`
`———————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————————
`
`PETROLEUM GEO-SERVICES INC.,
`Petitioner
`
`v.
`
`WESTERNGECO LLC
`Patent Owner
`
`———————————
`
`Cases
`IPR2014-00687 (U.S. Patent No. 7,162,967)
`IPR2014-00688 (U.S. Patent No. 7,080,607)
`IPR2014-00689 (U.S. Patent No. 7,293,520)
`———————————
`
`SECOND SUPPLEMENTAL DECLARATION OF ROBIN C. WALKER
`
`
`
`Pursuant to 28 U.S.C. § 1746, I, Robin C. Walker, the undersigned, hereby declare as
`
`follows:
`
`1.
`
`My name is Robin C. Walker. I am over eighteen years of age, of sound
`
`mind, and in all ways qualified and competent to make this declaration. I have personal
`
`knowledge of the facts contained in this declaration and they are true and correct.
`
`2.
`
`I have worked in the marine seismic industry for 30 years in technical,
`
`research and customer-facing roles. Through my experience, I have developed first-hand
`
`knowledge of the technologies that have driven customer demand and enabled effective
`
`acquisition techniques in this industry. During my 30 year tenure at Schlumberger, I rose to be
`
`the Vice President of Sales and Marketing Director for WesternGeco from March 2008 to March
`
`2013 and a Global Account Director for Schlumberger from March 2013 to January 2015. I am
`
`WESTERNGECO Exhibit 2140, pg. 1
`PGS v. WESTERNGECO
`IPR2014-00688
`
`
`
`particularly knowledgeable about the development, marketing and sales of WesternGeco’s Q-
`
`Marine System and the market’s reception of Q-Marine and other systems that practice the
`
`patents I understand to be at issue in this proceeding (“Bittleston patents”).
`
`3.
`
`Exhibit 2129 is a true and correct copy of my trial demonstratives in the
`
`WesternGeco L.L.C. v. ION Geophysical Corp. et al., Civ. No. 09-1827 (S.D. Tex.) litigation.
`
`4.
`
`Exhibit 2130 is a true and correct copy of email correspondence dating
`
`from 2007 with subject line “Libya Technical Seminar,” in which I participated during my time
`
`at WesternGeco. This correspondence was made and kept in the ordinary course of
`
`WesternGeco’s business.
`
`5.
`
`Exhibit 2131 is a true and correct copy of an excel spreadsheet that I
`
`authored between 1994 and 1996 during my time at WesternGeco. This spreadsheet was made
`
`and kept in the ordinary course of WesternGeco’s business.
`
`6.
`
`Exhibit 2132 is a true and correct copy of a spreadsheet dating from 2010
`
`titled “Tims stats 2005 to 2009 Retrieve 1” that was produced by employees at WesternGeco and
`
`that I received during my time at WesternGeco. This spreadsheet was made and kept in the
`
`ordinary course of WesternGeco’s business.
`
`7.
`
`Exhibit 2133 is a true and correct copy of an email dating from 2004 with
`
`subject line “AKPO/COMBO,” which I received during my time at WesternGeco. This
`
`correspondence was made and kept in the ordinary course of WesternGeco’s business.
`
`8.
`
`Exhibit 2134 is a true and correct copy of an email dating from 2002 with
`
`subject line “Status report for May, 2002,” which I received during my time at WesternGeco.
`
`This correspondence was made and kept in the ordinary course of WesternGeco’s business.
`
`WESTERNGECO Exhibit 2140, pg. 2
`PGS v. WESTERNGECO
`IPR2014-00688
`
`
`
`WESTERNGECO Exhibit 2140, pg. 3
`PGS v. WESTERNGECO
`IPR2014-00688
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