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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PETROLEUM GEO-SERVICES INC.,
`Petitioner
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`v.
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`WESTERNGECO LLC
`Patent Owner
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`———————————
`
`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)
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`SECOND SUPPLEMENTAL DECLARATION OF ROBIN C. WALKER
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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 2140, 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 2129 is a true and correct copy of my trial demonstratives in the
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`WesternGeco L.L.C. v. ION Geophysical Corp. et al., Civ. No. 09-1827 (S.D. Tex.) litigation.
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`4.
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`Exhibit 2130 is a true and correct copy of email correspondence dating
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`from 2007 with subject line “Libya Technical Seminar,” in which I participated during my time
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`at WesternGeco. This correspondence was made and kept in the ordinary course of
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`WesternGeco’s business.
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`5.
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`Exhibit 2131 is a true and correct copy of an excel spreadsheet that I
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`authored between 1994 and 1996 during my time at WesternGeco. This spreadsheet was made
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`and kept in the ordinary course of WesternGeco’s business.
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`6.
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`Exhibit 2132 is a true and correct copy of a spreadsheet dating from 2010
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`titled “Tims stats 2005 to 2009 Retrieve 1” that was produced by employees at WesternGeco and
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`that I received during my time at WesternGeco. This spreadsheet was made and kept in the
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`ordinary course of WesternGeco’s business.
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`7.
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`Exhibit 2133 is a true and correct copy of an email dating from 2004 with
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`subject line “AKPO/COMBO,” which I received during my time at WesternGeco. This
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`correspondence was made and kept in the ordinary course of WesternGeco’s business.
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`8.
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`Exhibit 2134 is a true and correct copy of an email dating from 2002 with
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`subject line “Status report for May, 2002,” which I received during my time at WesternGeco.
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`This correspondence was made and kept in the ordinary course of WesternGeco’s business.
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`WESTERNGECO Exhibit 2140, pg. 2
`PGS v. WESTERNGECO
`IPR2014-00687
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`
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`WESTERNGECO Exhibit 2140, pg. 3
`PGS v. WESTERNGECO
`IPR2014-00687