`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF TEXAS
`HOUSTON DIVISION
`
`
`WESTERNGECO LLC, . 4:09-CV-01827
` . HOUSTON, TEXAS
`PLAINTIFF, .
` .
` vs. .
` .
`ION GEOPHYSICAL .
`CORPORATION, FUGRO GEOTEAM, .
`INC., ET AL, .
` .
`DEFENDANTS . JULY 24, 2012
`. . . . . . . . . . . . . . . 7:37 A.M.
`
`
`TRANSCRIPT OF JURY TRIAL
`BEFORE THE HONORABLE KEITH P. ELLISON
`UNITED STATES DISTRICT JUDGE
`
` A
`
`
`
`
`
` P P E A R A N C E S:
`
`FOR THE PLAINTIFF:
`
`Lee K. Kaplan
`SMYSER KAPLAN & VESELKA LLP
`Bank of America Center
`700 Louisiana, Suite 2300
`Houston, Texas 77002
`Gregg F. LoCascio
`KIRKLAND & ELLIS LLP
`655 Fifteenth Street Northwest
`Washington, DC 20005
`Sarah Tsou
`Timothy K. Gilman
`KIRKLAND & ELLIS LLP
`Citigroup Center
`153 East 53rd Street
`New York, New York 10022
`
`
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 1
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`APPEARANCES - CONTINUED
`
`
`FOR THE DEFENDANT:
`
`David L. Burgert
`Susan Kopecky Hellinger
`Jonathan M. Pierce
`Jonna N. Stallings
`Ray T. Torgerson
`Eric D. Wade
`PORTER & HEDGES LLP
`Reliant Energy Plaza
`1000 Main Street, 36th Floor
`Houston, Texas 77002
`
`
`FOR FUGRO GEOTEAM, INC.:
`
`Gordon T. Arnold
`Jason A. Saunders
`ARNOLD KNOBLOCH LLP
`4900 Woodway Drive
`Suite 900
`Houston, Texas 77056
`James M. Thompson
`Christine Raborn
`Michael E. Streich
`ROYSTON RAYZOR VICKERY & WILLIAMS LLP
`Pennzoil Place
`711 Louisiana Street, Suite 500
`Houston, Texas 77002
`
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`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 2
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`APPEARANCES - CONTINUED
`
`
`
`OFFICIAL COURT REPORTER:
` Mayra Malone, CSR, RMR, CRR
` U.S. Courthouse
` 515 Rusk, Room 8016
`Houston, Texas 77002
`
`Proceedings recorded by mechanical stenography. Transcript
`produced by computer-aided transcription.
`- - - - -
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`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 3
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`INDEX
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`THOMAS SCOULIOS
`
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`Cross-Examination by Mr. Burgert
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`Cross-Examination by Mr. Thompson
`
`Continued Direct Examination by THOMAS SCOULIOS
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`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 4
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`MR. LOCASCIO: We will. Under the Rule, he's
`outside so if I may go outside and --
`THE COURT: Yes. Please retrieve him or her.
`THE WITNESS: Can I bring all this down?
`THE COURT: Yes, you may take all that. Thank
`you very much.
`THE WITNESS: Thank you, Your Honor.
`THE COURT: May this witness remain in the
`courtroom, or is he still subject to the Rule.
`MR. LOCASCIO: He may. He's the corporate
`representative, so he will. Thank you, Your Honor.
`THE COURT: Sir, if you could make your way up
`
`this way.
`
`MR. LOCASCIO: Thank you, Your Honor.
`THE COURT: We're going to have you in the seat
`nearest me right here.
`Before you take your seat, sir, Mrs. Loewe
`will administer the oath, if you would raise your right
`hand, please.
`CASE MANAGER: Do you solemnly swear that the
`testimony you are about to give in the matter now before
`the Court will be the truth, the whole truth and nothing
`but the truth?
`THE WITNESS: I do.
`THE COURT: Try to make yourself comfortable in
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 5
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`that chair. It's not the most comfortable.
`MR. LOCASCIO: Your Honor --
`THE COURT: Try to speak directly into the
`
`mike.
`
`MR. LOCASCIO: -- my colleague, Mr. Mr. Gilman
`will be examining t his witness.
`THE COURT: Very well.
`THE COURT: You may proceed.
`MR. GILMAN: May it please the Court, ladies
`and gentlemen. My name is Timothy Mr. Gilman, and I'm here
`also representing WesternGeco. And as our next witness, we
`are calling Dr. Simon Bittleston. Dr. Bittleston is the
`head of all research for WesternGeco and for Schlumberger
`as well. He's also the inventor of three -- or one of the
`inventors of three out of the four patents that we're
`talking about today, the patents that we often refer to as
`the Bittleston patents, and he's here with us today to
`testify about what those patents are and the technology
`they cover and also the work he did that led up to those
`patents.
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 6
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`Direct-Bittleston/By Mr. Gilman
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`495
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`SIMON BITTLESTON,
`after having been first cautioned and duly sworn, testified
`as follows:
`
`DIRECT EXAMINATION
`
`BY MR. GILMAN :
`Good morning, Dr. Bittleston.
`Q.
`A.
`Good morning.
`Could you please introduce yourself to the jury.
`Q.
`A.
`My name is Simon Bittleston. I work for Schlumberger
`I've worked for Schlumberger for 26 years. And for nine
`of those years, from 1990s, I worked for -- I worked for
`WesternGeco -- it was called Geco-Prakla at that time --
`in Norway. And while I was in Norway, I was working on
`all the sorts of systems.
`What is your position today, Dr. Bittleston?
`Q.
`A.
`I'm vice-president of research for Schlumberger,
`which also includes research for WesternGeco.
`And what types of research do you oversee?
`Q.
`A.
`So the research covers all of Schlumberger's
`activities. Schlumberger is a very large organization.
`We have 16 different business units, of which one is
`WesternGeco. And so, the research covers all of those
`different activities.
`In fact, Schlumberger spends on research
`and productive elements about a $1 billion a year, and the
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 7
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`Direct-Bittleston/By Mr. Gilman
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`496
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`research portion of that is about 140 million, so that's
`what I cover.
`And where do you conduct all this research?
`Q.
`A.
`So the research is covered in about six main research
`centers. The largest of those is in Boston, next to MIT,
`where we have about 140 scientists. The next sized one is
`in Cambridge in England, where we have about 120
`scientists. And then the others are based in Moscow,
`Stavanger, Rio and some other places.
`How many total scientists do you have working
`Q.
`underneath you?
`A.
`About 400 in the research organization.
`What is your role in charge of overseeing all these
`Q.
`scientists?
`A.
`So the lab directors report to me, and I'm
`responsible for making sure that the right work is being
`done in the right research labs and also to interact with
`the business units a lot to make sure that we are
`addressing their needs.
`What is your connection to WesternGeco? I think you
`Q.
`started to describe this earlier.
`A.
`So I went to Norway -- I was invited to go to Norway,
`moved from Cambridge to Norway in 1993. So I started
`working for what was Geco-Prakla as it was then, but
`WesternGeco now, in 1993. And I worked all the way
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 8
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`
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`Direct-Bittleston/By Mr. Gilman
`
`497
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`through to 1999 when I left Norway. So in that period, I
`was working for WesternGeco.
`What is your specific connection to this case?
`Q.
`A.
`So in this case, the number of patents I did, the
`three of them I have my name on. I'm a joint inventor
`with a chap called Oyvind Hillesund that I worked with,
`and those patents have been asserted.
`How many total patents are you an inventor on?
`Q.
`A.
`So U.S. patents, a bit less than 20. And then for
`the rest of the world, probably another 30. So that's my
`total.
`What types of inventions do your patents cover?
`Q.
`A.
`Well, the first patent I ever made was for -- in
`fact, it was for King Oil Wells, using multiphase flows,
`in that water in there. And then a lot of the patents,
`quite a few of the patents are associated with the systems
`we're going to talk about now. And then I have some
`others associated with sampling of down hole fluids,
`that's getting samples of oil and gas in the bottom of the
`well when you're drilling.
`Let's turn to the three patents of yours that are at
`Q.
`issue today.
`A.
`Yes.
`What technology do those patents cover?
`Q.
`A.
`So those patents cover really looking after handling
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 9
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`Direct-Bittleston/By Mr. Gilman
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`498
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`the whole of a streamer and a spread on how you control
`all of the cables in the water. And it might be useful
`just to first look at the scale of the problem, which
`is -- tried to illustrate it here a little bit.
`I think this is Bittleston Demonstrative 1 that's
`Q.
`next to you.
`A.
`Okay.
`Can you describe, yeah, what this is showing?
`Q.
`A.
`So this is showing such a streamers being today
`behind the vessel, and these streamers are about four and
`a half miles long. In fact, you can have systems of
`streamers which go up to about six miles long. So this
`isn't the longest possible.
`And just to give you a sense of scale,
`down at the bottom there, you can hardly see it, is a
`Boeing 747, which is about 231 feet long. Then there's
`the JPMorgan Chase Tower, which is the biggest tower in
`Houston which is next to it, a thousand feet high. And
`then this is the Guadalupe Peak, which is tallest peak in
`Texas, which is 8,700 feet.
`So you can see the system is very huge,
`and the task here is to try and control all of these
`cables at the same time. So it's really a huge task. So
`the patents cover different aspects of controlling that.
`In order to control this, it's not enough
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 10
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`Direct-Bittleston/By Mr. Gilman
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`499
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`just to maneuver the boat or the cable at the top of the
`headers, streamers, all at the tail, for that matter. But
`you have to actually put some loads and forces distributed
`over the different cables. So these cables -- I don't
`know if it's been described to you -- they're about two
`inches in diameter. They have a lot of electronics in
`them, and they're basically neutrally buoyant in water.
`So over this spread, you may have a couple
`of hundred of these birds, as they're called, streamer
`steering devices, which allow you to move the streamers
`sideways and vertically. At each points they're placed
`along the streamer, and they're placed uniformly spaced on
`the streamers.
`
`So the patents cover how you go about
`doing that. If you've got more than 200 airplanes to fly
`at the same time, you're not going to do it manually by
`giving instructions to each of the planes, and so, one of
`the patents is associated with how you can get give high
`level commands in order to tell all of these airplanes
`what to do at the same time and get them in the right
`position. So those are different strategies either
`keeping the cables parallel to each other, certain
`separation, or keeping them at a certain angle to the
`direction of the boat, or also, you can give them other
`commands in order to make sure that they don't tangle and
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 11
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`Direct-Bittleston/By Mr. Gilman
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`things like this.
`So in addition, the problem here is that
`each of the birds doesn't know where everything else is.
`The only place where you know where everything in water
`is, is on the vessel where you've got the navigation data
`and all the information about where all the cables are.
`So on the vessel, you need a controller, and in each of
`the birds, there's a little computer so they're quite
`intelligent in that way, and so, you can send commands
`from the boat to each of the birds to tell them what to
`do. So that means that you need split the control system
`between a global control system, which is the one on the
`boat that has all the navigation data, and the local
`control system, which at the birds.
`And there's one other aspect of the
`patents which is very important, which is that, in order
`to work out where everything is in the water, we have to
`actually take a set of what's called acoustic ranges.
`What we do is we make a little sound on one of the cables,
`we receive it on another cable, and that gives us the
`distance between two cables by the time it took the sound
`get from one cable to the other cable. And we do about
`800, up to 800 of those ranges, and we do it every 10
`seconds. And that's a lot of information to process. So
`it takes a bit of time before we actually work out where
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 12
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`Direct-Bittleston/By Mr. Gilman
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`501
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`all the cables were in the water because we have to
`process all this information.
`And in that time, everything's been
`moving. This is very dynamic. Everything is moving. And
`so, what we have to do we have to predict forward during
`period where we're doing the calculations what -- how --
`where the cables now are. So one of the patents is about
`predicting forward so that you know where the cables are
`so you can give it the right commands to do what you need
`to do next. So those are basically what it covers.
`So I think it makes sense to take a look at these
`Q.
`specific patents.
`A.
`Yes.
`
`MR. GILMAN: Your Honor, may I approach the
`
`witness?
`
`THE COURT: You may. You can approach your own
`witnesses without asking.
`MR. GILMAN: Thank you, Your Honor.
`BY MR. GILMAN:
`I'm handing you a collection of exhibits for today.
`Q.
`MR. GILMAN: And I believe that the jury has
`the copies of your patents as Patent Numbers 1 through 3 in
`their notebooks as well.
`BY MR. GILMAN:
`Dr. Bittleston, could you turn to Plaintiff's
`Q.
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 13
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`Direct-Bittleston/By Mr. Gilman
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`502
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`Exhibit 1?
`
`THE COURT: Dr. Bittleston, where are you
`located now? Cambridge or Boston or --
`THE WITNESS: Cambridge in England, yes.
`THE COURT: Could you briefly trace your
`education for me.
`THE WITNESS: Yes, Your Honor. So I was
`educated in England, I went to university at Imperial
`College in London, which is like the MIT, I guess, of the
`UK. And then so, I did my bachelor's there, and I did my
`Ph.D. in Bristol, which is the west coast of the UK. I did
`that Ph.D. in fluid mechanics, which is working out the
`flow of fluids over various objects.
`In fact, my Ph.D. was on flows past groups
`of cylinders. The application was dialysis machines to try
`and make better ways to remove waste products from the
`blood.
`
`And after I done my Ph.D., I moved to
`Schlumberger Cambridge Research, which is in Cambridge,
`which is actually where I am now based again, and I started
`working as a scientists in Cambridge.
`THE COURT: What is your degree in as an
`
`undergrad?
`
`THE WITNESS: Mathematics.
`THE COURT: Thank you.
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 14
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`Direct-Bittleston/By Mr. Gilman
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`THE WITNESS: All right.
`BY MR. GILMAN:
`I'd like to hear before the story that led to your
`Q.
`inventions too.
`
`Before we jump into how your research took
`you there, maybe we can start with a high level
`description of your patents.
`A.
`Okay.
`If you could turn to Plaintiff's Exhibit 1, which
`Q.
`should be behind?
`A.
`Yes, I'm there.
`Which -- what document is Plaintiff's Exhibit 1?
`Q.
`A.
`So this is the '520 patent, which is a patent which
`is associated with controlling all of these cables. And
`this particular patent is mainly concerned with the
`different control modes that you can have.
`MR. GILMAN: Pull up Exhibit 1, please.
`BY MR. GILMAN:
`Let's take a look at cover of the patent to begin
`Q.
`with.
`
`How do you know that this is one of your
`
`patents?
`A.
`So it's on the -- this page here, if I can put it up
`like this, it says, "Inventors: Oyvind Hillesund, Simon
`Hastings Bittleston, so that's me.
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 15
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`Direct-Bittleston/By Mr. Gilman
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`504
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`BY MR. GILMAN:
`So who is Mr. Hillesund?
`Q.
`A.
`So Oyvind worked with please in Norway. He was part
`of the streamer team, so he was one of my staff.
`If you look under the list of both of your names as
`Q.
`inventors, it says "Assignee, WesternGeco"?
`A.
`Yes.
`What does that mean?
`Q.
`A.
`It means that WesternGeco has taken the device of
`these patents because, when I joined the company, when
`Oyvind joined the company, we signed something saying that
`any inventions we made were going to be owned by the
`company, not by us, so they're the owners.
`If we move up a little bit, there's the title of a
`Q.
`patent.
`
`What does that refer to?
`A.
`So the title here is just a summary title of the
`patent. It's "Control System for Positioning of a Marine
`Seismic Streamer."
`And if we see in the upper right-hand corner, we know
`Q.
`that this is your '520 patent that we've talked about
`today.
`A.
`Yes.
`When did this patent issue from the U.S. Government?
`Q.
`A.
`It says just below it, it's 13th of November, 2007.
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 16
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`Direct-Bittleston/By Mr. Gilman
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`505
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`On the left side towards the bottom, there's a
`Q.
`section titled "References cited."
`What does that mean?
`A.
`So these are other documents of the patents where --
`have some relevance to this patent which the U.S.
`examiners will have looked at in order to see if this
`patent is unique or not.
`If we look at this list on that page and onto the
`Q.
`following page, how many references were considered by the
`U.S. Patent Office?
`A.
`I'm sorry. I didn't add up the total here, but I
`guess it's more than 20 or so, yeah.
`If we turn one page further in to the patent
`Q.
`document, we get to Figure 1 of your patent.
`A.
`Yeah.
`Could you describe what's being shown here in
`Q.
`Figure 1?
`A.
`So in Figure 1, we've got a set of streamers in the
`water, and we've got a few items which are marked on them.
`The items marked 18 are the positions where the birds are
`going to be.
`
`The items marked 16 are something called
`monowings. Monowings are the big wings in the front of
`the extreme which pull the front, these front cables
`sideways. They need to be quite a bit bigger because
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 17
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`
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`Direct-Bittleston/By Mr. Gilman
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`506
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`you've got a lot of force there.
`The Item Number 14 is actually the
`airguns. So that's where we make a bang -- sound bang
`every 10 seconds. That sound propagates through the earth
`and comes back reflected from underneath the earth and
`actually hits all the streamers, that sound wave, and we
`measure it with microphones, hydrophones, on all of these
`streamers. And that's the whole purpose is to actually
`make an image of the subsurface.
`10 is the boat and 20 is the tail buoy, and
`12 is the streamers in between.
`How big is this spread of streamers that's shown in
`Q.
`Figure 1?
`A.
`Well, this is just eight streamers wide, so it would
`probably be less than half a mile wide. And this length
`here, I guess, is quite short compared to that length that
`we've got up there.
`How long can these streamers arrays get to be?
`Q.
`A.
`They go up to -- up to six miles today. There are
`plans to go even further. There are reasons we want them
`to be even longer.
`Figure 1 is the overall streamer array.
`Q.
`What are you showing in Figure 2 of your
`patents on the next page?
`A.
`So Figure 2 is the particular birds' embodiment that
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 18
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`Direct-Bittleston/By Mr. Gilman
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`we chose to make. This is a two-wing bird. You can see
`the two wings there marked 28, and they're attached to a
`stiff center body by some wing routes, 32, and then
`there's some motor drivers, one for each wing, 34. That
`means the wings act actually independently of each other.
`And then at the heads and tail, you have some bits of
`streamer, in fact, some short sections of flexible.
`That's flexible parts. So it's just the center part
`that's stiff. And there are other components in that
`streamer, things like spaces.
`And the point about this bird is how it
`works, which I think, as you can get a bit feel from here,
`is that if you're just flying horizontally, you just move
`the wings up and down together; but if you want to suddenly
`go vertically, move the streamers sideways, what you do is
`you just put them slightly at a different angle. That's
`called a splay angle. And that rotates the whole thing.
`So it start to go like that. It's like an airplane banking
`around the corner. And then you put them in the right
`position and then they'll pull the streamers sideways. And
`by doing something in between, you can control both the
`sideways movement and the depth movement at the same time.
`So it's really quite like a plane in terms of the way in
`which it moves.
`How many of these planes would be on a given streamer
`Q.
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 19
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`Direct-Bittleston/By Mr. Gilman
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`508
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`array?
`A.
`So a couple of hundred is a very typical number. It
`can be more or less than that.
`If we look, then, down at Figure 3, what are you
`Q.
`showing here in Figure 3?
`A.
`In Figure 3, what we have here is an explanation of
`how this thing is going to respond to a command. What
`we've got is a bird. The bird wings are now marked 28
`again, you can see, with a center body 30. So that
`corresponds to the numbers above. So you can see it's at
`an angle. The streamers are actually going out of the
`page here. You're looking end on to it. And what's being
`asked for from the vessel is that it says, I want to move
`a horizontal force, which is marked by the horizontal
`arrow marked Number 42, and the vertical force which is
`marked by the vertical arrow 44.
`So you can actually add that force up, and
`you get -- the total force that's needed is the force
`marked 46. So that's the angle. So that's how much we're
`going to have to push in that direction.
`Now, the bird as it's sitting isn't quite
`pointing in this case direction. It's pointing along the
`long line marked along 52. And so, what we do is we start
`to push along that line marked 52, but then we put a
`little bit difference in the angles of the wings, and we
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 20
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`Direct-Bittleston/By Mr. Gilman
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`509
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`realign the birds so that this line matches up with the
`Line 46. So it starts just turning a little bit, in this
`case, so that it's lined up with 46, and we change
`actually the total force so it matches the arrow 46. So
`it's explaining how to go from one position to another.
`Dr. Bittleston, did you invent the idea of trying to
`Q.
`put a lateral force on a cable?
`A.
`No, I did not. There are many devices. I mentioned
`the monowing, which was before this, and other people had
`thought of trying to move cable sideways.
`Did you invent the idea of trying to use a device to
`Q.
`move one of these streamers?
`A.
`I invented a particular embodiment, a particular
`device, to move streamers sideways, which was a tooling in
`a natural bird which had independent wings.
`Is that the subject matter of these patents in suit?
`Q.
`A.
`No, this is actually not the subject at all, although
`there's a patent about it. The subject matter is about
`not any particular device, I've shown you one particular
`device. It's actually about how the move the whole thing
`together. It's irrelevant respective of which device is
`on the cables. These patents have nothing to say about
`which device is on the cable, just that there are devices
`that can move them, and they explain how to go about
`managing a couple of hundred of these birds at the same
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 21
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`
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`Direct-Bittleston/By Mr. Gilman
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`510
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`time. That's what the whole point is really.
`If you turn to Figure 4, what aspect of your
`Q.
`invention is this showing?
`A.
`So in Figure 4, we've got a block diagram. It shows
`you the main parts of a local controller. So I mentioned
`before that part of the patents is to have some
`intelligence on the boat, some brains on the boat for
`the -- where everything is in the water; and each of the
`birds, it has it's own little computer. And here you can
`actually see it. And the little computer in the bird,
`it's called a processor unit, which is marked 54. But
`importantly, we're going to need to move two wings, and
`so, you can see marked 34 a motor left wing and a motor
`right wing. And in order for those motors to do the right
`thing, they have a motor driver each. So you can see
`that's how the two wings are driven.
`And we need to know where they are. So
`after we've moved them, we have a position indicator
`marked 64. And so, that gives feedback so that we can
`actually know what to do next.
`There are a few other measurements here.
`There's a pressure sensor. So as you go deeper in the
`water, the pressure goes up. You get that when you go
`swimming, your ears pop. And so, if you have pressure
`sensors, you can work out approximately how deep you are,
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 22
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`
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`Direct-Bittleston/By Mr. Gilman
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`approximately. And then there is a -- on the top right
`marked 17, you've got a vertical accelerometer, horizontal
`accelerometer at 10 percent. So --
`THE COURT: I'm going to ask you to slow down
`just a little bit.
`THE WITNESS: Okay. Sorry. And those
`accelerometers actually allow you to know what the angle of
`the bird is, how much rotation you have on it.
`The -- to the left-hand side of this is a
`box marked 76, and that is a communications -- a method of
`communications. It has a particular name, 485. There are
`other ways you could do the communications. And that's
`going to communicate information to and from the rest of
`the system and particularly up to the boat.
`BY MR. GILMAN:
`So in front of you, you have the three different
`Q.
`patents of yours that are in this case --
`A.
`Yes.
`-- Exhibits 1, 2 and 3.
`Q.
`What do the different patents cover in
`terms of your invention and what you were thinking about?
`A.
`Okay. So one of the patents covers the overall
`strategies for controlling the cables, that includes how
`you might turn the cables, turn mode, how you might keep
`the cables separated at a fixing distance, and how you
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 23
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`Direct-Bittleston/By Mr. Gilman
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`might keep the cables at a fixed angle that are parallel
`to the direction. Maybe we have something I can show you
`that.
`Yeah, I think -- are there some slides that we have
`Q.
`that you think would help illustrate these features?
`A.
`Yes, I think so.
`Okay. So I'm going to start illustrating
`this by having no steering, so I hope you can see this
`little diagram here with cables wondering about in the
`water.
`
`This is a situation you would have if the
`cables didn't have any steering on them. And what you can
`notice in particular is that on some of the cables that
`get closer together, and some get further apart, so you
`get things where they're too close and too far apart.
`That's not good for a lot of reasons. One
`of the reasons is, you're trying to take a picture of the
`subsurface, and you want to take a uniform picture and
`you'd like all of these to be uniform to get a good
`picture. So maybe we can go on to the next slide.
`So if they get too close this is what
`happens, they cross, they tangle, and they make the most
`huge mess you can ever imagine. You tangle all those
`4 mile, 6 mile cables together, you're ending up taking all
`this back to port. It's a massive mountain of cables at
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`PGS v. WESTERNGECO (IPR2014-00687)
`WESTERNGECO Exhibit 2050, pg. 24
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`
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`Direct-Bittleston/By Mr. Gilman
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`513
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`the side of the port. You're going to have to untangle
`them with cranes and take them apart. The whole system is
`down for weeks.
`This is a catastrophe. It doesn't happen
`all the time. It happens rarely, but when it does happen,
`it's a lot of money down the strain.
`How expensive are each of these cables?
`Q.
`A.
`They are millions of dollars each cable. I can give
`you precise number, you know, 10 to $20 million of
`equipment in the water is not unusual.
`So that's what happens if the cables get too close
`Q.
`together?
`A.
`Yeah.
`What happens if they get too far apart?
`Q.
`A.
`I don't know if we have an example of that. So if
`they get too far apart, then what happens is you get an
`area in between cables where you're not taking the data,
`and the contracts we have with our clients say that we
`have to get certain amount of data everywhere across the
`area we're covering.
`And this example you can now see. There's
`a hole that's been made in the data. So now the only
`choice here is to come back later and go over the same
`territory again. I think yesterday it was explained in
`the introduction about mowing the lawn and going over the
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