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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 IPR2014-006891
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`U.S. Patent No. 7,293,520
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`PETITIONER PETROLEUM GEO-SERVICES INC.’S NOTICE OF
`APPEAL
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`1 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 Petitioner
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`Petroleum Geo-Services Inc. (“PGS”) hereby appeals to the United States Court of
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`Appeals for the Federal Circuit from the Final Written Decision entered December
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`15, 2015 (Paper 101) (the “Final Written Decision”) as it relates to claims 1, 6, 18,
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`and 23 of U.S. Patent No. 7,293,520 (“the ’520 patent”) and any finding or
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`determination supporting or relating to that decision, including the Decision on
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`Institution of Inter Partes Review entered December 15, 2014 (Paper 32) (the
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`“Institution Decision”).
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`In accordance with 37 C.F.R. § 90.2(a)(3)(iii), PGS further indicates that the
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`issues on appeal include, but are not limited to, the Patent Trial and Appeal
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`Board’s determinations that PGS did not demonstrate a reasonable likelihood that
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`it would prevail on the grounds of unpatentability of claims 1, 6, 18, and 23 the
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`’520 patent as obvious over the ’636 PCT (Ex. 1006) in view of the ’153 PCT (Ex.
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`1007) and as obvious over the ’636 PCT in view of Dolengowski (Ex. 1008), and
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`any finding or determination supporting or relating to those issues, as well as all
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`other issues decided adversely to PGS in any orders, decisions, rulings, and
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`opinions.
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`Pursuant to 37 C.F.R. § 90.2(a), with this submission: (1) a copy of this
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`Notice of Appeal is being filed electronically with the Patent Trial and Appeal
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`Board in accordance with 37 C.F.R. § 42.6(b); (2) a paper copy of this Notice of
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`Appeal, an electronic copy of this Notice of Appeal on the CM/ECF Document
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`Filing System, and the docketing fee of $500 are being simultaneously filed with
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`the Clerk’s Office for the United States Court of Appeals for the Federal Circuit;
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`(3) the original of this Notice of Appeal is being filed by hand with the United
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`States Patent and Trademark Office as provided in 37 C.F.R. § 104.2; and (4) a
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`copy of this Notice of Appeal is being served on Patent Owner WesternGeco, LLC.
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`Dated: May 31, 2016
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`Respectfully submitted,
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`/David Berl/
`David Berl
`Reg. No. 72,751
`Williams & Connolly LLP
`725 Twelfth Street, N.W.
`Washington, DC 20005
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`Phone: 202-434-5491
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`CERTIFICATE OF FILING
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`The undersigned hereby certifies that, in addition to being electronically
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`filed through PRPS, the above-captioned Petitioner Petroleum Geo-Services Inc.’s
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`Notice of Appeal is being filed by hand with the Director on May 31, 2016, at 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
`Madison Building East, 10B20
`600 Dulaney Street
`Alexandria, VA 22314-5793
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`The undersigned also hereby certifies that a true and correct paper copy of
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`the above-captioned Petitioner Petroleum Geo-Services Inc.’s Notice of Appeal, a
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`true and correct electronic copy of the above-captioned Petitioner Petroleum Geo-
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`Services Inc.’s Notice of Appeal, and the docketing fee of $500 are being filed by
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`hand, CM/ECF, and Pay.gov, respectively, with the Clerk’s Office of the United
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`States Court of Appeals for the Federal Circuit on May 31, 2016.
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`Dated: May 31, 2016
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`Respectfully submitted,
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`/David Berl/
`David Berl
`Reg. No. 72,751
`Williams & Connolly LLP
`725 Twelfth Street, N.W.
`Washington, DC 20005
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`Phone: 202-434-5491
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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-Services Inc.’s Notice of Appeal was served on May 31, 2016, by
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`delivering a copy via electronic 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
`IPR37136-0004IP1@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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`Dated: May 31, 2016
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`Respectfully submitted,
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`/David Berl/
`David Berl
`Reg. No. 72,751
`Williams & Connolly LLP
`725 Twelfth Street, N.W.
`Washington, DC 20005
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`Phone: 202-434-5491
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