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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT or TEXAS
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`HOUSTON DIVISION
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`O9—CV—l827
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`Houston, Texas
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`7:35 a.m.
`July 31, 2012
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`WESTERNGECO LLC
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`5 VS.
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`TON GEOPHYSICAL
`CORPORATION, FUGRO
`GEOTEAM,
`INC., ET AL
`
`JURY TRIAL
`
`Volume 7
`
`Morning Session
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`BEFORE THE HONORABLE KEITH P. ELLISON
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`UNITED STATES DISTRICT JUDGE
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`14 AP :
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`15
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`FOR 'I'HE P.'I'.AIN'I‘IFF:
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`16 Lee L. Kaplan
`SHSER, KAPLAN & VESELKA, LLP
`17 700 Louisiana, Suite 2300
`Houston, Texas 77002
`18 713.221.2300
`
`19
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`Gregg F. LoCascio
`2OKIRIG'.AND&E.LLISI|'..LP
`
`655 Fifteenth Street Northwest
`21 Washington, DC 20005
`202.879.5290
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`22
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`Sarah Tsou
`23 Timothy K. Gilman
`KIRKIAND&E|'..'LISLLP
`24 Citigroup Center
`153 East 53rd Street
`25 New York, New York 10022
`212.446.6435
`
`
`
`Johnny C. Sanchez, RMR, CRR — jcscourtreporter@aol.com
`
`WESTERNGECO Exhibit 2118, pg. 1
`PGS V. WESTERNGECO
`IPRZO14-00687
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`WESTERNGECO Exhibit 2118, pg. 1
`PGS v. WESTERNGECO
`IPR2014-00687
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`Direct—Morton/By Ms . Tsou
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`in your opinion?
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`A. Well,
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`the biggest role is to be able to repeat
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`exactly what you did last time, as well as close that
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`hole. Because if a 4D is a tool to manage an oil field,
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`that's really what it is, it's a tool to manage an oil
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`I'll field.
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`And if you've got this big hole where the
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`oil field is —— a big hole in the data where your oil
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`field is, you can't use it very effectively.
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`Q.
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`Let's turn to PTX 398. What is this document? Did‘
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`you consider this document?
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`A.
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`Yes, ma'am.
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`Q. What is it?
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`A.
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`This is a document talking about steerable streamer
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`benefits, and they list who is --
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`Q.
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`I know it's small, but I think the bottom it says --
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`it's coming from Fugro's files, but is this an ION
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`document?
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`A.
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`Q.
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`That is my understanding.
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`Now, what is —— does part of the document show on
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`Page 144?
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`A. Well, basically, you know, it says there are two
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`benefits to using steerable streamers utilizing DigiFIN
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`devices. And the two aspects to the benefits are seismic
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`contractors are looking for cost and time efficiency as
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`Johnny C. Sanchez, RMR, CRR — jcscourtreporter@aol.com
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`WESTERNGECO Exhibit 2118, pg. 2
`PGS V. WESTERNGECO
`IPRZO14-00687
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`WESTERNGECO Exhibit 2118, pg. 2
`PGS v. WESTERNGECO
`IPR2014-00687
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`Direct—Morton/By Ms . Tsou
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`2106
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`well as, you know,
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`the HSE benefit is clearly not sending
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`out some guy in a little Zodiac back—to—back. And the
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`oil companies are looking for geophysical benefits. And I
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`think this confirms my opinion of both of the benefits
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`that I concluded with —— they're agreeing with my
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`conclusions here.
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`Q.
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`And the next section on this page, does that address
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`your opinions regarding the need for lateral steering for
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`4D?
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`A.
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`Yes.
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`It is widely known among the oil companies that
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`the steerability is important there.
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`So they do know that
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`it's a key factor in influencing the success of 4D's
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`repeatability.
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`That's why we use the word repeatability.
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`I mean, if you put your receiver here on where I'm
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`sitting, and or back at the back door I actually haven't
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`repeated it.
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`If the receiver is in a different place
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`you're not repeating it. And the whole term is
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`repeatability through the industry.
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`Q.
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`That last part of the page —— of the section I should
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`say, it says,
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`"Most 3D seismic shot in North Sea has some
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`4D objective. And this is increasingly the case in other
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`regions of the world where environmental conditions make
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`4D surveys feasible."
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`Do you agree with that statement?
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`A.
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`Yes,
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`I do. Having worked I was -— I was manager of
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`Johnny C. Sanchez, RMR, CRR — jcscourtreporter@aol.com
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`WESTERNGECO Exhibit 2118, pg. 3
`PGS V. WESTERNGECO
`IPRZO14-00687
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`WESTERNGECO Exhibit 2118, pg. 3
`PGS v. WESTERNGECO
`IPR2014-00687
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`Di'rect—Morton/By Ms . Tsou
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`subsurface technology for Kerr—McGee for the North Sea and
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`that involved geophysics and reservoir simulation, which
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`is part of reservoir management.
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`And when I was over there, it was really
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`clear that the fields were being shot with the idea that
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`we're going to use 4D down the road. And so, it is
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`becoming widespread around the world.
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`Q.
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`So in the North Sea, even if it's a 3D survey,
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`the
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`idea is it could very well be a 4D down the road?
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`A.
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`Yes.
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`I don't think you can count any 3D.
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`If I go
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`get a survey,
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`I may not tell the contractor that it's
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`going to be used in 4D because he doesn't necessarily need
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`to know at this time. And -— but I may —— and I may not
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`know because I don't know whether I'm going to be able to
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`sell it to my management, hey, let's go spend another
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`$5 million again.
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`So sometimes it's tough to get that
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`money.
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`Q.
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`Can lateral steering play a role in that first survey
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`if you think it might be repeated down the road?
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`A.
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`I think if you have an inclination or even an inkling
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`down that it might be 4D down the road, you ought to use
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`lateral steering.
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`Why is that?
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`A.
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`So that you'll know where your cables and shots were.
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`Without the lateral steering you really don't know quite
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`Johnny C. Sanchez, RMR, CRR — jcscourtreporter@aol.com
`
`WESTERNGECO Exhibit 2118, pg. 4
`PGS V. WESTERNGECO
`|PR2014-00687
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`WESTERNGECO Exhibit 2118, pg. 4
`PGS v. WESTERNGECO
`IPR2014-00687
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`Di'rect—Morton/By Ms . Tsou
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`2108
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`where everything is.
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`I mean, you kind of have a close
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`approximation, but the error bar is very, very big, and
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`you need that knowledge reduced down so that you can put
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`your cables back where they were.
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`Q.
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`Let's turn together to PTX 214.
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`A.
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`214.
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`Q.
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`I believe we've seen this before, but let's look at
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`Page 209. And this is that ION presentation saying,
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`"Irregularities of streamer shape increase 4D noise, and
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`reduce repeatability."
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`A.
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`Yes, ma'am.
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`Q. What does this mean to you?
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`A.
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`This is an ION document and this is basically them
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`saying that irregularities and streamer shape, which
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`really means irregularities and where you put —— where the
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`cable —— are you repeatable are increasing the noise and
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`they use repeatability.
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`If your old survey is kind of all over the
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`place, you don't quite know where it is, you can't
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`quite —— you can't ever repeat it when you go back.
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`So
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`basically they're saying that by having a straight
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`streamer or at least a well behaved set of streamers, you
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`can reduce that noise out of the 4D signal.
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`Q.
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`So having a straighter or more well behaved array in
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`the first survey makes it easier to review?
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`Johnny C. Sanchez, RMR, CRR — jcscourtreporter@aol.com
`
`WESTERNGECO Exhibit 2118, pg. 5
`PGS V. WESTERNGECO
`IPR2014-00687
`
`WESTERNGECO Exhibit 2118, pg. 5
`PGS v. WESTERNGECO
`IPR2014-00687