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`———————————
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PETROLEUM GEO-SERVICES INC.,
`Petitioner
`
`v.
`
`WESTERNGECO LLC
`Patent Owner
`
`———————————
`
`Cases
`IPR2014-00687 (U.S. Patent No. 7,162,967)
`IPR2014-00688 (U.S. Patent No. 7,080,607)
`IPR2014-00689 (U.S. Patent No. 7,293,520)
`———————————
`
`SUPPLEMENTAL DECLARATION OF ROBIN C. WALKER
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`
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`Pursuant to 28 U.S.C. § 1746, I, Robin C. Walker, the undersigned, hereby declare as
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`follows:
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`1.
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`My name is Robin C. Walker. I am over eighteen years of age, of sound
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`mind, and in all ways qualified and competent to make this declaration. I have personal
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`knowledge of the facts contained in this declaration and they are true and correct.
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`2.
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`I have worked in the marine seismic industry for 30 years in technical,
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`research and customer-facing roles. Through my experience, I have developed first-hand
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`knowledge of the technologies that have driven customer demand and enabled effective
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`acquisition techniques in this industry. During my 30 year tenure at Schlumberger, I rose to be
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`the Vice President of Sales and Marketing Director for WesternGeco from March 2008 to March
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`2013 and a Global Account Director for Schlumberger from March 2013 to January 2015. I am
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`WESTERNGECO Exhibit 2104, pg. 1
`PGS v. WESTERNGECO
`IPR2014-00687
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`
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`particularly knowledgeable about the development, marketing and sales of WesternGeco’s Q-
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`Marine System and the market’s reception of Q-Marine and other systems that practice the
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`patents I understand to be at issue in this proceeding (“Bittleston patents”).
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`3.
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`Exhibit 2079 is a true and correct copy of a final draft of an industry
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`magazine article entitled “Application of Q-Marine Technology for SPC; Imaging for Pinghu
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`field gas reservoirs” that was produced by employees at WesternGeco and SPC (a customer of
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`WesternGeco) in 2008 and that I received in 2008 and approved in my role as the worldwide Q
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`Product Manager. This article was made and kept in the ordinary course of WesternGeco’s
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`business.
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`4.
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`Exhibit 2080 is a true and correct copy of a customer and marketing
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`presentation entitled “Q-Marine improvements.” I produced and gave this presentation during
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`my time at WesternGeco, specifically during the early to mid-2000s. This presentation was
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`made and kept in the ordinary course of WesternGeco’s business.
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`5.
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`Exhibit 2086 is a true and correct copy of a presentation entitled “4D
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`Acquisition with Q-Marine - Experiences and Strategies” that was produced by employees at
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`WesternGeco and that I received during my time at WesternGeco. Specifically, I received this
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`presentation on or around December 1, 2004. This presentation was made and kept in the
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`ordinary course of WesternGeco’s business.
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`6.
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`Exhibit 2088 is a true and correct copy of an article entitled “Mapping the
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`fluid front and pressure buildup using 4D data on Norne Field” from the September 2006 issue of
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`The Leading Edge, an industry magazine of the Society of Exploration Geophysicists (SEG). I
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`received this article during my time at WesternGeco and kept it in the ordinary course of
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`WesternGeco’s business.
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`WESTERNGECO Exhibit 2104, pg. 2
`PGS v. WESTERNGECO
`IPR2014-00687
`
`
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`7.
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`Exhibit 2089 is a true and correct copy of an article entitled “Interpreting
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`reservoir talk” from the September 4, 2003 issue of Offshore Engineer. I received this article
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`during my time at WesternGeco and kept it in the ordinary course of WesternGeco’s business.
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`8.
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`Exhibit 2090 is a true and correct copy of an article entitled “Making a
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`good recovery” from the March 14, 2005 issue of Offshore Engineer. I received this article
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`during my time at WesternGeco and kept it in the ordinary course of WesternGeco’s business.
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`9.
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`Exhibit 2091 is a true and correct copy of ION Technical Forum (ITF)
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`2010’s Book of Abstracts. A version of this document is available for download from ION’s
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`website. See http://www.iongeo.com/content/documents/pdfs/ITF_2010_Abstracts_.pdf.
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`10.
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`Exhibit 2092 is a true and correct copy of an article entitled “Intelligent
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`Infill for Cost Effective 3D Seismic Marine Acquisitions” from the 71st EAGE Conference and
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`Exhibition.
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`11.
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`Exhibit 2093 is a true and correct copy of a draft of an industry magazine
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`article entitled “Evolution Through New Functionality and Applications, Q-Marine gets even
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`better” that was produced by employees at WesternGeco. This article was made and kept in the
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`ordinary course of WesternGeco’s business.
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`12.
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`Exhibit 2094 is a true and correct copy of an article entitled “Q-
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`Technology - moving into the mainstream” from the July/August 2003 issue of The Journal of
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`Offshore Technology. Employees at WesternGeco contributed significantly to the content of this
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`article. I received this article during my time at WesternGeco and kept it in the ordinary course
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`of WesternGeco’s business.
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`13.
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`Exhibit 2100
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`is a
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`true and correct copy of an article entitled
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`“WesternGeco, Seeing Below the Surface” from the May 2002 issue of Shell E&P Technology.
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`WESTERNGECO Exhibit 2104, pg. 3
`PGS v. WESTERNGECO
`IPR2014-00687
`
`
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`WESTERNGECO Exhibit 2104, pg. 4
`PGS v. WESTERNGECO
`IPR2014-00687