`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`PETROLEUM GEO-SERVICES INC,
`Petitioner
`
`V.
`
`WESTERNGECO LLC
`Patent Owner
`
`Cases
`
`IPR2014-00687 (US. Patent No. 7,162,967)
`IPR20l4—00688 (US. Patent No. 7,080,607)
`IPR2014-00689 (US. Patent No. 7,293,520)
`
`THIRD SUPPLEMENTAL DECLARATION OF ROBIN C. WALKER
`
`Pursuant to 28 U.S.C. § 1746, 1, Robin C. Walker, the undersigned, hereby declare as
`
`follows:
`
`1.
`
`My name is Robin C. Walker.
`
`I am over eighteen years of age, of sound
`
`mind, and in all ways qualified and competent to make this declaration.
`
`I have personal
`
`knowledge of the facts contained in this declaration and they are true and correct.
`
`2.
`
`I have worked in the marine seismic industry for 30 years in technical,
`
`research and customer—facing roles. Through my experience,
`
`I have developed first-hand
`
`knowledge of the technologies that have driven customer demand and enabled effective
`
`acquisition techniques in this industry. During my 30 year tenure at Schlumberger, l rose to be
`
`the Vice President of Sales and Marketing Director for WestemGeco from March 2008 to March
`
`2013 and a Global Account Director for Schlumberger from March 2013 to January 2015.
`
`I am
`
`WESTERNGECO Exhibit 2172, pg. 1
`PGS V. WESTERNGECO
`
`|PR2014-00687
`
`WESTERNGECO Exhibit 2172, pg. 1
`PGS v. WESTERNGECO
`IPR2014-00687
`
`
`
`particularly knowledgeable about
`
`the development, marketing and sales of WestemGeco’s
`
`QMarine System and the market’s reception of Q—Marine and other systems that practice the
`
`patents I understand to be at issue in this proceeding (“Bittleston patents”).
`
`3.
`
`Exhibit 2131 is a true and correct copy of a spreadsheet titled “1112305-
`
`0007-075305” that I authored between 1994 and 1996 during my time at WestemGeco. This
`
`spreadsheet was made and kept in the ordinary course of WesternGeco’s business.
`
`4.
`
`I understand that Exhibit 2131 was provided to counsel for Petroleum
`
`Geo-Services, Inc. in its native form on April 28, 2015, prior to my deposition commencing on
`
`April 30, 2015.
`
`I further understand that the electronic filing system used in this proceeding does
`
`not allow native documents to be uploaded.
`
`I have therefore generated the screenshots attached
`
`hereto, which are true and accurate depictions of the various sheets within the native excel
`
`document and representative of the totality of information contained within Exhibit 2131.
`
`5.
`
`I hereby declare that all statements made herein of my own knowledge are
`
`true and that all statements made on information and belief are believed to be true; and further
`
`that these statements were made with the knowledge that willful false statements and the like so
`
`made are punishable by fine or imprisonment, or both, under Section 1001 of Title 18 of the
`
`United States Code and that such willful false statements may jeopardize the results of these
`
`proceedings.
`
`6.
`
`I declare under penalty of perjury under the laws of the United States of
`
`America that the foregoing is true and correct.
`
`
`
`Robin C. Walker
`
`July 5, 2015
`
`WESTERNGECO Exhibit 2172, pg. 2
`PGS V. WESTERNGECO
`
`|PR2014-00687
`
`WESTERNGECO Exhibit 2172, pg. 2
`PGS v. WESTERNGECO
`IPR2014-00687
`
`
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