`________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`IN-DEPTH GEOPHYSICAL, INC. AND
`IN-DEPTH COMPRESSIVE SEISMIC, INC.
`Petitioners,
`
`v.
`
`CONOCOPHILLIPS COMPANY,
`Patent Owner.
`______________________
`
`Case IPR2019-00849
`
`Patent 9,632,193
`
`_____________________________________________________________
`
`DECLARATION OF RICK L. RAMBO
`
`Page 1
`
`ConocoPhillips Company COP-2001,
`In-Depth Geophysical, Inc. and
`In-Depth Compressive Seismic, Inc.
`v. ConocoPhillips Company
`Case IPR2019-00849
`
`
`
`IPR2019-00849
`Patent No. 9,632,193
`
`I, Rick L. Rambo, hereby declare as follows:
`
`1. I am over 18 years of age and personally competent to make this declaration,
`
`having personal knowledge of all facts set forth herein.
`
`2. My name is Rick L. Rambo. I am currently a partner with Morgan, Lewis &
`
`Bockius L.L.P., counsel of record for Patent Owner.
`
`3. Attached as Exhibit COP-1002 is the Certified Letter sent by me to
`
`Petitioners’ Counsel on March 14, 2018, regarding “Service of Process of In-Depth
`
`compressive Seismic, Inc. and In-Depth Geophysical, Inc.,” including the Certified
`
`Mailing Article Number 9414 7266 9904 2108 4731 25 and the Return Receipt
`
`Request bearing Return Receipt Barcode 9590 9266 9904 2104 9730 11.
`
`4. Attached as Exhibit COP-1003 are the exhibits included with Certified
`
`Letter to Petitioners’ Counsel, including
`
`i. ECF 001, Original Complaint and Req for Prel and Perm Injunction;
`
`ii. ECF 001-2, Original Complaint and Req for Prel and Perm
`
`Injunction, Ex 1 (U.S. Patent No. 8,897,094);
`
`iii. ECF 001-3, Original Complaint and Req for Prel and Perm
`
`Injunction, Ex 2 (U.S. Patent No. 9,632,193);
`
`iv. ECF 001-4, Original Complaint and Req for Prel and Perm
`
`Injunction, Ex 3 (U.S. Patent No. 9,823,372);
`
`1
`
`Page 2
`
`ConocoPhillips Company COP-2001,
`In-Depth Geophysical, Inc. and
`In-Depth Compressive Seismic, Inc.
`v. ConocoPhillips Company
`Case IPR2019-00849
`
`
`
`IPR2019-00849
`Patent No. 9,632,193
`
`v. ECF 001-5, Original Complaint and Req for Prel and Perm
`
`Injunction, Ex 4 (U.S. Patent No. 9,846,248);
`
`vi. ECF 002, ConocoPhillips Corporate Disclosure Statement;
`
`vii. ECF 003, Summons as to In-Depth Compressive Seismic; and
`
`viii. ECF 003, Summons as to In-Depth Geophysical, Inc.
`
`5. Attached as Exhibit COP-1004 is the Return Receipt signed by A. Rendon at
`
`Petitioners’ Law Firm, dated March 15, 2018, Return Receipt Barcode 9590 9266
`
`9904 2104 9730 11.
`
`6. Attached as Exhibit COP-1005 is Letter from Petitioners’ Counsel, dated
`
`October 30, 2017, and directed to me, indicating that Petitioners’ Counsel had been
`
`retained by Petitioners, and to “direct all future correspondence to my direction.”
`
`7. Attached as Exhibit COP-1006, are Joint Appendix Pages A301-A306,
`
`presented in the PTAB Appeal for IPR2013-00312.
`
`8. I also note that Petitioners, as Defendants in the District Court litigation,
`
`never challenged service or indicated that it was ineffective or improper.
`
`Petitioners never made any arguments regarding defects in service in a motion
`
`under Rule 12 of the Federal Rules of Civil Procedure, in any other responsive
`
`pleading, or in an amendment allowed by Rule 15(a)(1) of the Federal Rules of
`
`Civil Procedure.
`
`2
`
`Page 3
`
`ConocoPhillips Company COP-2001,
`In-Depth Geophysical, Inc. and
`In-Depth Compressive Seismic, Inc.
`v. ConocoPhillips Company
`Case IPR2019-00849
`
`
`
`IPR2019-00849
`Patent No. 9,632,193
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Further, these statements are made with the knowledge that willful false statements
`
`are punishable by fine or imprisonment, or both, under Section 1001 of Title 18 of
`
`the 246 United States Code.
`
`Dated:
`
`June 26, 2019
`
`z,,,-- _____ z_, z----,
`
`Rick L. Rambo
`
`3
`
`Page 4
`
`ConocoPhillips Company COP-2001,
`In-Depth Geophysical, Inc. and
`In-Depth Compressive Seismic, Inc.
`v. ConocoPhillips Company
`Case IPR2019-00849
`
`
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