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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`PETROLEUM GEO-SERVICES INC.
`and
`ION GEOPHYSICAL CORPORATION
`AND ION INTERNATIONAL S.A.R.L,
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`Petitioners,
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`v.
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`WESTERNGECO LLC,
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`Patent Owner.
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`____________
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`Case IPR2014-006891
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`U.S. Patent No. 7,293,520
`____________
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`PATENT OWNER’S NOTICE OF APPEAL TO THE
`U.S. COURT OF APPEALS FOR THE FEDERAL CIRCUIT
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` Case IPR2015-00565 has been joined with this proceeding.
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`Notice is hereby given, pursuant to 37 C.F.R. § 90.2(a), that Patent Owner,
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`Patent Owner’s Notice of Appeal
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
`
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`WESTERNGECO LLC, hereby appeals and/or petitions for a writ of mandamus to
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`the United States Court of Appeals for the Federal Circuit from the Final Written
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`Decision entered on December 15, 2015 (Paper No. 101) (the “Final Written
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`Decision”), the Decision on Request for Rehearing entered on March 17, 2016
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`(Paper No. 106) (the “Decision on Rehearing”), and from all underlying orders,
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`decisions, rulings and opinions regarding U.S. Patent No. 7,293,520 (“the ‘520
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`Patent”).
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`In accordance with 37 C.F.R. § 90.2(a)(3)(ii), Patent Owner further
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`indicates that the issues may include the following, as well as any underlying
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`findings, determinations (including claim constructions), rulings, decisions,
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`opinions, or other related issues:
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`• The Board’s holding that claims 1 and 18 are anticipated by
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`Workman;
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`• The Board’s holding that claims 1, 2, 18, and 19 are rendered obvious
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`by Workman;
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`• The construction of claims 1, 2, 18, and 19;
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`• Secondary considerations of non-obviousness;
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`• Petitioners’ failure to identify real parties-in-interest;
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`• Whether Petitioners are in privity with each other;
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`1
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`Patent Owner’s Notice of Appeal
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
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`• Whether the Petition was time-barred under 35 U.S.C. § 315(b);
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`• Whether collateral estoppel and res judicata barred ION Geophysical
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`Corporation’s and ION International S.A.R.L.’s joinder to the
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`proceeding;
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`• The Board’s denial of additional discovery regarding real party-in-
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`interest and privity; and
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`• Whether Patent Owner was afforded due process in this proceeding.
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`A copy of this Notice of Appeal to the United States Court of Appeals for
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`the Federal Circuit is being simultaneously filed with the Office of the General
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`Counsel for the U.S. Patent and Trademark Office via U.S. First-Class Mail to the
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`following address:
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`Director of the United States Patent and Trademark Office
`c/o Office of the General Counsel
`United States Patent and Trademark Office
`Madison Building East, 10B20
`600 Dulany Street
`Alexandria, VA 22314
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`Additionally, a copy of this Notice of Appeal to the United States Court of
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`
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`Appeals for the Federal Circuit is being simultaneously filed electronically with the
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`Clerk’s Office for the United States Court of Appeals for the Federal Circuit via
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`the CM/ECF Document Filing System along with the required filing fee of $500.00
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`via the “Pay.gov” website.
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`2
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`Patent Owner’s Notice of Appeal
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
`
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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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`Customer Number
` 22850
`Tel. (703) 413-3000
`Fax. (703) 413-2220
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`3
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`Dated: May 18, 2016
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies service of
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`PATENT OWNER’S NOTICE OF APPEAL TO THE U.S. COURT OF
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`APPEALS FOR THE FEDERAL CIRCUIT on the counsel of record for the
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`Petitioners by filing this document through the Patent Review Processing System
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`as well as delivering a copy via electronic mail to the following addresses:
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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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`W. Karl Renner
`Roberto Devoto
`IPR37136-0004IP1@fr.com
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`/Michael L. Kiklis/
`Michael L. Kiklis
`Registration No. 38,939
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`Dated: May 18, 2016
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