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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PETROLEUM GEO-SERVICES INC.
`and
`ION GEOPHYSICAL CORPORATION
`AND ION INTERNATIONAL S.A.R.L.
`Petitioners
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`v.
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`WESTERNGECO, LLC
`Patent Owner
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`Case IPR2014-006871
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`U.S. Patent No. 7,162,967
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`PETROLEUM GEO-SERVICES INC.’S OBJECTIONS TO EVIDENCE
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`1 Case IPR2015-00566 has been joined with this proceeding.
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`Case IPR2014-00687
`Patent 7,162,967
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`Petitioner Petroleum Geo-Services Inc. (“PGS”) objects pursuant to 37
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`C.F.R. § 42.64(b)(1) and the Federal Rules of Evidence (“FRE”) to the
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`admissibility of evidence served by Patent Owner WesternGeco, LLC on June 22,
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`2015. PGS files these objections pursuant to 37 C.F.R. § 42.64(b)(1), which—as
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`of May 19, 2015—requires objections to be filed with the Board. See 80 F.R.
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`28,561, 28,563. Nothing contained herein shall be deemed to withdraw any
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`objection in PGS’ Objections to Evidence—including to Exhibits 2141, 2142,
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`2151, 2152, 2153-56, and 2161—previously served on Patent Owner on March 27,
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`April 16, May 6, May 28, and June 8, 2015.
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`The exhibits objected to, and grounds for PGS’ objections, are listed below.
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`PGS also objects to Patent Owner’s reliance on or citation to any objected evidence
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`in its papers.
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`I.
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`IDENTIFICATION OF CHALLENGED EVIDENCE AND GROUNDS
`FOR OBJECTIONS
`A. Exhibit 2163
`PGS objects to Exhibit 2163, the Third Declaration of Timothy Gilman,
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`under FRE 402 and FRE 403 because it is irrelevant and its probative value is
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`substantially outweighed by the danger of wasting time in this compressed
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`proceeding. Exhibit 2163 purports to authenticate various exhibits. Exhibit 2163
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`is irrelevant to the extent that it attempts to authenticate irrelevant exhibits.
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`Exhibit 2163 is also irrelevant to the extent that it does not cure the objections
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`identified in PGS’ Objections to Evidence of June 8, 2015.
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`PGS further objects to Exhibit 2163 under FRE 402, 403 and 602 to the
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`extent that Mr. Gilman provides comments that are outside his personal knowledge
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`or lack foundation.
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`Nothing herein shall be deemed to withdraw any of PGS’ objections to
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`exhibits referenced in Exhibit 2163.
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`Exhibit 2165
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`B.
`PGS objects to Exhibit 2165, the Second Declaration of Michael Kiklis,
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`under FRE 402 and FRE 403 because it is irrelevant and its probative value is
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`substantially outweighed by the danger of wasting time in this compressed
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`proceeding. Exhibit 2165 purports to authenticate an exhibit. Exhibit 2165 is
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`irrelevant to the extent that it attempts to authenticate irrelevant exhibits. Exhibit
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`2165 is also irrelevant to the extent that it does not cure the objections identified in
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`PGS’ Objections to Evidence of June 8, 2015.
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`Nothing herein shall be deemed to withdraw any of PGS’ objections to
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`exhibits referenced in Exhibit 2165.
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`II. CONCLUSION
`To the extent Patent Owner fails to correct the defects identified above, PGS
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`may file a motion to exclude under 37 C.F.R. § 42.64(c).
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`Respectfully submitted,
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` /Jessamyn Berniker/
`Jessamyn Berniker
`Reg. No. 72,328
`Williams & Connolly LLP
`725 Twelfth Street, N.W.
`Washington, DC 20005
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`Phone: 202-434-5474
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`Dated: June 29, 2015
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the above-captioned Petroleum Geo-
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`Services Inc.’s Objections to Evidence was served on June 29, 2015, by delivering
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`a copy via electronic mail upon the following attorneys of record.
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`For Petitioner ION Geophysical Corporation and ION International S.A.R.L.:
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`W. Karl Renner
`Roberto Devoto
`IPR37136-0003IP1@fr.com
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`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`202-783-5070
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`For Patent Owner:
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`Michael L. Kiklis
`CPDocketKiklis@oblon.com
`Scott McKeown
`CPDocketMcKeown@oblon.com
`Kevin Laurence
`CPDocketLaurence@oblon.com
`Katherine Cappaert
`CPDocketCappaert@oblon.com
`Christopher Ricciuti
`CPDocketRicciuti@oblon.com
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`Oblon
`1940 Duke Street
`Alexandria, Virginia 22314
`703-413-3000
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`Dated: June 29, 2015
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`Respectfully submitted,
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`/Jessamyn Berniker/
`Jessamyn Berniker
`Reg. No. 72,328
`Williams & Connolly LLP
`725 Twelfth Street, N.W.
`Washington, DC 20005
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`Phone: 202-434-5474
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