`________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_________________________
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`PETROLEUM GEO-SERVICES INC.
`and
`ION GEOPHYSICAL CORPORATION
`AND ION INTERNATIONAL S.A.R.L,
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`Petitioners,
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`v.
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`WESTERNGECO LLC
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`Patent Owner.
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`____________
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`Case IPR2014-006881
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`U.S. Patent No. 7,080,607
`____________
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`PATENT OWNER’S MOTION TO SEAL UNDER
`37 C.F.R. §§ 42.14 AND 42.54
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`1 Case IPR2015-00567 has been joined with this proceeding.
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`Pursuant to 37 C.F.R. §§ 42.14 and 42.54, Patent Owner, WesternGeco
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`Patent Owner’s Motion to Seal
`Case IPR2014-00688
`U.S. Patent No. 7,080,607
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`L.L.C (“WesternGeco” or “Patent Owner”) submits this Motion to Seal Patent
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`Owner’s Request for Rehearing Under 37 C.F.R. § 42.71(d) (“Patent Owner’s
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`Request for Rehearing”) filed on January 14, 2016.
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`I.
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`Reasons for Sealing Patent Owner’s Request for Rehearing
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`Patent Owner’s Request for Rehearing contains direct quotations from
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`Exhibit 2069, which was previously designated as confidential in this proceeding
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`because it contains confidential business information between PGS Geophysical
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`A.S. and a third-party and is subject to a protective order in WesternGeco L.L.C.v.
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`Petroleum Geo-Services Inc., Civil Action No. 4:13-cv-02725.
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`II. Certification of Non-Publication Status
`Patent Owner’s undersigned counsel certifies that the information sought to
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`be sealed by this motion has not been published or otherwise made public to the
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`best of his knowledge.
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`III. Certification of Conference with Opposing Party Pursuant to 37 C.F.R.
`§ 42.54
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`At the time Ex. 2069 was filed in this proceeding, Patent Owner conferred in
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`good faith with Petitioners, whom did not oppose Patent Owner’s original motion
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`to seal the exhibit. Pursuant to that agreement, and the protective order in this case
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`(Ex. 2038), Patent Owner’s Request for Rehearing containing direct quotations
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`1
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`from Exhibit 2069 is similarly being filed under seal.
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`Patent Owner’s Motion to Seal
`Case IPR2014-00688
`U.S. Patent No. 7,080,607
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`IV. Request For Relief
`Patent Owner requests that Patent Owner’s Request for Rehearing remain
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`Respectfully submitted,
`Oblon, McClelland, Maier &
`Neustadt, LLP
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`
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`/Michael L. Kiklis/
`Michael L. Kiklis
`Registration No. 38,939
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`Attorney for Patent Owner
`WESTERNGECO L.L.C.
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`under seal.
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`Dated: January 14, 2016
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`Customer Number
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`Tel. (703) 413-3000
`Fax. (703) 413-2220
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`Patent Owner’s Motion to Seal
`Case IPR2014-00688
`U.S. Patent No. 7,080,607
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies service of MOTION TO SEAL on the
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`counsel of record for the Petitioners by filing this document through the Patent
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`Review Processing System as well as delivering a copy via electronic mail to the
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`following addresses:
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`David Berl
`dberl@wc.com
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`Jessamyn Berniker
`jberniker@wc.com
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`Thomas S. Fletcher
`tfletcher@wc.com
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`Christopher Suarez
`csuarez@wc.com
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`W. Karl Renner
`Roberto Devoto
`IPR37136-0002IP1@fr.com
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`/Michael L. Kiklis/
`Michael L. Kiklis
`Registration No. 38,939
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`Attorney for Patent Owner
`WESTERNGECO L.L.C.
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`Date: January 14, 2016