`

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` R. STEPHEN, PhD
` constructively support one another. So that
` lets you separate S-2.
` Then if you alternate -- in
` post-processing, if you alternate the signals
` from the sequential transmissions, so now you
` would take the -- so we could swap those
` signals.
` We could swap for every record
` prior to stacking, you would find that you
` would constructively support S-1 signals while
` destructively eliminating signals from S-2.
` So that lets you separate S-1 from S-2.
` Q. And just to be clear about what's
` depicted in Figure 2, the right-hand side of
` Figure 2 with this series of -- and S-1
` positive and negative transmissions -- this
` square wave that's depicted here isn't
` actually a depiction of a wave that's received
` somewhere; this is a schematic of positive and
` negative polarities alternating, correct?
` A. That's correct.
` Q. And in -- let me focus on the -- a
` signal positive transmission in Figure 2.
` That would correspond to a -- an activation
`
`Page 28
`
` R. STEPHEN, PhD
` elements at different depths, one can control
` the -- and by harnessing the ghost reflection
` from the free surface, one can change the
` polarity of the downgoing energy from the
` sources. And that enables their separation
` through this algorithm.
` Q. So I want to mark as Exhibit 1022.
` (Whereupon, Exhibit 1022 is
` marked for identification.)
` BY MR. KRINSKY:
` Q. So this is a simplified rendition
` of the same types of figures depicted on the
` right-hand side of Figure 1-A and 1-B, and
` what I'm trying to understand is how the two
` sources are fired relative to one another, and
` the elements of those sources are fired
` relative to one another.
` So in the very first left-hand box
` of Figure 2, you have a positive activation of
` Source 1 and a positive activation of
` Source 2, correct?
` Just referring to Figure 2. We'll
` get to my drawing in a moment.
` A. I haven't seen this figure before,
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` R. STEPHEN, PhD
` sequence or source elements of that one source
` akin to the one depicted in Figure 1-A,
` correct?
` MR. KIKLIS: Objection. Form.
` THE WITNESS: Would you mind
` repeating the question?
` BY MR. KRINSKY:
` Q. Sure. I want to focus you on a
` single positive transmission in Figure 2.
` For example, the very top leftmost
` positive square in S-1; are you with me?
` A. Yes.
` Q. That transmission corresponds to
` an activation sequence of the elements of
` Source 1 like that depicted in Figure 1-A?
` A. That's correct.
` Q. And in order to generate a
` negative polarity signal such as the next box
` in that S-1 graph in Figure 2 that is --
` points downward, the source elements of that
` source would activate in the manner depicted
` in Figure 1-B, correct?
` A. That's correct. So that by
` controlling the delays of the two source
`
`Page 29
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` R. STEPHEN, PhD
` and there is no description on it. So by
` commenting on it without some further written
` description, it could be taken out of context.
` I haven't been asked to analyze
` this figure as part of my analysis for the
` declaration.
` Q. That's very nice. My question is
` about Figure 2. I want you to put that down
` for a moment. I'm asking a predicate question
` about Figure 2.
` A. Can you repeat the question,
` please?
` Q. Certainly. In Figure 2, the very
` first activation of Source 1, the leftmost
` activation of Source 1 is positive, correct?
` We discussed that a moment ago.
` A. Yes, that's correct.
` Q. And all the activations for
` Source 2 were positive, correct?
` A. Yes, that's correct.
` Q. And the first activation of
` Source 1 and the first activation of Source 2
` occur at the same time, correct?
` A. That's not correct.
`
`8 (Pages 26 to 29)
`TSG Reporting - Worldwide - 877-702-9580
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`IPR2016-00407
`PGS Exhibit 1023
`PGS v. WG
`
`

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` R. STEPHEN, PhD
` At the scale of this fig- -- I
` mentioned each of those blocks corresponds to
` a time of 10 seconds or up to 30 seconds in a
` typical survey.
` But the actual timing of the
` sources, S-1 and S-2, in order to implement
` this polarity and coding scheme, the firing
` sometimes of the sources have to be -- have to
` be shifted by a very small amount,
` milliseconds, so that the sources are not
` being fired precisely simultaneously.
` And the scale of this figure, it's
` hard to show the change in time of
` milliseconds.
` Q. Why do the firing times of the
` sources have to be shifted by a matter of
` milliseconds in the first activation when both
` are positive?
` A. For the first activation where
` they are both positive, they would not have to
` be separated by milliseconds.
` Q. In the second activation where one
` is positive and one is negative, the
` activation of the negative source elements
`
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` R. STEPHEN, PhD
` A. There is room for confusion here.
` Going back to Figure 1, which I think we were
` discussing at the time you mentioned it --
` Q. Sure.
` A. -- we talked about the delay
` between source elements controlling the
` polarity, and that ultimately it was that
` polarity that enabled the source separation.
` What isn't -- what isn't shown so
` clearly in Figure 1 is that the -- if you're
` firing both sources at the same time, in order
` to make the system work, the TR = 0 of the top
` figure, Figure 1-A, and the TR = 0 at the
` bottom of Figure 1-B have to be at the same
` time on a -- what we were discussing earlier
` as an imaginary receiver directly below the
` source.
` And so the milliseconds shift
` between sources as introduced in order to get
` those times to coincide. And I'm pretty sure
` that clarifies what I said earlier.
` Q. Well, I don't know that it
` entirely does, but we'll -- let me ask some
` more questions, and we'll find out.
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` R. STEPHEN, PhD
` occurs very slightly before the reference time
` TR 0.
` And the activation of the positive
` source occurs -- or the elements of the
` positive source occurs very slightly after
` that TR 0?
` Is that what you mean when they
` have to be separated by milliseconds?
` MR. KIKLIS: Objection. Form.
` THE WITNESS: When you are
` transmitting positive and negative
` polarities in the same transmission from
` two different sources, the timing
` between those two sources has to be
` slightly shifted by a matter of
` milliseconds in order to get the correct
` destruct and construct interference to
` enable the polarity separation.
` BY MR. KRINSKY:
` Q. The polarity separation, Doctor, I
` believe you testified a moment ago was
` performed by summing one activation of a
` source with another activation of the same
` source. That's what cancels, isn't it?
`
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` R. STEPHEN, PhD
` A. Okay.
` Q. I believe you testified earlier
` that in order -- when you separate Source 1
` from Source 2, the separation of Source 1 and
` Source 2 that is enabled by this technique
` occurs across multiple activations of the
` sources, correct?
` MR. KIKLIS: Objection.
` Misstates.
` BY MR. KRINSKY:
` Q. Let's look at Figure 2, again, if
` you will, Doctor. Figure 2 depicts, as we
` discussed earlier, a series of activations of
` those sources, correct?
` A. Yes.
` Q. And I believe you testified
` earlier that in order to separate the sources
` so that we -- t