`
`____________
`
`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 OPPOSITION TO MOTION FOR PRO HAC VICE
`
`
`
`
`
`
`
`
`1 Case IPR2015-00565 has been joined with this proceeding.
`
`
`
`Patent Owner’s Opposition to Motion for Pro Hac Vice
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
`
`
`Patent Owner, WesternGeco LLC (“Patent Owner” or “WesternGeco”),
`
`opposes ION Geophysical Corporation’s and ION International S.A.R.L.’s
`
`(collectively, “ION’s”) Motion for Pro Hac Vice of David Healey as it (1) violates
`
`the Board’s Order joining ION as a party to this inter partes review (“IPR”)
`
`proceeding and (2) unduly prejudices Patent Owner.
`
`When the Board joined ION as a party to this proceeding, the Board ordered
`
`that “ION is not permitted to file papers.” See Paper 54 at 6 (emphasis added).
`
`Now, less than one week after the Board issued its Order granting joinder, ION is
`
`doing exactly what it is prohibited from doing by filing the instant motion.
`
`Not only is ION in violation of the Board’s Order, but ION’s motion also
`
`unduly prejudices Patent Owner. Despite knowing the location and time of the
`
`deposition of Mr. Robin Walker for almost a week, ION waited until the eve of
`
`Mr. Walker’s deposition to file this motion, which it obviously had ready for some
`
`time. Due to this delay, Patent Owner was forced to draft an opposition to this
`
`Motion in less than two and a half hours on the eve of an important deposition.
`
`Moreover, ION already has counsel of record who could have attended the
`
`deposition without burdening this Board or Patent Owner with this expedited and
`
`unnecessary briefing. Quite simply, this motion is untimely and prejudicial and
`
`thus should be should be denied.
`
`
`
`
`
`2
`
`
`
`Patent Owner’s Opposition to Motion for Pro Hac Vice
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
`
`
`ION’s motion is simply an attempt to further skirt the Board’s Order by
`
`
`
`having ION’s trial counsel at the deposition to “act on ION’s behalf.” See Ex.
`
`2128. ION, however, is not allowed to participate in the deposition. Paper 54 at 6.
`
`Accordingly, if the Board grants ION’s motion, Patent Owner requests that the
`
`Board specify that, although ION may attend the deposition, it may not
`
`“participate,” meaning that ION should not be allowed to confer or communicate
`
`in any way with Petroleum Geo-Services Inc.’s (“PGS’s”) counsel or its
`
`representatives from the time the witness is sworn in until the time the deposition
`
`has concluded.
`
`For the forgoing reasons, Patent Owner respectfully requests that the Board
`
`deny ION’s Motion for pro hac vice admission of David J. Healey. Patent Owner
`
`also reserves all rights, including its right to oppose ION being a party to this
`
`proceeding.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`3
`
`
`
`Patent Owner’s Opposition to Motion for Pro Hac Vice
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
`
`
`Respectfully submitted,
`Oblon, McClelland, Maier &
`Neustadt, LLP
`
`
`
`
`
`
`
`
`
`/Michael L. Kiklis/
`Michael L. Kiklis (Reg. No. 38,939)
`Attorney for Patent Owner
`WESTERNGECO L.L.C.
`
`
`Dated: April 29, 2015
`
`
`
`
`
`
`Customer Number
` 22850
`Tel. (703) 413-3000
`Fax. (703) 413-2220
`
`
`
`
`
`
`
`
`
`
`
`
`4
`
`
`
`Patent Owner’s Opposition to Motion for Pro Hac Vice
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
`
`
`CERTIFICATE OF SERVICE
`
`
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies service of
`
`PATENT OWNER’S OPPOSITION TO MOTION FOR PRO HAC VICE and
`
`EXHIBIT 2128 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
`
`
`
`
`
`
`
`/Michael L. Kiklis/
`Michael L. Kiklis (Reg. No. 38,939)
`
`Dated: April 29, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`5
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
