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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`PETROLEUM GEO-SERVICES INC.
`Petitioner
`
`v.
`
`WESTERNGECO LLC
`Patent Owner
`
`
`Case No. IPR2014-01475
`Patent No. 7,162,967
`
`
`
`PETITIONER’S RESPONSES TO
`PATENT OWNER’S INTERROGATORIES
`
`Pursuant to 37 C.F.R. § 42.51(c), Petitioner Petroleum Geo-Services, Inc.
`
`(“PGS”), through its counsel, hereby provides the following objections and
`
`responses to “Patent Owner’s Interrogatories to Petitioners” (“Interrogatories”) as
`
`provided via email to the Board on November 10, 2014.
`
`
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 1
`
`
`
`
`
`
`
`GENERAL OBJECTIONS
`
`The following General Objections form a part of, and are hereby
`
`incorporated into, the response to each and every question set forth below. Nothing
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`in those responses, including any failure to recite a specific objection in response to
`
`a particular request, should be construed as a waiver of any of these General
`
`Objections.
`
`1.
`
`PGS objects to the definition of “petitioners” in the prefatory language
`
`and caption of the Interrogatories to the extent that it suggests that the petitioners in
`
`this proceeding include any entities other than Petroleum Geo-Services, Inc.
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`Petroleum Geo-Services, Inc. is the only petitioner in this proceeding.
`
`2.
`
`PGS objects to the conflicting definitions of “PGS” provided in the
`
`Interrogatories. Compare first sentence of preface with Definition No. 3. The
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`definition of “PGS” applied in these responses is explained below in Definition
`
`No. 1.
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`3.
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`PGS objects to the definition of “Inter Partes Review Proceedings” as
`
`overly broad. The definition of “PGS IPR Proceedings” applied in these responses
`
`is explained below in Definition No. 5.
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`4.
`
`PGS objects to each interrogatory, definition, and instruction as
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`overbroad to the extent that the Interrogatories purport to include a Request For
`
`Production of Documents, and specifically the preface (“Pursuant to 37 C.F.R.
`
`2
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 2
`
`
`
`
`
`§ 42.51(c), WesternGeco requests that production of requested documents be made
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`. . .” and Instruction No. 1 (“In responding to and producing documents and things
`
`responsive to these requests, the responding party will comply with instructions in
`
`the Patent Trial Practice Guide.”). Prior to emailing its Interrogatories to the Board,
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`Patent Owner had not requested —via communication with Petitioner’s counsel or
`
`the Board—to serve a Request For Production on Petitioner. Petitioner has not
`
`agreed to provide any such discovery, Patent Owner has not requested any such
`
`discovery from the Board, and the Board has not ordered any such discovery.
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`5.
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`PGS objects to each interrogatory, definition, and instruction to the
`
`extent that it attempts to impose any discovery duties on PGS beyond the scope of
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`discovery affirmatively imposed or agreed to by any applicable rule, law, doctrine,
`
`or accepted practice.
`
`6.
`
` The responses given herein to any one or more of the interrogatories
`
`shall not be deemed to waive any claim of privilege or immunity that PGS may
`
`have as to any response, document, or information, or any objection that PGS may
`
`have as to a demand for further response to these or other interrogatories. During
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`the teleconference concerning the previously-filed IPR petitions concerning the
`
`same patents, the Board advised that: “The agreement is that Patent Owner will
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`today seek to get an agreement that answering any interrogatories would not be
`
`used as a waiver of privilege in District Court litigation.” Petroleum Geo-Services
`
`3
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 3
`
`
`
`
`
`Inc v. WesternGeco LLC, IPR2014-00678, Paper No. 26, Ex. A (Transcript of
`
`August 27, 2014 Board Conference Call), at 39:15-19. Patent Owner’s
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`Interrogatories include Condition No. 11: “WesternGeco reserves the right to argue
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`that PGS’s affirmative reliance on any documents or information produced in
`
`response to the interrogatories may constitute a waiver of privilege held by the
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`producing party.” In propounding this Condition No. 11, Patent Owner has again
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`affirmatively declined to agree to the precondition of PGS’s offer to provide
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`discovery responses.
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`7.
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`Petitioner objects to Condition No. 11. However, in an effort to
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`resolve the dispute regarding the scope of discovery without the Board’s
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`intervention, PGS nevertheless provides the responses to Patent Owner’s
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`interrogatories, subject to the objections set forth herein, despite the fact that
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`discovery has not been ordered by the Board and is not warranted by governing
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`precedent.
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`8.
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`PGS objects to each interrogatory, definition, and instruction as overly
`
`broad, unduly burdensome, and not reasonably calculated to lead to the discovery
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`of admissible evidence to the extent that it seeks information concerning any
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`subject other than ION’s alleged participation in the preparation or prosecution of
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`the “PGS IPR Proceedings” (defined below). In response to a request for guidance
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`as to the appropriate scope of any potential discovery in IPR proceedings
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`4
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 4
`
`
`
`
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`concerning the same patents, the Board advised that: “And given that, then both
`
`sides will endeavor to negotiate on five interrogatories related to ION's
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`participation in the IPR, hopefully by the end of this week.” Petroleum Geo-
`
`Services Inc v. WesternGeco LLC, IPR2014-00678, Paper No. 26, Ex. A (Transcript
`
`of August 27, 2014 Board Conference Call), at 39:20-23. And Patent Owner
`
`represented to the Board that “My reaction is we are interested in communications
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`that link ION, obviously, to this IPR effort. If the question is do we have a cutoff
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`date, for example, once the IPR was filed, no. We’re looking at communications
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`that lead up to the preparation of that petition. And so, you know, certainly we’re
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`only looking for communications relating to the IPR effort.” Id. at 36:10-19. To
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`the extent that discovery sought does not pertain to ION’s alleged participation in
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`the preparation or prosecution of the PGS IPR Proceedings, PGS objects to the
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`interrogatories as irrelevant.
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`9.
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`PGS objects to each interrogatory to the extent that it calls for the
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`disclosure of information protected by any privilege, including, without limitation,
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`the attorney-client privilege, the work product doctrine, the common interest
`
`privilege, or any other available and valid grounds for withholding information
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`from production. All interrogatories have been read to exclude the discovery
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`and/or production of such privileged information.
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`5
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 5
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`
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`
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`10. PGS’s responses herein are based on facts presently known to PGS
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`and represent a diligent and good faith effort to respond to the interrogatories.
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`PGS’s discovery and investigation into the matters specified is continuing. PGS
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`reserves the right to supplement, alter or change its responses and objections to
`
`these interrogatories and to provide additional responsive information, if any, that
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`PGS has in its possession, custody, or control at the time the interrogatories were
`
`propounded.
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`DEFINITIONS
`
`1.
`
`“PGS” means Petroleum Geo-Services, Inc. Although Patent Owner
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`has not sought leave to serve discovery on PGS Geophysical AS or Petroleum
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`Geo-Services ASA, PGS has conducted a reasonable investigation including PGS
`
`Geophysical AS and Petroleum Geo-Services ASA, and PGS’s responses below do
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`not exclude information that would have been provided by these entities had they
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`been required to answer the following interrogatories.
`
`2.
`
`“ION” means ION Geophysical Corporation, ION International
`
`S.a.r.l., an employee of ION, or a person acting as an agent of ION within the
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`scope of that agency.
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`3.
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`“ION Litigation” means the civil action WesternGeco L.L.C. v. ION
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`Geophysical Corp. et al., 4:09-cv-01827 (S.D. Tex.).
`
`4.
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`“Williams & Connolly” means Williams & Connolly LLP.
`
`6
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 6
`
`
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`
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`5.
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`“PGS IPR Proceedings” means Inter Partes Review Case Nos.
`
`IPR2014-01475; IPR2014-01476; IPR2014-01477; and IPR2014-01478.
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`6.
`
`“Challenged Patents” means U.S. Patent Nos. 6,691,038; 7,162,967;
`
`7,080,607; and 7,293,520—the patents challenged in the PGS IPR Proceedings.
`
`7.
`
`“PGS IPR Petitions” means the petitions filed in the PGS IPR
`
`Proceedings seeking institution of Inter Partes Review.
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`RESPONSES AND OBJECTIONS TO SPECIFIC INTERROGATORIES
`
`INTERROGATORY NO. 1:
`
`Disclose any and all entities identified in and describe any agreements
`regarding William & Connolly’s retention in connection with the Petitions,
`including but not limited to:
`
`(a) any retention agreement;
`
`(b) any invoices or remittances;
`
`(c) any cost-sharing or indemnity agreements, including between PGS and
`
`ION;
`
`(d) any documents relating to ION contributions or reimbursements for any
`expenses related to the Petitions or the preparations thereof.
`
`RESPONSE:
`
`
`
`PGS objects to the scope of this interrogatory as set forth in General
`
`Objection No. 6. PGS objects to this interrogatory as vague and ambiguous with
`
`respect to the relationship between the preamble of the interrogatory and its
`
`subparts. PGS objects to this interrogatory to the extent that it calls for the
`
`disclosure of information protected by any privilege or protection.
`
`7
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 7
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`
`
`
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`
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`Subject to and without waiving the foregoing specific objections and the
`
`General Objections, and based on the information reasonably available to PGS,
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`PGS states that:
`
`
`
`(a) Williams & Connolly has no retention agreement with ION in
`
`connection with the PGS IPR Proceedings. Williams & Connolly has no
`
`agreements of any kind with ION. PGS has no agreements with ION regarding
`
`Williams & Connolly’s retention in connection with the PGS IPR Proceedings.
`
`
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`(b) Williams & Connolly has not provided any invoices to ION or
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`received any remittances from ION, directly or indirectly, in connection with the
`
`PGS IPR Proceedings. PGS has no agreements with ION regarding Williams &
`
`Connolly’s invoices or any remittances related to any of Williams & Connolly’s
`
`invoices.
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`
`
`(c)
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`PGS does not have any cost sharing or indemnity agreements with
`
`ION in connection with the PGS IPR Proceedings. There are no cost sharing or
`
`indemnity agreements with ION regarding Williams & Connolly’s retention in
`
`connection with the PGS IPR Proceedings. PGS incorporates by reference its
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`response to Interrogatory No. 2.
`
`
`
`(d)
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`ION has not made any contribution or reimbursement for any
`
`expenses related to the PGS IPR Petitions or the preparations thereof. There are no
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`documents relating to ION contributions or reimbursements for any expenses
`
`8
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 8
`
`
`
`
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`related to the PGS IPR Petitions or the preparations thereof. There are no
`
`agreements regarding ION making any contributions or reimbursements for any
`
`expenses related to the PGS IPR Proceedings or the preparations thereof.
`
`INTERROGATORY NO. 2:
`
`Disclose and describe all communications between PGS or its counsel and
`ION or its counsel regarding indemnification for infringement of WesternGeco’s
`patents, including but not limited to:
`
`(a) any agreements related to indemnity for infringement of WesternGeco’s
`patents;
`
`(b) any claims or requests for indemnity for infringement of WesternGeco’s
`patents;
`
`(c) any discussions regarding litigation funding or expenses patent disputes
`with WesternGeco.
`
`RESPONSE:
`
`
`
`PGS objects to this interrogatory as vague and ambiguous with respect to the
`
`relationship between the preamble of the interrogatory and its subparts. PGS
`
`objects to “WesternGeco’s patents” as vague and ambiguous; PGS interprets the
`
`phrase to mean the Challenged Patents. PGS objects to subpart (c) of this
`
`interrogatory as vague and ambiguous; PGS interprets it to mean “any discussions
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`regarding litigation funding or expenses for patent disputes with WesternGeco.”
`
`
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`Subject to and without waiving the foregoing specific objections and the
`
`General Objections, and based on the information reasonably available to PGS,
`
`PGS states that:
`
`9
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 9
`
`
`
`
`
`
`
`(a)
`
`PGS is aware of the following agreements between PGS (or PGS
`
`affiliates) and ION that may relate to ION’s DigiFIN products that WesternGeco
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`accused of infringing the Challenged Patents during the ION Litigation. For
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`clarity, inclusion of an agreement below should not be understood to indicate that
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`the agreement is “related to indemnity for infringement of WesternGeco’s
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`patents”: PGSI-T2725-WG-0043542, PGSI-T2725-WG-0046267, PGSI-T2725-
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`WG-0046459, PGS-JURID_00000130, PGSI-T2725-WG-0043570, PGSI-T2725-
`
`WG-0046580, PGS-JURID_00000227, PGSI-T2725-WG-0043598, PGSI-T2725-
`
`WG-0046610, PGS-JURID_00000201, PGSI-T2725-WG-0043422, PGSI-T2725-
`
`WG-0043426, PGSI-T2725-WG-0046520, PGS-JURID_00000037, PGSI-T2725-
`
`WG-0046321, PGSI-T2725-WG-0046439, PGS-JURID_00000184, PGSI-T2725-
`
`WG-0046295, PGSI-T2725-WG-0046413, PGS-JURID_00000158, PGSI-T2725-
`
`WG-0043453, PGSI-T2725-WG-0043490, PGSI-T2725-WG-0046547, PGS-
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`JURID_00000064, PGSI-T2725-WG-0047173, PGSI-T2725-WG-0043518, PGSI-
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`T2725-WG-0046487, PGS-JURID_00000097, PGSI-T2725-WG-0043360, PGSI-
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`T2725-WG-0046458, PGSI-T2725-WG-0043624, PGSI-T2725-WG-0046246,
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`PGSI-T2725-WG-0046385.
`
`
`
`10
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 10
`
`
`
`
`
`
`
`(b)
`
`PGS is not aware of any communications between PGS (or PGS’s
`
`affiliates) or their counsel and ION or its counsel regarding any claims or requests
`
`for indemnity for infringement of the Challenged Patents.
`
`
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`PGS is aware of the following communications between PGS Geophysical
`
`AS and ION that do not constitute communications regarding claims or requests
`
`for indemnity:
`
`
`
`On June 28, 2012, in the context of negotiating a new agreement between a
`
`PGS entity and ION, ION’s general counsel David L. Rowland stated that “past
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`equipment and software sales contracts agreed to between PGS and ION did not
`
`contain any patent infringement protection for PGS[.]” (This email was produced
`
`in district court litigation at PGSI-T2725-WG-0047218.)
`
`
`
`On November 13, 2012, PGS Geophysical AS wrote to ION to inform ION
`
`that it had received a demand letter from Kirkland & Ellis LLP (trial counsel to
`
`WesternGeco). (The letter was produced in district court litigation at PGSI-T2725-
`
`WG-0047303.) The letter identified the following language contained in various
`
`Master Purchase Agreements between PGS Geophysical AS and ION: “the
`
`trademarks, trade names, patents, logos and symbols, owned, controlled or adopted
`
`by [ION] by any of its affiliates in respect of the Products are the exclusive
`
`property of [ION] or that [ION] has licenses to use the foregoing.” The letter also
`
`identified the following provision in a 2008 agreement between PGS Geophysical
`
`11
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 11
`
`
`
`
`
`AS and ION’s Concept Systems Ltd. (“ION Concept”): “[ION Concept is]
`
`responsible for ensuring that no part of the Equipment or the intended use of any
`
`part of the Equipment conflicts with any patent rights or other intellectual property
`
`rights belonging to third parties. [ION Concept] shall indemnify PGS from any
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`claim by third parties regarding breach of the said rights.” PGS made clear in the
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`letter that it reserved the right to exercise any rights or remedies under such
`
`provisions and that it was not doing so as of November 13, 2012 because, for
`
`example, “threshold questions such as whether ION had the proper patent licenses
`
`have not yet been finally resolved by the courts.”
`
`
`
`On January 8, 2013, ION responded to the PGS Geophysical AS’s
`
`November 13, 2012 letter. (The letter was produced in district court litigation at
`
`PGSI-T2725-WG-0047309.) With respect to PGS Geophysical AS’s notification
`
`concerning various contract provisions, ION stated that:
`
`ION believes that your company ultimately should not be
`exposed to liability for the same claims of patent
`infringement that are resolved in the lawsuit against ION.
`Finally, there is no blanket remedy under the Master
`Purchase Agreement. Remedies, if any, are both fact and
`contract dependent. Nonetheless, it is not appropriate to
`discuss remedies when no concrete action or claim has
`been asserted against PGS, the trial court proceedings are
`in progress, and near-term rulings may clarify whether
`remedies are even an issue for analysis and discussion.
`
`12
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 12
`
`
`
`
`
`
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`(c) There have been no discussions between PGS or its counsel and ION
`
`or its counsel regarding litigation funding or expenses for patent disputes with
`
`WesternGeco.
`
`INTERROGATORY NO. 3:
`
`Disclose and describe any prior art references that ION or its counsel
`disclosed to PGS or its counsel, including but not limited to the prior art references
`discussed in a June 2, 2014 email from Phillip Shotts to Kevin Hart (PGSI-T2725-
`WG-0047296), such disclosure and description including but not limited to:
`
`(a) the identity of the reference;
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`(b) the date of the disclosure;
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`(c) the names and affiliations of the people involved;
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`(d) any discussions associated with or subsequent to the disclosure.
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`RESPONSE:
`
`
`
`PGS objects to this interrogatory as vague and ambiguous with respect to the
`
`relationship between the preamble of the interrogatory and its subparts. PGS
`
`objects to the scope of this interrogatory as vague and ambiguous with respect to
`
`“any discussions associated with or subsequent to the disclosure;” PGS interprets
`
`this phrase to mean any such discussions with ION or its counsel. PGS objects to
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`this interrogatory to the extent that it calls for the disclosure of information
`
`protected by any privilege or protection.
`
`13
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 13
`
`
`
`
`
`
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`Subject to and without waiving the foregoing specific objections and the
`
`General Objections, and based on the information reasonably available to PGS,
`
`PGS states that:
`
`
`
`The June 2, 2014 email (PGSI-T2725-WG-0047296) from Phillip Shotts
`
`(ION) to Kevin Hart (PGS) was unsolicited. The email does not identify any prior
`
`art reference. On or about June 2, 2014, Mr. Hart left a voicemail for Mr. Shotts in
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`which he acknowledged receipt of the email but declined at the time to engage in a
`
`discussion concerning the company referenced in the email or any prior art. Mr.
`
`Hart has not had any further communications with Mr. Shotts concerning the email
`
`of June 2, 2014, the company referenced in the email, or any prior art that may
`
`relate to the June 2, 2014 email or the company referenced in the email.
`
`Subsequent to the June 2, 2014 email, Mr. Shotts has not provided any information
`
`concerning any prior art reference, including but not limited to any prior art
`
`referenced in the June 2, 2014 email. PGS is unaware of the identity of the prior
`
`art reference that Mr. Shotts suggested may exist in his June 2, 2014 email.
`
`
`
`There were no meetings between PGS and ION concerning the PGS IPR
`
`Proceedings.
`
`
`
`There was only one call between counsel for PGS and counsel for ION
`
`regarding validity of any Challenged Patent and that related in any way to any IPR
`
`proceeding filed by PGS. The conference call was requested by counsel for PGS
`
`14
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 14
`
`
`
`
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`to learn particular facts about the ION Litigation. Regarding this single conference
`
`call:
`
`(a) The conference call occurred on February 14, 2014 at approximately
`
`11:30 AM EST, and lasted no more than 30 minutes.
`
`(b)
`
`Jessamyn Berniker, William Doffermyre, and Alec Swafford from
`
`Williams & Connolly were on the call. Kevin Hart from PGS was on
`
`the call. To the best of PGS’s knowledge, Phillip Shotts of ION and
`
`Jonathan Pierce from Porter & Hedges were on the call.
`
`(c) Consistent with the purpose of the call, counsel for PGS asked counsel
`
`for ION whether, and if so on what basis, WesternGeco had disputed
`
`during the ION Litigation the prior art status of PCT Application No.
`
`WO98/28636 (the ’636 PCT) in relation to Patent Nos. 7,162,967,
`
`7,080,607, and 7,293,520. In this context, the statute 35 U.S.C. § 363
`
`was also discussed. Neither the substance of, nor the disclosures
`
`contained in, the ’636 PCT or any other prior art reference were
`
`discussed.
`
`(d) No documents were exchanged during the conference call. In two
`
`follow-up email messages from Jonathan Pierce to Kevin Hart and
`
`Philip Shotts, Mr. Pierce identified two cases relating to 35 USC §
`
`363 that Mr. Pierce represented had been discussed with WesternGeco
`
`15
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 15
`
`
`
`
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`counsel in the context of discussing jury instructions during the ION
`
`Litigation: (1) Broad. Innovation, L.L.C. v. Charter Communications,
`
`Inc., 420 F.3d 1364, 1365-69 (Fed. Cir. 2005); and (2) Sanitec Indus.
`
`v. Micro-Waste Corp., CIV.A. H-04-3066, 2006 WL 3455000 (S.D.
`
`Tex. Nov. 28, 2006) aff'd sub nom. Sanitec Indus., Inc. v. Micro-
`
`Waste Corp., 296 F. App’x 44 (Fed. Cir. 2008) - Sanitec Indus., Inc. v.
`
`Micro-Waste Corp., 296 F. App’x 44, 45 (Fed. Cir. 2008). PGS cited
`
`neither case in the IPR Petitions it has filed regarding the Challenged
`
`Patents.
`
`
`
`PGS is also aware of an email chain that was produced in district court
`
`litigation between Patent Owner and PGS (PGSI-T2725-WG-0046686). This
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`email chain begins with a request by PGS in-house counsel Kevin Hart on behalf
`
`of “PGS/Irell” (Irell & Manella LLP is PGS’s trial counsel) for copies of ION’s
`
`invalidity contentions from the ION Litigation because “receiving them from WG
`
`[Patent Owner] would take some time.” ION’s outside counsel Jonathan Pierce
`
`provided copies of ION’s non-confidential invalidity contentions to Irell &
`
`Manella LLP and Mr. Hart. Patent Owner subsequently produced these materials
`
`to PGS in the district court proceedings approximately three weeks after ION’s
`
`counsel provided them to Irell & Manella. Mr. Hart did not refer to or use these
`
`16
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 16
`
`
`
`
`
`materials in connection with the PGS IPR Proceedings. Williams & Connolly did
`
`not refer to or use these materials in connection with the PGS IPR Proceedings.
`
`PGS never has discussed the substance of the PGS IPR Petitions with ION
`
`or its counsel, never has engaged in any substantive discussions with ION
`
`regarding the scope and content of the prior art in the PGS IPR Petitions, never has
`
`discussed with ION any comparison of the prior art to any claims challenged in the
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`PGS IPR Petitions, never has transmitted to ION any PGS IPR Petition or draft
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`thereof, never has sought, solicited, or obtained input from ION regarding the PGS
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`IPR Petitions, arguments or prior art to include in the PGS IPR Petitions, or the
`
`filing of the PGS IPR Petitions. ION has exercised no control whatsoever over the
`
`PGS IPR Petitions or PGS IPR proceedings.
`
`
`
` /s/ David I. Berl
`By:
`David I. Berl
`Attorney for Petitioner
`Petroleum Geo-Services, Inc.
`Registration No. 72,751
`
`Date: November 20, 2014
`
`
`
`
`
`
`
`
`
`
`
`17
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 17
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`(37 C.F.R. §§ 42.6(e) and 42.105(a))
`
`The undersigned hereby certifies that the above-captioned Petroleum Geo-
`
`Service Inc.’s “PETITIONER’S RESPONSES TO PATENT OWNER’S
`
`INTERROGATORIES” were served on this 20th day of November, 2014, on the
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`Patent Owner by delivering a copy via electronic mail to the following individuals
`
`at the email addresses below, as consented to by the Patent Owner:
`
`Scott A. McKeown (CPdocketMcKeown@oblon.com)
`Christopher A. Bullard (CPdocketBullard@oblon.com)
`Michael L. Kiklis (CPdocketKiklis@oblon.com)
`
`
`
`
`
`
` /s/ David I. Berl
`By:
`David I. Berl
`Attorney for Petitioner
`Petroleum Geo-Services, Inc.
`Registration No. 72,751
`
`Date: November 20, 2014
`
`
`
`
`
`
`
`18
`
`PGS v WESTERNGECO (IPR2014-00688)
`WESTERNGECO Exhibit 2071, pg. 18
`
`
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