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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PETROLEUM GEO-SERVICES INC.
`and
`ION GEOPHYSICAL CORPORATION
`AND ION INTERNATIONAL S.A.R.L.
`Petitioners
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`v.
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`WESTERNGECO, LLC
`Patent Owner
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`Case IPR2014-006881
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`U.S. Patent No. 7,080,607
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`PETITIONER PETROLEUM GEO-SERVICES INC.’S MOTION TO SEAL
`PORTIONS OF ITS REPLY IN SUPPORT OF MOTION TO EXCLUDE
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`1 Case IPR2015-00567 has been joined with this proceeding.
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`Pursuant to 37 CFR § 42.14, Petitioner Petroleum Geo-Services Inc. (PGS)
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`respectfully submits this Motion to Seal Portions of its Reply in Support of Motion
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`to Exclude, which is being filed concurrently with this Motion.
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`I.
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`Reasons for Redacting Portions of the Motion
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`The standard governing the Board’s determination of whether to grant a
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`motion to seal is “good cause.” Garmin v. Cuozzo, IPR2012-0001, Paper 36 (April
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`5, 2013). The board aims to “strike a balance between the public’s interest in
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`maintaining a complete and understandable file history and the parties’ interest in
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`protecting truly sensitive information.” Id.
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`PGS’s Motion discusses exhibits (1089, 2077, and 2103) that have been
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`designated by WesternGeco as containing business confidential information. These
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`exhibits, the statements and deposition transcript of Mr. Robin Walker in this
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`proceeding, have been designated as confidential by WesternGeco. Pursuant to
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`Section 4(A)(ii) of the Board’s default protective order applicable in this
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`proceeding, PGS has filed a confidential, non-redacted version of its Motion as well
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`as a redacted version of its Motion to remove references and citations to the sealed
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`information and exhibits. Because the redacted portions of the Motion are subject
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`to the aforementioned protective orders, Petitioner brings this motion to seal with
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`good cause.
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`II. Conclusion
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`For the foregoing reasons, Petitioner requests that the Board grant
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`Petitioner’s Motion to Seal. Petitioner understands that the documents filed
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`concurrently with this motion will remain sealed pending the outcome of the
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`decision on this motion. See 37 C.F.R. § 42.14. Should the Board require it before
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`deciding this motion, PGS is prepared to meet and confer with WesternGeco to
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`prepare any Joint Motion to Seal that may be required to further clarify the bases
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`Respectfully Submitted,
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` /David Berl/
`David Berl
`Reg. No. 72,751
`Williams & Connolly, LLP
`725 12th St., NW
`Washington, DC 20005
`Phone: 202-434-5491
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`for sealing the above documents.
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`Dated: July 13, 2015
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the above-captioned Petitioner
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`Petroleum Geo-Service Inc.’s Motion to Seal Portions of Its Reply in Support of
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`Motion to Exclude was served on July 13, 2015, by delivering a copy via electronic
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`mail upon the following attorneys of record.
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`For Petitioner ION Geophysical Corporation and ION International S.A.R.L.:
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`W. Karl Renner
`Roberto Devoto
`IPR37136-0002IP1@fr.com
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`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`202-783-5070
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`For Patent Owner:
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`Michael L. Kiklis
`CPDocketKiklis@oblon.com
`Scott McKeown
`CPDocketMcKeown@oblon.com
`Kevin Laurence
`CPDocketLaurence@oblon.com
`Katherine Cappaert
`CPDocketCappaert@oblon.com
`Christopher Ricciuti
`CPDocketRicciuti@oblon.com
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`Oblon
`1940 Duke Street
`Alexandria, Virginia 22314
`703-413-3000
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`Respectfully submitted,
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` /David Berl/
`David Berl
`Reg. No. 72,751
`Williams & Connolly, LLP
`725 12th St., NW
`Washington, DC 20005
`Phone: 202-434-5491
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`DATE: July 13, 2015.
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