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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`PETROLEUM GEO-SERVICES, )
` )
` Petitioner, ) Case No.
` ) IPR2014-00687,
` vs. ) -00688, -00689
` )
`WESTERNGECO, )
` )
` Patent Owner. )
`-----------------------------x
`
` DEPOSITION OF BRIAN EVANS, PH.D.
` VOLUME I
`
` Washington, D.C.
` Thursday, February 5, 2015
`
`Reported by: Lori J. Goodin, RPR, CLR, CRR
` Realtime Systems Administrator
`Job No. 90106
`
`TSG Reporting - Worldwide
`(877) 702-9580
`
`PGS v. WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2039, pg. 1
`
`

`

`Page 3
`
` A P P E A R A N C E S:
`
` On Behalf of Petitioner:
` WILLIAMS & CONNOLLY
` 725 Twelfth Street, Northwest
` Washington, D.C. 20005
` BY: THOMAS FLETCHER, ESQUIRE
` BY: DAVID BERL, ESQUIRE
` BY: CHRISTOPHER SUAREZ, ESQUIRE
`
` PETROLEUM GEO-SERVICES, INC.
` 15150 Memorial Drive
` Houston, Texas 77079
` BY: KEVIN HART, ESQUIRE
`
` On Behalf of Patent Owner:
` OBLON MCCLELLAND MAIER &
` NEUSTADT
` 1940 Duke Street
` Alexandria, Virginia 22314
` BY: SCOTT MCKEOWN, ESQUIRE
` CHRISTOPHER BULLARD, ESQUIRE
`
`
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`Page 5
`
` B. Evans, Ph.D.
` BRIAN J. EVANS, PH.D.,
` having been first duly sworn, testified as
` follows:
` EXAMINATION
` BY MR. MCKEOWN:
` Q. Can you please state your name for 08:49
` the record. 08:49
` A. Brian John Evans. 08:49
` Q. Okay. Mr. Evans, my name is Scott 08:49
` McKeown, I'm an attorney for WesternGeco, and 08:49
` you have filed some declarations in some 08:49
` proceedings at the U.S. Patent and Trademark 08:49
` Office. Those are 2014-687 through 689. 08:49
` Are you generally familiar with 08:49
` those proceedings? 08:49
` A. Generally. But I'm not a lawyer. 08:49
` Q. Sure. 08:49
` MR. BERL: I don't mean to 08:49
` interrupt, but are we putting appearances 08:49
` on the record? 08:49
` MR. MCKEOWN: Yes, sure, we can go 08:49
` around the table, if you want to. 08:49
` So, I'm Scott McKeown. I'm an 08:49
` attorney for WesternGeco. To my right is 08:49
`
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`Page 2
`
` February 5, 2015
` 8:49 a.m.
`
` Deposition of BRIAN EVANS, PH.D.,
` held at Williams & Connolly, 725 12th
` Street, Northwest, Washington, D.C. before
` Lori J. Goodin, RPR, CLR, CRR, a Notary
` Public of the District of Columbia.
`
`Page 4
` A P P E A R A N C E S (CONTINUED):
`
` On Behalf of Patent Owner:
` KIRKLAND & ELLIS
` 300 North La Salle
` Chicago, Illinois 60654
` BY: SIMEON PAPACOSTAS, ESQUIRE
`
`
`
`
`TSG Reporting - Worldwide
`(877) 702-9580
`
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`PGS v. WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2039, pg. 2
`
`

`

`Page 6
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`
` B. Evans, Ph.D.
` Chris Bullard, also with the Oblon firm. 08:49
` To his immediate right is Simeon -- 08:49
` MR. PAPACOSTAS: Papacostas. 08:49
` MR. MCKEOWN: There you go. Of the 08:49
` Kirkland & Ellis firm. 08:49
` MR. BERL: And it is David Berl of 08:49
` Williams & Connolly for petitioner. Along 08:50
` with me is Tom Fletcher from Williams & 08:50
` Connolly, Chris Suarez from Williams & 08:50
` Connolly and Kevin Hart from PGS. 08:50
` BY MR. MCKEOWN: 08:50
` Q. So, I will be asking you some 08:50
` questions today about some declarations you 08:50
` prepared in those proceedings at the Patent 08:50
` Office. 08:50
` I would ask that we try not to talk 08:50
` over each other. And if you need more 08:50
` information or clarification about a question, 08:50
` please feel free to ask. If you need a break 08:50
` for the bathroom, we can do that whenever you 08:50
` need it, just as long as it is not as a 08:50
` question is pending. 08:50
` So, when I ask you questions, you 08:50
` are expected to give truthful answers to the 08:50
`
`Page 8
`
` B. Evans, Ph.D.
` Q. Are they U.S. patents? 08:51
` A. No, Australia. 08:51
` Q. Okay. What is the subject matter of 08:51
` those patents? 08:51
` A. Oh, it was a seismic, seismic data 08:51
` processing were two of them. 08:52
` And the other one was a function of 08:52
` my Ph.D. thesis about 3D techniques. 08:52
` Q. What was the title of your Ph.D. 08:52
` thesis? 08:52
` A. I need to see my -- I can't remember 08:52
` these things. 08:52
` Q. Okay. Why don't I give you your 08:52
` declarations here. 08:52
` So, I will give you all three of 08:52
` them. 08:52
` A. Okay, thanks. 08:52
` Q. And, a copy for your counsel as 08:52
` well. So, the first one I'm handing you is for 08:52
` the '607. 08:52
` THE WITNESS: This is the '607. 08:52
` MR. BERL: That is for you. He will 08:52
` give me my copy. 08:52
` MR. BULLARD: That is one copy of 08:52
`
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` B. Evans, Ph.D.
` extent you can. And you are required to answer 08:50
` unless your attorney instructs you not to 08:51
` answer. 08:51
` Do you understand that? 08:51
` A. Oh, okay. 08:51
` Q. Okay. Have you had, have you been 08:51
` previously deposed before? 08:51
` A. What do you mean by deposed? 08:51
` Q. This, what we are doing today is a 08:51
` deposition. 08:51
` A. Because I'm not legal. I'm a 08:51
` scientist. 08:51
` Q. Okay. 08:51
` A. No, I have never. This is the first 08:51
` time. 08:51
` Q. Okay. Fair enough. Do you have any 08:51
` other questions before we begin? 08:51
` A. I don't know until I've got 08:51
` something to ask. 08:51
` Q. Okay, fair enough. Fair enough. 08:51
` Are you an inventor on any patents, Mr. Evans? 08:51
` A. I am a coinventor on three. Not 08:51
` that they have been continued, because we paid 08:51
` the money out. 08:51
`
`Page 9
`
` B. Evans, Ph.D.
` the '607. 08:52
` MR. MCKEOWN: This is the '607. I 08:53
` may as well give them all out here. That 08:53
` is the '967. 08:53
` THE WITNESS: This isn't the same 08:53
` index as I have had it. 08:53
` MR. BERL: Yes. 08:53
` BY MR. MCKEOWN: 08:53
` Q. And this is the '520. So, we will 08:53
` be talking about all three of these today. I 08:53
` will try to keep it clear which one we are 08:53
` talking about when we are talking about it, so 08:53
` we don't confuse the three. 08:53
` MR. BERL: And for the record, as 08:53
` Dr. Evans just noted. We realize that the 08:53
` table of contents was inappropriately 08:53
` abridged in his declarations. 08:53
` And we prepared, and it may move 08:53
` things along more quickly to use table of 08:53
` contents that goes down each level and 08:53
` reflects the actual sections of the 08:53
` declaration. 08:53
` So, we have prepared those if you 08:53
` would like to use and mark them. It may 08:53
`
`TSG Reporting - Worldwide
`(877) 702-9580
`
`3
`
`PGS v. WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2039, pg. 3
`
`

`

`Page 10
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`Page 11
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` B. Evans, Ph.D.
` make the process more efficient in the 08:53
` coming days. The table of contents in the 08:53
` actual declarations only go down two or 08:54
` sometimes three levels, rather than all of 08:54
` the way down. 08:54
` THE WITNESS: So, do I get an update 08:54
` then? 08:54
` MR. BERL: He will likely give you a 08:54
` copy. 08:54
` MR. MCKEOWN: Do you have a copy of 08:54
` this, Mr. Evans? 08:54
` THE WITNESS: No, I don't. 08:54
` MR. BERL: So, I will give you three 08:54
` copies of each, Mr. McKeown, and then you 08:54
` can give them back to Dr. Evans. 08:54
` MR. MCKEOWN: Okay. All right. 08:54
` MR. BERL: And maybe mark them as-B 08:54
` or however you want to mark them is fine 08:54
` with us. 08:54
` MR. MCKEOWN: So, are these 08:54
` corresponding to outline entries in the 08:54
` actual declaration or are these -- 08:54
` MR. BERL: Yes. 08:54
` MR. MCKEOWN: Okay. All right. I 08:54
`
`Page 12
`
` B. Evans, Ph.D.
` A. Page 5. 08:55
` MR. BERL: These are the '520. 08:55
` THE WITNESS: We are in the '520, 08:55
` right? 08:55
` BY MR. MCKEOWN: 08:55
` Q. I think it is the same in all of 08:55
` them at least for the first couple of 08:55
` paragraphs. But -- 08:55
` A. So, should I be looking at '607. 08:55
` MR. BERL: He thinks it is the same. 08:56
` THE WITNESS: Oh, okay. 08:56
` BY MR. MCKEOWN: 08:56
` Q. It looks the top of Page 6 there. 08:56
` A. So, Yes, top of Page 6, Advancements 08:56
` in Techniques of Low Fold Three-Dimensional 08:56
` Seismic Reflection Surveying. I think that 08:56
` answers your question. 08:56
` Q. Okay. So, that was the topic of the 08:56
` thesis you were referring to? 08:56
` A. Yes. 08:56
` Q. Okay. Have you ever been involved 08:56
` in any kind of patent disputes previously? 08:56
` MR. BERL: Objection. 08:56
` THE WITNESS: When you say 08:56
`
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` B. Evans, Ph.D.
` don't know that I need to use them. So, 08:54
` let's just keep them on the side. 08:54
` MR. BERL: It may make it easier to 08:54
` find. 08:54
` MR. MCKEOWN: I will be referring to 08:54
` paragraph numbers, so I am not using 08:54
` headings. 08:54
` THE WITNESS: The headings help me 08:55
` to find it in the -- 08:55
` BY MR. MCKEOWN: 08:55
` Q. Yes, okay. I will refer you to 08:55
` the -- 08:55
` A. Because in between these, I get 08:55
` confused. 08:55
` Q. Okay. Sure. Yes. So I was just 08:55
` asking the name, or the title of your thesis. 08:55
` A. Okay. Can I -- It is one of these 08:55
` three replacement contents. 08:55
` Q. Let me see if I can find it for you. 08:55
` Looks to be about Paragraphs 10 through 11 talk 08:55
` about your Ph.D. 08:55
` A. What page? 08:55
` Q. So, looks like Paragraph 10 top of 08:55
` Page 5 in the '520. 08:55
`
`Page 13
`
` B. Evans, Ph.D.
` objection, sorry, I'm not, I don't 08:56
` understand the process. 08:56
` BY MR. MCKEOWN: 08:56
` Q. You can answer. You are expected to 08:56
` answer. 08:56
` MR. BERL: You can answer the 08:56
` question. I am just preserving the 08:56
` objection. 08:56
` THE WITNESS: Oh, okay. Okay. 08:56
` Only inasmuch as talking between 08:56
` authors of a patent that I argued my name 08:57
` should be first and he argued. And he won. 08:57
` It was just a personal argument. 08:57
` BY MR. MCKEOWN: 08:57
` Q. So, you haven't been hired as a 08:57
` consultant? 08:57
` A. Oh, never, never, never. 08:57
` Q. Okay. 08:57
` A. First time ever. 08:57
` Q. Sure. How many declarations did you 08:57
` prepare for this matter? 08:57
` A. I think -- 08:57
` MR. BERL: What? For this? 08:57
` BY MR. MCKEOWN: 08:57
`
`TSG Reporting - Worldwide
`(877) 702-9580
`
`4
`
`PGS v. WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2039, pg. 4
`
`

`

`Page 14
`
`Page 15
`
` B. Evans, Ph.D.
` Q. For this matter. 08:57
` A. For the whole -- 08:57
` MR. BERL: Objection. 08:57
` MR. MCKEOWN: Right. 08:57
` BY MR. MCKEOWN: 08:57
` Q. So, you have three declarations in 08:57
` front of you. 08:57
` A. Yes. 08:57
` Q. Did you just prepare three? 08:57
` A. I think there was a fourth, I think. 08:57
` My memory isn't what it should be. 08:57
` Q. Okay. 08:57
` A. I think there is a fourth. 08:57
` Q. Are you aware of the Patent Office's 08:57
` review of those declarations? 08:57
` MR. BERL: Objection. 08:57
` THE WITNESS: I'm confused in him 08:58
` saying objection. Am I supposed to stop 08:58
` now or -- 08:58
` MR. BERL: You can answer the 08:58
` question. He will ask you questions, I may 08:58
` object. 08:58
` If I tell you not to answer, then 08:58
` you don't answer. Unless I tell you not to 08:58
`
`Page 16
`
` B. Evans, Ph.D.
` BY MR. MCKEOWN: 08:58
` Q. Okay. But you did read the decision 08:58
` that denied the fourth? 08:58
` A. I read it, but that was -- I have 08:59
` got seven Ph.D. students. That is one of the 08:59
` many documents I read on a daily basis, but I 08:59
` don't exactly read these things on a daily 08:59
` basis. 08:59
` Q. Sure. Did you form an opinion as to 08:59
` whether you believe that decision was correct 08:59
` or not? 08:59
` A. The board made? 08:59
` Q. Right. 08:59
` MR. BERL: Objection. 08:59
` THE WITNESS: I, my impression, 08:59
` because I didn't go into it deeply, and I 08:59
` was on my own, not with anyone else, not 08:59
` discussing it with anyone else, 08:59
` 12,000 miles away, was that I didn't think 08:59
` the interpretation was the same as I had 08:59
` put on it. 08:59
` BY MR. MCKEOWN: 08:59
` Q. Uh-huh. So did you conclude that 08:59
` the USPTO's interpretation was wrong? 09:00
`
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` B. Evans, Ph.D.
` answer you can try to answer his question, 08:58
` if you understand it. 08:58
` THE WITNESS: Okay. I don't 08:58
` understand the process, you understand. 08:58
` Now, could you repeat? 08:58
` BY MR. MCKEOWN: 08:58
` Q. Sure. So you prepared four 08:58
` declarations, correct? 08:58
` A. Yes. 08:58
` Q. And they were -- 08:58
` A. To the best of my memory. 08:58
` Q. And they were submitted to the 08:58
` Patent Office; is that right? 08:58
` A. Through his company. 08:58
` Q. Okay. Have you seen the decisions 08:58
` from the Patent Office? 08:58
` A. Yes, I have scanned over them. 08:58
` Q. Okay. So you are aware that the 08:58
` fourth submission, or one of these submissions 08:58
` was denied; is that right? 08:58
` MR. BERL: Objection. 08:58
` THE WITNESS: Yes. Because now, you 08:58
` know, I am working with three now instead 08:58
` of four. That is my -- 08:58
`
`Page 17
`
` B. Evans, Ph.D.
` MR. BERL: Objection, relevance. 09:00
` THE WITNESS: In Australia, a court 09:00
` in one state can have a different decision 09:00
` from a court in another state. 09:00
` And part of that decision process is 09:00
` based on state rules and regulations. I am 09:00
` not conversant with U.S. or Australia state 09:00
` rules and regulations. 09:00
` So, I can't really saying that it 09:00
` was wrong without a thorough understanding 09:01
` and a legal standing. 09:01
` Wouldn't you agree with that, that 09:01
` that is a reasonable assumption? I 09:01
` couldn't even make a decision myself on 09:01
` whether there is something wrong. 09:01
` But, if I came to my opinion and the 09:01
` court came to their opinion, based on their 09:01
` knowledge, which is far superior to mine, 09:01
` one assumes they must be right based on 09:01
` their own regulations. 09:01
` BY MR. MCKEOWN: 09:01
` Q. Okay. I'm going to talk a little 09:01
` bit about your educational background in the 09:01
` next couple of questions. And I believe that 09:01
`
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`TSG Reporting - Worldwide
`(877) 702-9580
`
`5
`
`PGS v. WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2039, pg. 5
`
`

`

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` B. Evans, Ph.D.
` the three declarations are fairly identical in 09:01
` that respect. 09:01
` So, you should feel free to refer to 09:01
` any of the three. 09:01
` A. Okay. 09:01
` Q. But, I will, I guess I will use the 09:01
` '520 just for, in case the paragraph numbering 09:01
` is off or the page numbering is off. 09:01
` A. Okay. '520. 09:02
` Q. So, Paragraph 4, at least in the 09:02
` '520, you are -- 09:02
` A. Paragraph 4. 09:02
` Q. Right. 09:02
` A. Page -- 09:02
` Q. I believe it is Page 2. 09:02
` A. Oh, okay. Yes. 09:02
` Q. So, you are a professor of 09:02
` geophysics at Curtin University; is that 09:02
` correct? 09:02
` A. That's correct. 09:02
` Q. What is the field of geophysics? 09:02
` A. The field of geophysics is very 09:02
` broad. I was actually in a Department of 09:02
` Exploration Geophysics, which is not the same 09:03
`
`Page 20
`
` B. Evans, Ph.D.
` A. Yes. 09:04
` Q. Do you have any background in, or I 09:04
` should say, do you have any formal education in 09:04
` mechanical engineering? 09:04
` A. First year, I did mechanical 09:04
` engineering as part of the undergraduate 09:04
` electrical engineer. And the reason why, we 09:04
` didn't have Bachelor's in those days. We 09:05
` actually didn't have Bachelor's. 09:05
` They are all diploma-like today. 09:05
` Imperial College London, does not give a 09:05
` Bachelor's degree out. It gives a diploma of 09:05
` Imperial College, DIC. 09:05
` So, that is the University of 09:05
` Liverpool. Today they have Bachelor's, 09:05
` Master's, and Ph.D.s, but in those days they 09:05
` didn't. So -- 09:05
` Q. Sure. But your diploma is in 09:05
` mechanical engineering and not mechanical 09:05
` engineering? 09:05
` A. Yes. But I still did mechanical 09:05
` engineering. And actually I teach stress 09:05
` analysis from a mechanical engineering 09:05
` standpoint as part of my Master's of subsea 09:05
`
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` B. Evans, Ph.D.
` as the broad field of geophysics. Geophysics 09:03
` as it suggests is the physics of geo, or 09:03
` physics of rocks. 09:03
` But, also, as an extension it is the 09:03
` study of interplanetary sciences, tidal effects 09:03
` of the gravitational pull of the moon at 09:03
` different levels. 09:03
` The geophysical world is quite 09:03
` different from the exploration geophysics in 09:03
` which I have spent 99 percent of my career. 09:03
` And consequently I am in the Department of 09:03
` Exploration Geophysics. 09:03
` I actually named the department 09:03
` because I established the Department of 09:03
` Exploration Geophysics with someone called 09:03
` Dr. Norm Uren. 19 -- when was this? This is 09:03
` 1987. 1987. 09:04
` Q. Is Dr. Uren also at Curtin 09:04
` University? 09:04
` A. Oh, he has retired years ago. But 09:04
` he was at that time, yes, sure. 09:04
` Q. Okay. Moving on down to 09:04
` Paragraph 6. You reference a diploma in 09:04
` electrical engineering. Do you see that? 09:04
`
`Page 21
`
` B. Evans, Ph.D.
` engineering, which I teach to mechanical 09:05
` engineering graduates. 09:05
` So, I'm expected to know certain, 09:05
` how certain knowledge of mechanical 09:05
` engineering. 09:05
` Q. And that is stress analysis of 09:05
` anything in particular? 09:05
` A. Cantilevers, bending moments, 09:05
` bridges. I teach, I teach rig design. Part of 09:05
` my work. And that is in a topic called 09:06
` Introduction to Subsea Engineering, that I 09:06
` presently teach, and will be in three weeks 09:06
` time. 09:06
` Q. Do you teach fluid mechanics? 09:06
` A. I don't teach fluid mechanics. I've 09:06
` got enough problems with seven Ph.D. students. 09:06
` Q. In Paragraph 11 you talk about your 09:06
` Ph.D. students, so let's talk about them for a 09:06
` couple of minutes. 09:06
` A. On page -- sorry. 09:06
` Q. Page 5, sorry. 09:06
` A. Page 5. I went to Page 11. 09:06
` Q. Paragraph 11. 09:06
` A. Page 5. 09:06
`
`TSG Reporting - Worldwide
`(877) 702-9580
`
`6
`
`PGS v. WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2039, pg. 6
`
`

`

`Page 22
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`Page 23
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` B. Evans, Ph.D.
` Q. Why don't you just read that 09:07
` paragraph to yourself and just let me know when 09:07
` you are done. 09:07
` A. I can mark this, yes? 09:07
` Q. Sure. 09:07
` A. I just want to underline something. 09:08
` Okay, yes. 09:08
` Q. And what did you underline? 09:08
` A. I underlined 20 Master's because I 09:08
` have had more than -- I mean this whole thing 09:08
` was written a while back, right? 09:08
` Q. Okay. 09:08
` A. I'm referring here to four Ph.D.s, 09:08
` but unfortunately I've got seven now, which is 09:08
` a pain. They are the major two things 09:08
` eventuated obviously, the Master's and the 09:08
` Ph.D. students are all a function of time. 09:08
` And some graduate, and they go and 09:08
` then you get some coming in. 09:08
` Q. Okay. 09:08
` A. And in actual fact, I mean, I can't 09:08
` remember how many Ph.D. students I have 09:08
` graduated. But, if you really take all of the 09:08
` Master's and Ph.D. students through, I was 09:08
`
`Page 24
`
` B. Evans, Ph.D.
` streamer steering is one of electronics and 09:11
` positioning. 09:11
` An electronics thesis would be done 09:11
` by the Electrical Engineering Department. A 09:11
` location thesis would be done by a Surveying 09:11
` Department. 09:11
` Q. Uh-huh. 09:11
` A. And in a Geophysics Department, it 09:11
` doesn't necessarily follow that you would do 09:11
` those areas, because you are more interested in 09:11
` acquiring an understanding of the location of 09:11
` reflected seismic data as opposed to the actual 09:11
` steering devices. 09:11
` Q. Okay. 09:12
` A. So, I guess the answer is personally, 09:12
` no. But, I know in the Center of Marine 09:12
` Science and Technology works in robotic 09:12
` steering, for example. 09:12
` But then that is the electronics 09:12
` side of the operation. 09:12
` Q. Okay. Let's go to Page 3, 09:12
` Paragraph 6. 09:12
` A. Page 3. Top paragraph. 09:12
` Q. Right. Why don't you just read that 09:12
`
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` B. Evans, Ph.D.
` responsible for, I was responsible for 25 09:08
` Master's graduates this year alone. 25, 09:08
` because we graduate in November. 09:09
` Q. Uh-huh. 09:09
` A. Not May, June. 09:09
` Q. Okay.