IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PETROLEUM GEO-SERVICES INC.
`Petitioner
`v.
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`WESTERNGECO LLC
`Patent Owner
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`
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`CASE IPR: Unassigned
`Patent 7,162,520 B2
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`DECLARATION OF DR. BRIAN EVANS, PhD.
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`PGS v. WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2064, pg. 1
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`TABLE OF CONTENTS
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`INTRODUCTION ............................................................................................... 1
`I.
`II. QUALIFICATIONS ........................................................................................... 2
`III. COMPENSATION AND RELATIONSHIP TO THE PARTIES ..................... 7
`IV. LEGAL STANDARDS ....................................................................................... 8
`A. Claim Construction .......................................................................................... 8
`B. Anticipation ..................................................................................................... 8
`C. Obviousness ..................................................................................................... 9
`D. Person of Ordinary Skill in the Art .................................................................. 9
`V. SUMMARY OF OPINION .............................................................................. 10
`VI. TECHNICAL BACKGROUND ....................................................................... 11
`VII. THE ’520 PATENT ....................................................................................... 53
`A. Brief Description of the Relevant File History .............................................. 53
`B. Relevant Time Frame for Analysis of the ’520 Patent .................................. 54
`C. The Specification of the ’520 Patent ............................................................. 54
`C. Relevant Time Frame for Analysis of the ’520 Patent .................................. 76
`D. The Specification of the ’520 Patent ............................................................. 76
`E. Claims 18 and 1 of the ’520 Patent are Anticipated by Workman ................ 77
`1. Claim 18 ..................................................................................................... 78
`F. Claims 1, 2, 18 and 19 of the ’520 Patent are Obvious over Workman ........ 86
`1. Streamer Separation Mode ......................................................................... 87
`2. Feather Angle Mode ................................................................................... 91
`3. One or More “Modes” ................................................................................ 94
`G. Claims 1, 2, 18 and 19 are Anticipated by Hedberg ...................................... 96
`1. Claim 18 ..................................................................................................... 97
`H. Claims 1, 2, 18 and 19 are Obvious Over Hedberg .....................................113
`1. Streamer Separation Mode .......................................................................113
`2. Feather Angle Mode .................................................................................115
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`PGS v. WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2064, pg. 2
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`I. Claims 1, 6, 18, and 23 are Obvious Over the ’636 PCT in view of the ’153
`PCT .....................................................................................................................117
`1. “An array of streamers each having a plurality of streamer positioning
`devices there along” ........................................................................................119
`2. A Control System Configured to Use a Turn Control Mode ...................121
`J. Claims 1, 6, 18, and 23 are Obvious Over Dolengowski in view of the ’636
`PCT .....................................................................................................................130
`VIII. CONCLUSION ............................................................................................134
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`PGS v. WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2064, pg. 3
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`I, Dr. Brian Evans, hereby state the following:
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`I. INTRODUCTION
`1.
`I have been retained by Petroleum Geo-Services, Inc. (“PGS”) to
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`provide technical assistance related to the filing of a Petition for Inter Partes
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`Review of U.S. Patent No. 7,293,520 B2 (“the ’520 Patent”) (Ex. 1001). I am
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`working as a private consultant on this matter and the opinions presented here are
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`my own.
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`2.
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`I have been asked to prepare a written report, including comments
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`related to whether certain claims of the ’520 Patent are unpatentable because they
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`are anticipated or would have been obvious to one of ordinary skill in view of the
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`prior art. I have reviewed the documents set forth in the attached Appendix of
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`Exhibits and relied on my decades of knowledge and experience in the field of
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`seismic marine surveys (detailed in Section II) in reaching my opinions regarding
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`validity. This report sets forth the bases and reasons for my opinions, including the
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`additional materials and information relied upon in forming those opinions and
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`conclusions.
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`3.
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`This report is based on information currently available to me. I reserve
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`the right to continue my investigation and analysis, which may include a review of
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`documents and information not yet produced. I further reserve the right to expand
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`or otherwise modify my opinions and conclusions as my investigation and study
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`PGS v. WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2064, pg. 4
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`bins, thereby avoiding holes or uneven distributions of seismic traces that can
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`cause poor data quality within the bins.
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`c. Streamer Tangling
`39. If streamers veer substantially off their intended course, for
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`example due to local currents, they can become entangled. Streamer tangling can
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`damage the streamers and the devices thereon. Tangling can also take a significant
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`time to remedy and, thus, forces the survey operators to cease data collection for an
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`extended period of time. The costs of this can be substantial, as the streamer
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`equipment is enormously expensive, and the efficient conduct of the survey, with
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`minimal downtime, is essential to the profitable conduct of the survey. See Ex.
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`1006 (WO 98/28636) (“’636 PCT”) at 2.
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`d. Turning
`It was well known, since at least the 1970s, that turning operations
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`40.
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`during a survey were encumbered by currents and the centripetal forces of turns
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`that resulted in certain problems during marine seismic surveys, including streamer
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`tangling and wasted time that costs marine seismic surveys substantial amounts of
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`money. Other problems were caused by the relative speeds of cables during turns.
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`A further explanation of marine seismic turn control operations will clarify these
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`problems, which are also disclosed by various references described below.
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`41. During a turn, centripetal and other forces on a streamer generate a
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`force radially inward (i.e., in the direction of the turn) that causes the streamers to
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`“compress together,” as shown in the Figure below.
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`42.
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`In 1998, a person of ordinary skill in the art would have understood
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`(and observed on board vessels during surveys) that this compression effect occurs
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`to streamers during the typical operation of a turn, and such a person would have
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`therefore been motivated to push the streamers radially outward (i.e., in the
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`“opposite direction of the turn”) so that the streamers could (1) avoid tangling; and
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`(2) approximate their original separation and be directed to their original positions
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`(e.g., an optimal straight and parallel streamer configuration, so that marine
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`seismic data collection could resume) upon completion of the turn in a prompt
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`manner. See infra ¶¶ 43-45, 209-10.
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`43.
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`I illustrate three steps of a turn in more detail below. The diagram on
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`the left shows the ideal configuration of the streamers for data collection purposes
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`(that is, a straight and parallel configuration). The diagram on the right illustrates
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`the centripetal forces that act on the streamers and force the streamers together.
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`These forces would be understood by a person of ordinary skill in the art to
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`increase the risk of streamer tangling; moreover, such centripetal force impedes
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`returning the streamers to their original configuration to facilitate subsequent
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`marine seismic data collection along the seismic survey lines. See supra ¶¶ 40-41.
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`This would not be an ideal situation from a marine seismic surveyor’s standpoint,
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`as it would increase the amount of time needed to continue survey operations. The
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`more quickly data collection resumes, the less money is lost while line changing.
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`As I discussed above, time is money in the marine seismic survey industry.
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`Average turns can take anywhere from 1 to 4 hours, depending on the size of the
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`streamer array, and every additional hour of time spent operating a survey vessel,
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`around 1998, would cost approximately $4,000, as it typically would cost about
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`$100,000 per day (or more) to operate a marine seismic survey vessel.
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`44. The
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`last diagram shown below, finally,
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`illustrates
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`the
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`ideal
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`configuration that is to be maintained during a turn. In contrast to the diagram
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`above, where the compressed streamers are quite far from the seismic survey line
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`as the vessel attempts to begin its next pass, the survey vessel in the diagram below
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`maintains its straight and parallel configuration and is well-equipped to begin
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`collecting data along the next line (this ideal configuration, as I discuss below, can
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`be obtained when streamers are steered by streamer steering positioning devices).
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`See infra ¶ 47-51.
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`45.
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`I observed the compression effect described above on streamer cables
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`during turns at least since the 1970s (when I was on survey vessels towing two
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`streamers) and, at that time, I would use booms and other means to maximize the
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`cable separation distance between the cables that were being towed. Another
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`problem I observed relates to the velocities of the streamer cables during a turn. As
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`noted above an ideal speed of streamer cables during a marine seismic survey is
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`approximately 5 knots. However, during turns, the inside streamers travel more
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`slowly than the outside streamers—meaning that those inside streamers may be
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`traveling more slowly than 4 knots. Moreover, if the streamers travel at a speed of
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`less than 3 knots, this can cause the birds on the cables to stall, causing surveyors
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`to lose control of the cables, resulting in additional tangling. Additionally, the
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`outermost streamers may travel too quickly, and need to be controlled at speeds
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`less than 9 knots, otherwise the streamer cables may snap. This was a reason why
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`marine seismic surveyors, once given laterally steerable streamer positioning
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`devices, would have been motivated to control streamers so as to minimize these
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`effects and maintain them in equally spaced configurations throughout the duration
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`of a turn.
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`46. Further disclosures echo the problems I have described above about
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`turning streamers. For example, U.S. Patent No. 4,231,111 (Neeley), a patent filed
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`in 1978 and issued in 1980 describes the tangling concern during turns:
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`One of the primary concerns in towing such a long and
`curved cable is in the steering of the towing vessel past
`other marine vessels or obstacles such as drilling towers,
`etc., in such a way that the projected path of the cable
`does not intersect such other vessels or obstacles. This is
`true not only when the vessel passes such obstacle in a
`straight line but also when the vessel is in a directional
`turn. Under certain conditions the vessel could even turn
`sharply enough to cross the cable itself as it extends one
`or more miles behind the vessel.
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`Ex. 1010 (U.S. Patent No. 4,231,111) (“Neeley”) at 1:62-2:3.
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`And the concern about wasting time because the ship has not been realigned with
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`the survey line was expressed in U.S. Patent No. 4,486,863 (French), which
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`explained that:
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` As mentioned above, areal marine seismic reflection
`surveys are presently conducted using a number of
`substantially equally spaced parallel vessel course lines.
`Usually, one-half of the lines are shot in one direction
`and one-half of the lines are shot in the opposite
`direction. Thus, upon finishing the shooting along one
`line, for example, west to east, the marine vessel comes
`about and a line is shot from east to west. The turns are
`made outside of the area of interest for the survey in
`order to acquire data from the entire area of interest. The
`time that the vessel is outside of the survey area
`represents wasted ship time as far as data acquisition is
`concerned.
`Ex. 1011 (U.S. Patent No. 4,486,863) (“French”) at 1:67-2:10. Thus, the problems
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`associated with streamer turning were well-known, both based on my experiences
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`and the experiences of others.
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`2. Keeping Streamers Straight and Parallel is the Optimal
`Solution to Marine Seismic Data Acquisition Problems
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`It was well accepted by those working in the field of marine seismic
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`47.
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`surveying that it was generally preferable to keep the streamers straight—i.e., they
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`are towed along the pre-planned survey lines—and parallel to each other when
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`acquiring data, in order to avoid many of these problems and acquire optimal
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`seismic data. Streamer steering was known to be desirable to avoid accidents that
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`could damage the survey system. As practitioners in the field have long
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`recognized, ensuring that the streamers stay straight creates the most optimal and
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`efficient survey, because the vessel can follow the survey line while the towed
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`streamers and the associated hydrophones move through and obtain the requisite
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`number of pre-planned data points from the desired bins, as envisioned in the
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`survey design. See ¶¶ 32-35, supra. Moreover, having straight and parallel
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`streamers helps ensure regular spatial sampling within each bin because the
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`streamers—and, thus, the hydrophones—can travel through the bins at roughly the
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`same points, avoiding spatial aliasing as a result of the seismic traces being farther
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`apart than planned and desired.
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`48.
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` Quite simply, it was understood that if the streamers deviate from
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`the predetermined course of the survey design, the hydrophones on the streamers
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`will record data from different bins and in different locations within the bins than
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`the survey design indicated, thereby leading to the reduced data quality and
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`inefficient in-filling problems discussed above.
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`3. Streamer Steering Can be Used to Keep Streamers Straight
`and Parallel
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` Effective streamer steering has long been recognized in the field to
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`49.
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`provide many benefits for seismic surveys. During the seismic survey, the
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`streamers are typically intended to remain straight, parallel to each other and
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`equally spaced. Due to environmental factors such as wind and sea currents,
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`however, seismic streamers frequently bow and undulate, thereby introducing
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`deviations into this desired path and shape. As explained above, without the ability
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`to control the streamers, deviations from desired streamer positions can create gaps
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`in the seismic data coverage, reducing data quality and the efficiency of seismic
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`survey operations. See Ex. 1006 (’636 PCT) at 2; Ex. 1004 (Workman) at 1:28-41.
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`Therefore, an advantage of being able to steer a streamer laterally is the ability to
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`ensure that streamers remain straight and parallel, along their intended path of
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`travel, throughout the seismic survey.
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`50.
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` The use of streamer steering to resolve problems in marine seismic
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`data acquisition has been long known in the art. Both the concern regarding
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`streamer entanglement and the clear solution of horizontally steerable streamers to
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`avoid entanglement were recognized in issued patents as early as the 1970s. See,
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`e.g., Ex. 1009 (U.S. Patent No. 3,605,674) (“Weese”). Quite simply, steerable
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`streamers ensure that streamers do not deviate substantially from their desired
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`course and thereby reduce the risk of adjacent streamers tangling.2 It has also been
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`2 Moreover, for the same reason, it was well recognized that streamer positioning
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`helps the streamer array avoid entanglement, contact, and collisions with
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`potentially damaging obstacles in the ocean. See, e.g., ¶ 68, infra.
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`PGS v. WESTERNGECO (IPR2014-00688)
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`known as early as the 1970s that an advantage of being able to steer a streamer
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`laterally is the ability to ensure that streamers remain straight and parallel, along
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`their intended path of travel, which allows for more efficient and accurate surveys.
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`See, e.g., Ex. 1005 (U.S. Patent No. 3,581,273) (“Hedberg”) at 1:71-2:11, 6:27-32.
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`51.
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`It was commonly understood by anyone experienced in the field of
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`marine seismic in 1998 that it was important to avoid streamer tangling during a
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`turn and return the streamers to their straight and parallel configurations as quickly
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`as possible, as discussed above. Indeed, it would have been understood that, once
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`lateral steering of streamer cables became possible, persons of ordinary skill in the
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`art would have wanted to use such steering to ensure that the streamers do not
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`tangle during a turn and return to their straight and parallel configurations as
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`quickly as possible. It would have been understood that forces in the “opposite
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`direction” of the centripetal forces pushing the streamers inward would have been
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`needed to address the problems related to turning.
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`4. Streamer Positioning Devices to Implement Streamer Steering
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`52. To implement streamer steering, marine seismic surveyors have
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`developed streamer positioning devices. Generally, streamer positioning devices
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`are part of the streamer or are attached to the streamer. Below is a depiction of two
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`prior art streamer positioning devices:
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`correction” calculations to keep the spacing between streamers “set” and
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`“maintained.”
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`2. Feather Angle Mode
`149. As noted above, “feather angle mode” is “a control mode that attempts
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`to keep each streamer in a straight line offset from the towing direction by a certain
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`feather angle.” See supra ¶¶ 112-14. This construction, in my view, is equivalent to
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`a construction that would “set and maintain” all of the streamers in straight lines at
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`identical angles in relation to the towing direction. As explained above, a person of
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`ordinary skill reading Workman would have been motivated to ensure that the
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`spacing between streamer positioning devices was “set” and “maintained” so that
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`streamer tangling could be minimized and seismic data could be optimized.
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`Similarly, a person of ordinary skill would have been motivated to, at minimum,
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`set and maintain the streamers at a zero degree feather angle offset based on the
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`above disclosures. Such uniform spacing between at a zero degree feather angle
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`was desirable, as explained above. Moreover, Workman’s Figure 1 makes clear
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`that persons of ordinary skill in the art optimally wanted streamers to be oriented at
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`a zero degree feather angle in relation to the towing direction of the boat.
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`150. Additionally, a person of ordinary skill would also have been
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`motivated
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`to set and maintain a non-zero feather angle under certain
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`circumstances. First, a person of ordinary skill would want to set and maintain a
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`non-zero degree feather angle when the streamer positioning devices create too
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`much noise in moderate-to-strong currents. Workman disclosed the well-known
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`problem that the noise produced by streamer positioning devices can reduce
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`seismic data quality in certain situations. See Ex. 1004 (Workman) at 1:62-2:9.
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`When streamer positioning devices adjust a water-deflecting surface (such as a
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`wing), that generates more noise because the water’s natural flow over the surface
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`is obstructed. In one example, medium-to-strong current moves the streamers and
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`they may naturally feather at an angle of five degrees. In this situation, attempting
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`to return the streamers to a zero degree feather angle against the current may
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`generate hydrophone noise that adversely affects data quality. In such situations, a
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`person of ordinary skill would understand that it may be more desirable to maintain
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`the streamers at a constant two degree feather angle than to return the streamers to
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`the zero degree feather angle position. It was well-known to persons of ordinary
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`skill that maintaining a straight and constant feather angle—even if non-zero—
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`would produce more reliable seismic data than data retrieved from a cable that was
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`not set and maintained in a straight configuration. See supra ¶ 42. This is because
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`certain problems with data that results from irregular positioning of streamers,
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`known as “smearing,” would result in the absence of a feather angle mode. Such
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`problems may force the surveyor to perform “infill” operations in the same area to
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`collect better data.
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`151. Second, a person of ordinary skill may be motivated to match the
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`feather angles of the plurality of streamers for other reasons. For example, the
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`prospect of 4D marine seismic data acquisition was known in the art prior to 1998.
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`For 4D surveys to be effective, it is critical that the feather angles of repeated
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`surveys are matched. For example, if currents forced a survey at time T to be
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`conducted at a 5 degree feather angle, a survey at time T+Δ would also need to be
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`conducted at such a 5 degree angle to obtain suitable data for 4D purposes. See,
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`e.g., Ex. 1012 (David H. Johnston et. al., “Time-Lapse Seismic analysis of the
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`North Sea Fulmer Field,” SEG Extended Abstracts (1997)) (“Johnston”) at 890
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`(“repeatability of seismic data is a key issue”).
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`152. Additionally, it was well known that placing the streamers at a
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`particular feather angle may be necessary for infilling purposes.
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`153. Given these motivations to have both a zero degree feather angle and
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`non-zero feather angle, and given Workman’s disclosure of multiple laterally
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`steerable streamer positioning devices that can control the shape of cables, a person
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`of ordinary skill reading Workman would have found “feather angle mode”
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`obvious. The lateral steering capability of the streamer positioning devices attached
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`to the streamer, as disclosed in Workman, would have enabled Workman to be
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`configured to separate streamers and maintain them in straight line configurations.
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`Because Workman’s system is readily capable of monitoring the positions of
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`streamers, it would have been trivial to adapt Workman to maintain spacing
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`between streamers using both “minimum” and “maximum allowable separation”
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`threshold parameters. Similarly, given the position determining capabilities of
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`Workman, it also would have been possible to adapt Workman so that its control
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`system could include a parameter that measured the feather angle between
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`streamers.
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`3. One or More “Modes”
`154. Given that the disclosures of both “feather angle mode” and “streamer
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`separation mode” would have been based on Workman, it would have also been
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`obvious to to design a control system that employed one or more of those modes,
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`meeting the limitation of claim 18 that the control system be “configured to use a
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`control mode selected from a feather angle mode, a turn control mode, a streamer
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`separation mode, and two or more of these modes.”
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`155. Though the phrase “control mode” is not employed in Workman, the
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`threshold parameter system disclosed by Workman—in which the distance
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`between streamers was compared to a mimimum threshold and the positions of the
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`streamers moved if the distance fell below the threshold—is a control system that
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`operates in a mode. For the reasons set forth above, it would have been obvious to
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`a person of ordinary skill in the art to modify Workman (if necessary) so that it
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`could be configured to operate in streamer separation mode and/or feather angle
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`were all undesirable. Id. at 11. These concepts would have been fundamental and
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`uncontroversial to those working in the field of marine seismic surveys at the
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`priority date.
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`207. Moreover, the ’153 PCT makes clear that a “turning programme”
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`could be programmed to steer during a turn achieve these well recognized goals of
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`minimizing downtime, optimizing data collection, and avoiding tangling. Such a
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`turning programme is disclosed as part of the ’153 PCT’s “adaptive control system
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`which manoeuvres the [streamer] cable in such a way that [the cable] will be
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`positioned as favourably as possible.” Ex. 1007 at 10. Such a program could be
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`adapted, as part of a global control system, to incorporate the steering requirements
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`of streamer positioning devices during a turn control mode.
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`208. As the disclosures of the ’153 PCT make clear, laterally steerable
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`streamer positioning devices like those disclosed in the ’636 PCT may be
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`programmed in an “adaptive control system” so that streamers may be maintained
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`in an optimal shape during the course of a turn and returned to their optimal
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`position to resume data collection on the next lines to be shot. With the laterally
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`steerable birds of the ’636 PCT in hand, a person of ordinary skill in the art would
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`have had no doubt as to how these goals could be effected during a turn. As
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`explained above, both elementary knowledge of the basic physics of turns and even
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`minimal experience aboard surveys during the data collection phase (far less
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`experience than I possessed) would have indicated clearly that the streamer
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`steering during a turn should be applied to “throw out” streamers in the “opposite
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`direction of the turn,” thereby addressing the streamer compression problem
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`widely recognized in the field, as I have explained above.
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`209. The diagrams below illustrate the effect that a person of ordinary skill
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`would have understood to ensue from adapting the “turning programme” to “throw
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`out the streamers” and then position them consistent with the feather angle mode. I
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`illustrate the desirability of the effect of steering in the four diagrams below. They,
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`like the diagrams illustrated above showing compression, illustrate the centripetal
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`force acting upon the streamers. This time, however, streamer steering forces
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`counteract the centripetal forces so that the “compression effect” described above
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`is minimized and the spacing between the streamers is approximately maintained.
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`This is clear in diagrams 3 and 4, which stand in stark contrast to the other
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`diagrams. Such steering minimizes the risk of streamer tangling and also allows the
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`streamers to obtain their optimal configuration once the survey resumes data
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`collection on its next survey line pass. The boat is ready to begin the next survey
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`line in a configuration that will be straight and parallel.
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`127
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`PGS v. WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2064, pg. 20
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`210. A person of ordinary skill in the art would therefore have been
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`motivated to incorporate the disclosures of the ’153 PCT in implementing the
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`streamer positioning control system of the ’636 PCT. Indeed, given the multiple-
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`streamer environment of the ’636 PCT, the importance of streamer steering during
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`turns, for purposes of efficiency and to avoid tangling (or severe slowing) as a
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`128
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`PGS v. WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2064, pg. 21
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`result of the streamer “compression” problem explained above, would have been
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`especially apparent. Indeed, the need for making turns as efficient as possible was
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`well accepted in the field, and a person of ordinary skill of course would have
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`understood that lateral streamer positioning (of the sort disclosed in ’636 PCT)
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`would have been a useful tool for addressing it. The ’153 PCT provides explicit
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`motivation to provide a turn control mode, though even a passing familiarity with
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`the physical and mechanical forces at play would have led a person of ordinary
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`skill to the same conclusion. Moreover, the ’153 PCT’s disclosure illustrates that
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`one would have been motivated to “throw out” streamers even with one cable, as
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`the centripetal forces still prevent the cable from being aligned with the next
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`survey line, which furnished the primary motivation for the ’153 PCT’s disclosure.
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`211. A person of ordinary skill in the art would clearly have been
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`motivated, given the disclosures of the ’153 PCT, to implement a turn control
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`mode in a multi-streamer configuration, especially when given the laterally
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`steerable birds disclosed in the ’636 PCT. The goals of minimizing turn time and
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`preventing tangling were well-known, and a person of ordinary skill in the
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`artwould have understood that lateral steering could have been employed to steer
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`streamers in “the opposite direction of the turn” so as to prevent streamer tangling
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`while, at the same time, directing the streamers to return to position for data
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`acquisition upon completion of the turn so as to resume data collection as quickly
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`129
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`PGS v. WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2064, pg. 22
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`as possible. Lateral steering would allow this sort of precise positioning,
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`particularly given the plurality of birds on each streamer disclosed by the ’636.
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`212. Additionally, though not required by the claims of the ’520 Patent, a
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`person of ordinary skill in the art would have understood that control systems
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`could easily be adapted such that they steer streamers in multiple phases, so as to
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`apply a force on the streamers in the “opposite direction of the turn” during one
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`phase and then ensure that the streamers are configured consistent with feather
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`angle mode during another phase. See, e.g., Ex. 1060 (Thor Fossen, Guidance and
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`Control of Ocean Vehicles (1994)) at 288 (“Fossen”) (describing a multi-phase
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`turn mode for ship steering). Creating such a “turn control mode” by reference to
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`the ’153 PCT and the ’636 PCT was a predictable solution to a problem that was
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`well-known in the marine seismic area. .
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`213. Given that Claim 23 of the ’520 Patent would have been obvious in
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`light of the disclosures of the ’153 PCT and ’636 PCT applications, Claim 18 is
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`also obvious because that merely requires that the control system be configured to
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`operate in one or more control modes. Claims 1 and 6 must also be obvious in light
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`of these disclosures because they are merely the method claims that implement
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`claims 18 and 23.
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`J. Claims 1, 6, 18, and 23 are Obvious Over Dolengowski in view of the
`’636 PCT
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`130
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`PGS v. WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2064, pg. 23
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`VIII. CONCLUSION
`218. I understand that this report will be filed as evidence in a contested
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`case before the Patent Trial and Appeal Board of the United States Patent and
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`Trademark Office. I also understand that I may be subject to cross-examination
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`concerning this report, and I will appear for cross-examination, if required of me,
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`during the time allotted for cross-examination.
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`219. I hereby declare that all of the statements m