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`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_________________________
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`PETROLEUM GEO-SERVICES INC.
`
`Petitioner
`
`v.
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`WESTERNGECO, LLC
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`Patent Owner
`
`________________________
`
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
`________________________
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`PATENT OWNER’S MOTION TO SEAL UNDER
`37 C.F.R. §§ 42.14 AND 42.54
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`
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`Pursuant to 37 C.F.R. §§ 42.14 and 42.54, Patent Owner, WesternGeco
`
`Patent Owner’s Motion to Seal
`Case IPR2014-0689
`U.S. Patent No. 7,293,520
`
`
`L.L.C (“WesternGeco” or “Patent Owner”) submits this Motion to Seal certain
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`exhibits submitted with Patent Owner’s Response filed on March 20, 2014.
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`Patent Owner’s Response and certain accompanying exhibits were filed
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`under seal because they contain information designated as confidential by Patent
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`Owner, Petitioner, or a Third-Party. The below table lists those documents that the
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`Patent Owner believes should remain under seal.
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`I.
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`Reasons for Sealing Certain Confidential Information
`A.
`Exhibits 2052, 2069, 2077, 2079, 2080, and 2086 were filed under seal. As
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`Patent Owner Response Exhibits
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`set forth in Table 1, below, good cause exists for maintaining these exhibits under
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`seal. It is noted that each of these exhibits is identical to exhibits with the same
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`number in related proceedings IPR2014-00687 and IPR2014-00688.
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`Table 1: Exhibits to Patent Owner’s Response that Should Remain Under Seal
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`Exhibit
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`Description
`
`Good Cause
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`2052
`
`Excerpts of Deposition
`Transcript of Oyvind
`Hillesund, WesternGeco
`L.L.C. v. Ion Geophysical
`Corporation, Civil Action No.
`4:09-CV-01827.
`2069 Agreement Between PGS
`Geophysical A.S. and another
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`This exhibit contains party
`confidential information and is
`subject to a protective order in
`WesternGeco L.L.C. v. Ion
`Geophysical Corporation, Civil
`Action No. 4:09-CV-01827.
`This exhibit contains confidential
`business information between PGS
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`
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`2
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`
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`Exhibit
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`Description
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`Patent Owner’s Motion to Seal
`Case IPR2014-0689
`U.S. Patent No. 7,293,520
`
`
`Good Cause
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`party, WesternGeco L.L.C.v.
`Petroleum Geo-Services Inc.,
`Civil Action No. 4:13-cv-
`02725, PGS-
`JURID_00000158-183.
`Declaration of Robin C.
`Walker (“Walker
`Declaration”).
`
`Application of Q-Marine
`Technology for SPC; Imaging
`the Pinghu Field Gas
`Reservoirs by M. Garden, T.
`Bunting
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`Presentation Titled: “Q-Marine
`Improvements” by Robin
`Walker
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`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.
`The Walker declaration is cited in
`support of Patent Owner’s Response
`and includes confidential business
`information of Patent Owner.
`This exhibit is a draft of an article
`published in Offshore magazine (July
`2008) containing confidential
`information regarding WesternGeco’s
`Q-Marine system that was not
`released in the published article.
`This exhibit contains confidential
`business information regarding
`WesternGeco’s Q-Marine system
`included as part of an internal
`PowerPoint presentation.
`This exhibit contains confidential
`business information regarding
`WesternGeco’s Q-Marine system
`included as part of an internal
`PowerPoint presentation.
`II. Certification of Non-Publication Status
`Patent Owner’s undersigned counsel certifies that the information sought to
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`2077
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`2079
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`2080
`
`2086
`
`Presentation Titled: “4D
`Acquisition with Q-Marine
`Experiences and Strategies
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`be sealed by this motion has not been published or otherwise made public to the
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`best of his knowledge.
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`
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`3
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`
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`III. Certification of Conference with Opposing Party Pursuant to 37 C.F.R.
`§ 42.54
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`Patent Owner’s Motion to Seal
`Case IPR2014-0689
`U.S. Patent No. 7,293,520
`
`
`Patent Owner has in good faith conferred with Petitioner, and the parties
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`have agreed to a protective order in this case, Ex. 2038. Petitioner has taken no
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`position on whether it will oppose this motion.
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`IV. Request For Relief
`Patent Owner requests that the following exhibits remain under seal:
`
`2052, 2069, 2077, 2079, 2080, and 2086.
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`
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`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.
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`Dated: March 20, 2015
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`Customer Number
` 22850
`Tel. (703) 413-3000
`Fax. (703) 413-2220
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`
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`4
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`
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the foregoing MOTION TO SEAL
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`was served electronically on March 20, 2015, in their entireties upon the following
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`counsel for Petitioner Petroleum Geo-Services, Inc.:
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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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`/Michael L. Kiklis/
`Michael L. Kiklis
`Registration No. 38,939
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`Attorney for Patent Owner
`WESTERNGECO L.L.C.
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`Date: March 20, 2015
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