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UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________________
`
`PETROLEUM GEO-SERVICES INC.
`and
`ION GEOPHYSICAL CORPORATION
`AND ION INTERNATIONAL S.A.R.L,
`
`Petitioners,
`
`v.
`
`WESTERNGECO LLC
`
`Patent Owner.
`
`____________
`
`Case IPR2014-006891
`
`U.S. Patent No. 7,293,520
`____________
`
`PATENT OWNER’S MOTION TO SEAL UNDER
`37 C.F.R. §§ 42.14 AND 42.54
`
`
`1 Case IPR2015-00565 has been joined with this proceeding.
`
`

`
`Pursuant to 37 C.F.R. §§ 42.14 and 42.54, Patent Owner, WesternGeco
`
`Patent Owner’s Motion to Seal
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
`
`
`L.L.C (“WesternGeco” or “Patent Owner”) submits this Motion to Seal Patent
`
`Owner’s Request for Rehearing Under 37 C.F.R. § 42.71(d) (“Patent Owner’s
`
`Request for Rehearing”) filed on January 14, 2016.
`
`I.
`
`Reasons for Sealing Patent Owner’s Request for Rehearing
`
`Patent Owner’s Request for Rehearing contains direct quotations from
`
`Exhibit 2069, which was previously designated as confidential in this proceeding
`
`because it contains confidential business information between PGS Geophysical
`
`A.S. and a third-party and is subject to a protective order in WesternGeco L.L.C.v.
`
`Petroleum Geo-Services Inc., Civil Action No. 4:13-cv-02725.
`
`II. Certification of Non-Publication Status
`Patent Owner’s undersigned counsel certifies that the information sought to
`
`be sealed by this motion has not been published or otherwise made public to the
`
`best of his knowledge.
`
`III. Certification of Conference with Opposing Party Pursuant to 37 C.F.R.
`§ 42.54
`
`At the time Ex. 2069 was filed in this proceeding, Patent Owner conferred in
`
`good faith with Petitioners, whom did not oppose Patent Owner’s original motion
`
`to seal the exhibit. Pursuant to that agreement, and the protective order in this case
`
`(Ex. 2038), Patent Owner’s Request for Rehearing containing direct quotations
`
`1
`
`

`
`from Exhibit 2069 is similarly being filed under seal.
`
`Patent Owner’s Motion to Seal
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
`
`
`IV. Request For Relief
`Patent Owner requests that Patent Owner’s Request for Rehearing remain
`
`Respectfully submitted,
`Oblon, McClelland, Maier &
`Neustadt, LLP
`
`
`
`/Michael L. Kiklis/
`Michael L. Kiklis
`Registration No. 38,939
`
`Attorney for Patent Owner
`WESTERNGECO L.L.C.
`
`
`
`under seal.
`
`
`
`
`Dated: January 14, 2016
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Customer Number
` 22850
`Tel. (703) 413-3000
`Fax. (703) 413-2220
`
`
`
`2
`
`

`
`Patent Owner’s Motion to Seal
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies service of MOTION TO SEAL on the
`
`counsel of record for the Petitioners by filing this document through the Patent
`
`Review Processing System as well as delivering a copy via electronic mail to the
`
`following addresses:
`
`David Berl
`dberl@wc.com
`
`Jessamyn Berniker
`jberniker@wc.com
`
`Thomas S. Fletcher
`tfletcher@wc.com
`
`Christopher Suarez
`csuarez@wc.com
`
`W. Karl Renner
`Roberto Devoto
`IPR37136-0004IP1@fr.com
`
`
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`
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`
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`
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`
`
`
`
`/Michael L. Kiklis/
`Michael L. Kiklis
`Registration No. 38,939
`
`
`Attorney for Patent Owner
`WESTERNGECO L.L.C.
`
`3
`
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`
`
`Date: January 14, 2016

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