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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`PETROLEUM GEO-SERVICES INC.
`and
`ION GEOPHYSICAL CORPORATION
`AND ION INTERNATIONAL S.A.R.L,
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`Petitioners,
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`v.
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`WESTERNGECO LLC
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`Patent Owner.
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`____________
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`Case IPR2014-006881
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`U.S. Patent No. 7,080,607
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`____________
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`PATENT OWNER’S OPPOSITION TO MOTION FOR PRO HAC VICE
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`1 Case IPR2015-00567 has been joined with this proceeding.
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`Patent Owner’s Opposition to Motion for Pro Hac Vice
`Case IPR2014-00688
`U.S. Patent No. 7,080,607
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`Patent Owner, WesternGeco LLC (“Patent Owner” or “WesternGeco”),
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`opposes ION Geophysical Corporation’s and ION International S.A.R.L.’s
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`(collectively, “ION’s”) Motion for Pro Hac Vice of David Healey as it (1) violates
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`the Board’s Order joining ION as a party to this inter partes review (“IPR”)
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`proceeding and (2) unduly prejudices Patent Owner.
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`When the Board joined ION as a party to this proceeding, the Board ordered
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`that “ION is not permitted to file papers.” See Paper 55 at 6 (emphasis added).
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`Now, less than one week after the Board issued its Order granting joinder, ION is
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`doing exactly what it is prohibited from doing by filing the instant motion.
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`Not only is ION in violation of the Board’s Order, but ION’s motion also
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`unduly prejudices Patent Owner. Despite knowing the location and time of the
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`deposition of Mr. Robin Walker for almost a week, ION waited until the eve of
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`Mr. Walker’s deposition to file this motion, which it obviously had ready for some
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`time. Due to this delay, Patent Owner was forced to draft an opposition to this
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`Motion in less than two and a half hours on the eve of an important deposition.
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`Moreover, ION already has counsel of record who could have attended the
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`deposition without burdening this Board or Patent Owner with this expedited and
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`unnecessary briefing. Quite simply, this motion is untimely and prejudicial and
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`thus should be should be denied.
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`2
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`Patent Owner’s Opposition to Motion for Pro Hac Vice
`Case IPR2014-00688
`U.S. Patent No. 7,080,607
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`ION’s motion is simply an attempt to further skirt the Board’s Order by
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`having ION’s trial counsel at the deposition to “act on ION’s behalf.” See Ex.
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`2128. ION, however, is not allowed to participate in the deposition. Paper 55 at 6.
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`Accordingly, if the Board grants ION’s motion, Patent Owner requests that the
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`Board specify that, although ION may attend the deposition, it may not
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`“participate,” meaning that ION should not be allowed to confer or communicate
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`in any way with Petroleum Geo-Services Inc.’s (“PGS’s”) counsel or its
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`representatives from the time the witness is sworn in until the time the deposition
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`has concluded.
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`For the forgoing reasons, Patent Owner respectfully requests that the Board
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`deny ION’s Motion for pro hac vice admission of David J. Healey. Patent Owner
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`also reserves all rights, including its right to oppose ION being a party to this
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`proceeding.
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`3
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`Patent Owner’s Opposition to Motion for Pro Hac Vice
`Case IPR2014-00688
`U.S. Patent No. 7,080,607
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`Respectfully submitted,
`Oblon, McClelland, Maier &
`Neustadt, LLP
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`/Michael L. Kiklis/
`Michael L. Kiklis (Reg. No. 38,939)
`Attorney for Patent Owner
`WESTERNGECO L.L.C.
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`Dated: April 29, 2015
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`Customer Number
` 22850
`Tel. (703) 413-3000
`Fax. (703) 413-2220
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`4
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`Patent Owner’s Opposition to Motion for Pro Hac Vice
`Case IPR2014-00688
`U.S. Patent No. 7,080,607
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`CERTIFICATE OF SERVICE
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`
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies service of
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`PATENT OWNER’S OPPOSITION TO MOTION FOR PRO HAC VICE and
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`EXHIBIT 2128 on the counsel of record for the Petitioners by filing this document
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`through the Patent Review Processing System as well as delivering a copy via
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`electronic mail to the following addresses:
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`David Berl
`dberl@wc.com
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`Jessamyn Berniker
`jberniker@wc.com
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`Thomas S. Fletcher
`tfletcher@wc.com
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`Christopher Suarez
`csuarez@wc.com
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`W. Karl Renner
`Roberto Devoto
`IPR37136-0002IP1@fr.com
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`/Michael L. Kiklis/
`Michael L. Kiklis (Reg. No. 38,939)
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`Dated: April 29, 2015
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`5