Transcript of MICHAEL S. TRIANTAFYLLOU, Sc.D
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`Date: May 22, 2015
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`Case: PETROLEUM GEO-SERVICES INC., ET AL v. WESTERNGECO LLC
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`Planet Depos
`Phone: 888-433-3767
`Fax: 888-503-3767
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`Internet: www.planetdepos.com
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`Worldwide Court Reporting | Interpretation | Trial Services
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`PGS Exhibit 1091, pg. 1
`PGS v. WesternGeco (IPR2014-00689)
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`

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`DEPOSITION OF MICHAEL S. TRIANTAFYLLOU, Sc.D
`CONDUCTED ON FRIDAY, MAY 22, 2015
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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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`---------------------------------x
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`PETROLEUM GEO-SERVICES INC. : Cases
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`and ION GEOPHYSICAL CORPORATION : IPR2014-00687
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`AND ION INTERNATIONAL S.A.R.L., : (U.S. Patent No. 7,162,967)
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` Petitioners,: IPR2014-00688
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` v. : (U.S. Patent No. 7,080,607)
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`9 WESTERNGECO, LLC, : IPR2014-00689
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` Patent Owner.: (U.S. Patent No. 7,293,520)
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`---------------------------------x
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` Deposition of MICHAEL S. TRIANTAFYLLOU, Sc.D
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` Alexandria, Virginia
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` Friday, May 22, 2015
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` 8:35 a.m.
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` A P P E A R A N C E S
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` ON BEHALF OF PETITIONER:
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` DAVID I. BERL, ESQUIRE
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` THOMAS S. FLETCHER, ESQUIRE
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` JESSAMYN BERNIKER, ESQUIRE
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` ALEC SWAFFORD, ESQUIRE
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` WILLIAMS & CONNOLLY LLP
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` 725 Twelfth Street, N.W.
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` Washington, D.C. 20005
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` (202) 434-5000
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` ON BEHALF OF THE PATENT OWNER:
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` MICHAEL L. KIKLIS, ESQUIRE
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` CHRISTOPHER RICCIUTI, ESQUIRE
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` OBLON, SPIVAK, McCLELLAND, MAIER &
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` NEUSTADT, LLP
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` 1940 Duke Street
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` Sixth Floor
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` Alexandria, Virginia 22314
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` (710) 413-3000
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` A P P E A R A N C E S C O N T I N U E D
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` ON BEHALF OF THE PATENT OWNER:
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` RYAN KANE, ESQUIRE
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` KIRKLAND & ELLIS LLP
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` 601 Lexington Avenue
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` New York, New York 10022
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` (212) 446-4800
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` ALSO PRESENT:
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` KEVIN M. HART, Petroleum Geo-Services, Inc.
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` TRISHA JHUNJHNUWALA
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`Job No.: 83209
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`Pages: 1 - 422
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`Reported by: Leslie A. Todd
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` Deposition of MICHAEL S. TRIANTAFYLLOU, Sc.D, held
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`at the offices of:
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` OBLON, SPIVAK, McCLELLAND, MAIER &
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` NEUSTADT, LLP
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` 1940 Duke Street
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` Sixth Floor
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` Alexandria, Virginia 22314
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` (710) 413-3000
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` Pursuant to Notice, before Leslie Anne Todd,
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`Court Reporter and Notary Public in and for the
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`Commonwealth of Virginia, who officiated in
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`administering the oath to the witness.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`PGS Exhibit 1091, pg. 2
`PGS v. WesternGeco (IPR2014-00689)
`
`

`

`DEPOSITION OF MICHAEL S. TRIANTAFYLLOU, Sc.D
`CONDUCTED ON FRIDAY, MAY 22, 2015
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` C O N T E N T S
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`EXAMINATION OF MICHAEL S. TRIANTAFYLLOU, Sc.D PAGE
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` By Mr. Berl 7
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`5
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` E X H I B I T S
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` (Attached to transcript)
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`DEPOSITION EXHIBIT PAGE
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`2 (Pages 5 to 8)
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` P R O C E E D I N G S
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` ---------------------
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` MICHAEL S. TRIANTAFYLLOU, Sc.D,
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` having been duly sworn, was examined
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` and testified as follows:
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` MR. BERL: Let's do, for the record,
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`appearances.
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` David Berl, Williams & Connolly. With me
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`is Tom Fletcher, also from Williams & Connolly. And
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`Exhibit 1076 Simon Bittleston Curriculum Vitae 51
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`Trisha Jhunjhnuwala, a summer associate with us at
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`Exhibit 1077 SEG Application for Active
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` Membership 72
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`Exhibit 1078 WesternGeco's Opening Claim
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` Construction Brief 138
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`Exhibit 1079 Claim Construction Expert Report
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` of Peter H. Canter 152
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`Exhibit 1080 Patent Office Action 255
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`Exhibit 1081 Great Britain Application 9821277 269
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`Exhibit 1082 Statement by the European Patent
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` Office 272
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`11 Williams & Connolly, and also Kevin Hart from
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`Petroleum Geo-Services, Inc.
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` MR. KIKLIS: Mike Kiklis from Oblon for
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`the patent owner. With me is Ryan Kane from Kirkland
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`and Chris Ricciuti from Oblon as well.
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` EXAMINATION BY COUNSEL FOR PETITIONER
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`BY MR. BERL:
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` Q Good morning, Doctor.
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` A Good morning.
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` Q You've done this before, Doctor, right,
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`given a deposition?
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` A Yes.
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` E X H I B I T S C O N T I N U E D
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`DEPOSITION EXHIBIT PAGE
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`Exhibit 1083 Document in ION case entitled
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` "Opening Expert Report of
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` Michael S. Triantafyllou" 338
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`OTHER EXHIBITS REFERRED TO AND ATTACHED:
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`Exhibit 1001 U.S. Patent No. US 7,162,967
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` U.S. Patent No. US 7,080,607
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` U.S. Patent No. US 7,293,520 91
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`Exhibit 1002 Declaration of Dr. Brian Evans,
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` PhD. 55
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` Q So you understand I'm going to ask you a
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`series of questions over the next two days, and you
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`will provide answers to those questions.
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` A Exactly.
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` Q If you don't understand my questions, you
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`can just tell me, and I will try to explain it or ask
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`it a different way. Okay?
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` A Okay.
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` Q And is there any reason you can't give
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`truthful testimony today?
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` A There is no reason.
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` Q Doctor, I would like to hand you the
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`declaration that you submitted in these three cases
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`that's been marked as Exhibit 2042, I believe in each
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`of the three cases.
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` Is this in fact the declaration that you
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`submitted in connection with the three IPRs?
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` A It's a long declaration, but, yes, it
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`appears to be.
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` Q And at the end of it after page 88, your
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`signature appears; is that right?
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` A Correct.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`PGS Exhibit 1091, pg. 3
`PGS v. WesternGeco (IPR2014-00689)
`
`

`

`DEPOSITION OF MICHAEL S. TRIANTAFYLLOU, Sc.D
`CONDUCTED ON FRIDAY, MAY 22, 2015
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` Q And you signed that on or about
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`2 March 20th, 2015?
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` A Yes.
` Q In Singapore?
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` A In Singapore.
` Q And you reviewed the declaration before
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`you signed it?
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` A Yes.
` Q You believed it to be truthful before you
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`signed it?
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` A Yes, I did.
` Q And if you reviewed it and believed it to
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`contain errors, you would have changed those errors
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`before you signed it, correct?
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` A Correct.
` Q Are you aware of any errors in your
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`declaration as you sit here today?
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` A Not as I sit today.
` Q I notice you brought with you a binder.
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`20 What's in that binder?
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` A In the binder there is a copy of what you
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`just handed me, and there are four principal
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` A Yes.
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` Q And it says that you pioneered the
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`development of science-driven biomimetic robots to
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`study the basic mechanisms of flow control that lead
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`to the outstanding agility of fish and cetaceans; is
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`that right?
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` A Yes.
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` Q That's one of your research interests?
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` A It is.
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` Q And it says further down that you're
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`currently studying the physics of flow sensing in
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`fish and marine mammals to achieve
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`supermaneuverability in ocean vehicles through flow
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`feedback control; is that right?
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` A Right.
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` Q That's another one of your research
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`interests?
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` A Yes.
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` Q There's nothing in the summary of your
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`research interests about marine seismic surveys,
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`right?
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` A This is implied because the whole area I
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`references that were used in the declaration.
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`developed on fish hydrodynamics and the like sprang
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` Q Okay. Now, appended to your declaration
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`was Exhibit A to 2042. I suppose we can mark this
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`as -- let's keep this as part of 2042 since that's
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`how it was submitted in connection with your
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`declaration.
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` And for the record, I'm also handing you
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`what was marked as Exhibit B to your declaration,
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`2042, as well as Exhibit C to your declaration, 2042.
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` Do you have those documents, sir?
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` A Yes, I do.
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` Q Exhibit A is a copy of your curriculum
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`vitae; is that right?
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` A Yes, it is.
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` Q And that was current as of March 2015?
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`out of my work on cables, towed cables and the like.
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` Q But with respect to marine seismic
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`surveys, there is nothing in the summary of your
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`research interests that talks about that, right?
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` A It is implied, as I told you, and if you
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`look back in my references you can find plenty of
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`such references. So this is -- we're looking at the
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`cutting edge of the moment which we will advertise in
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`this caption. This is for various reasons.
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` Q It's for various what?
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` A We do this for reasons of promoting the
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`students and the like. But this whole research area
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`came as a result of my cable mechanics, which is my
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`sort of bread and butter. That's how I got tenure at
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` A Yes.
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`16 MIT.
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` Q And your curriculum vitae provides some
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`of your research and experience, right?
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` A Correct.
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` Q And on the first page it has a paragraph,
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`the second paragraph about your journal articles and
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`research interests, right?
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` Q Okay. And my question, though, is a
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`simple one. In this summary of your research
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`interests, it does not say anything about marine
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`seismic surveys, right?
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` MR. KIKLIS: Objection. Form.
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` THE WITNESS: To a layperson, maybe no.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`PGS Exhibit 1091, pg. 4
`PGS v. WesternGeco (IPR2014-00689)
`
`

`

`DEPOSITION OF MICHAEL S. TRIANTAFYLLOU, Sc.D
`CONDUCTED ON FRIDAY, MAY 22, 2015
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`But to those who can read through the words, it says
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`plenty.
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`BY MR. BERL:
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` Q It may say plenty, but it doesn't say
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`"marine seismic surveys," right?
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` MR. KIKLIS: Objection. Form.
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` THE WITNESS: It comes together with all
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`the publications here.
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`BY MR. BERL:
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` Q Okay. So let's look at the publications.
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`You have a 21-page curriculum vitae, correct?
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` A Yes.
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` Q And the term "marine seismic survey" does
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` A I discuss the basics on which the towed
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`arrays are based. If you don't know the basics, you
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`cannot do any progress in the area.
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` Q I understand that, but my question is
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`very simple. You don't discuss in that paper marine
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`seismic survey.
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` MR. KIKLIS: Objection. Form.
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` THE WITNESS: The fundamental --
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` MR. KIKLIS: Michael, let me get a chance
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`to object.
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` Objection. Form.
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` THE WITNESS: The fundamentals for the
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`paper are very pertinent, whereas you can find from
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`not appear in the 21-page curriculum vitae, correct?
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`14 my declaration, that's where I base the whole
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` A It is an application of all the things
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`that I have published on the dynamics of translating
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`cables. For example, number 8 on dynamics of --
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` THE REPORTER: Excuse me?
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` THE WITNESS: Number 7 and 8 of my
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`publications.
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` Let me point you out to another one which
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`will be more relevant. The review papers.
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`discussion on the towed arrays. If you don't know
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`those principles that I explained in those papers,
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`you cannot do towed arrays.
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`BY MR. BERL:
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` Q That may be true, but my question is
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`different.
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` You don't actually discuss marine seismic
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`surveying in that paper, do you?
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`BY MR. BERL:
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` Q Those are on page 11?
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` A Page 11, number 2. "Dynamics of cables,
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`Towing Cables and Mooring Systems." The Shock and
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`Vibrations Digest is a journal where people review
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`the literature to find out what is the state of the
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`art, what is the most advanced, what is missing from
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`the area. Whereas, you can see I reviewed the
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`relevant area which is where all the work on towed
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`arrays is based on.
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` Q Let's take a look at reference number 7
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`that you identified. That's on page 3. That's the
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`Kim article from 1984. Correct?
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` A Yes.
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` Q That does not address marine seismic
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`surveys, does it?
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` A It has applicability to it, not in -- in
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`the application of commercial application. But all
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`this work was the basis for deriving the fundamentals
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`of how towed arrays and the like move.
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` Q You don't discuss in that paper marine
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` MR. KIKLIS: Objection to form.
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` THE WITNESS: I have answered the
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`question more than once.
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`BY MR. BERL:
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` Q Well, you've answered about whether you
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`think it has applicability to marine seismic surveys.
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`I understand that answer.
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` My question is a different question, and
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`I'm entitled to an answer to my question, which is
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`that paper does not discuss marine seismic surveys,
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`correct?
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` MR. KIKLIS: Objection to form.
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` THE WITNESS: It discusses the principles
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`that apply to the towed arrays.
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`BY MR. BERL:
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` Q But not seismic surveys itself.
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` MR. KIKLIS: Objection to form.
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` THE WITNESS: It applies to seismic
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`arrays as well.
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`BY MR. BERL:
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` Q But it does not discuss seismic --
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` A But it applies to seismic arrays as well.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`PGS Exhibit 1091, pg. 5
`PGS v. WesternGeco (IPR2014-00689)
`
`

`

`DEPOSITION OF MICHAEL S. TRIANTAFYLLOU, Sc.D
`CONDUCTED ON FRIDAY, MAY 22, 2015
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` Q Okay. I understand. So your answer is
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`it does not discuss marine seismic surveys but it
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`applies to marine seismic surveys.
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` A It discusses the principles of seismic
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`arrays; therefore, it applies to seismic arrays.
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` Don't change my answer, please.
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` Q I'm not changing your answer. I'm trying
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`to get an answer to the question which is --
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` A And you got the answer.
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` Q I don't think you've answered my narrow
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`question, which was paper number 7 does not discuss
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`in the paper marine seismic surveys, correct?
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` A Or a person like me.
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` Q Let's take a look at number 2, this
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`review paper you identified on page 11.
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` A Yes.
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` Q From 1991. That likewise does not
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`discuss marine seismic surveys, correct?
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` A Towing cables.
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` Q It discusses towing cables, but not the
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`problems associated with marine seismic surveys, for
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`example.
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` A I have to look back whether I used in
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`fact the word, because I meant -- I believe -- which
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` A It discusses the principles that apply to
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`13 my memory from so many years is not exact, whether in
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`seismic arrays.
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` Q Okay. Paper number 8 that you identified
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`as well, that likewise does not discuss marine
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`seismic surveys, correct?
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` A We can go down the list, and I will give
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`you the same answer which you heard before.
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` Q Which is that it does not discuss marine
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`seismic surveys, but in your view it applies to
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`this publication, but I think it was in that one I
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`discussed towed arrays as an application. I have to
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`look at that to reinforce my memory which one it is.
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` Q Towed arrays in marine seismic surveys?
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` A Towed arrays.
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` Q But not in marine seismic surveys, just
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`in general.
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` A Towed arrays. Whether it is behind
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`submarines, which was my primary field of study at
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`is it applies to the principles; therefore, it
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`applies to seismic arrays.
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` Q But that marine seismic surveys are not
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`explicitly discussed in the article number 8.
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` A When you discuss the principles of
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`something, it applies to those principles. That's
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`8 my position.
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` Q But you discussed the principles. You
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`did not discuss marine seismic surveys.
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` MR. KIKLIS: Objection. Form.
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` THE WITNESS: Someone who is studying
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`the time, or behind -- the principles are the same --
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`or behind oil and gas exploring vehicles, the
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`principles are the same.
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` Q So the information that one can determine
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`based on work on submarines, for example, you view as
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`being applicable to the context of marine seismic
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`surveying.
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` A Submarines is more challenging than for
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`gas and oil.
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` Q But information that one obtains from the
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`literature in the area of submarines, in your view,
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`certainly would apply to the problems associated with
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`seismic arrays will have to go and look at those
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`publications. Therefore, it is pertinent.
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`BY MR. BERL:
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` Q I didn't hear the end of what you said.
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` A Someone who is studying the towed arrays
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`will have to look at my publications; therefore, it's
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`pertinent to the seismic.
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` Q They will have to look at your
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`publications so that it's impossible to understand
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`22 marine seismic arrays without reviewing your papers?
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`which were published, yes.
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` MR. KIKLIS: Could you just wait for him
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`to finish his question before you answer.
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` THE WITNESS: Sure.
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` MR. KIKLIS: Thank you.
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` THE WITNESS: Sorry if I rush ahead of
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`you.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`PGS Exhibit 1091, pg. 6
`PGS v. WesternGeco (IPR2014-00689)
`
`

`

`DEPOSITION OF MICHAEL S. TRIANTAFYLLOU, Sc.D
`CONDUCTED ON FRIDAY, MAY 22, 2015
`
`21
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` MR. BERL: No, that's fine. No apology
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`necessary.
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`BY MR. BERL:
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` Q Doctor, in the field of marine seismic
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`surveying, you would agree that Dr. Evans has more
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`expertise than you do.
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` A It depends on how you put it. If you are
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`talking about what we are talking today, the dynamics
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`of towed arrays, which is what is the field of these
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`publications, I would claim that he is not more
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`expert than I am. In fact, I would say the opposite.
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`In fact, I would say few people in the world would be
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`on the same level.
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` Q But if we're talking about what problems
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`are encountered in the field when conducting marine
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`seismic surveys, you would agree that in that area
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`Dr. Evans has more expertise than you do?
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` A Not in the field of towing arrays. You
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`can talk about binning, you can talk about throwing
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`additional lines. I think the specific field of
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`pertinence, I believe I have more expertise.
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` Q But when we talk about binning or towing
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`you don't want to compare. How many marine seismic
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`surveys have you designed?
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` A Specifically for the industry, I'm not a
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`designer of arrays. I'm the developer of the
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`technology which is used -- fundamentals of dynamics
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`and control, which are used to design such arrays.
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` Q So it's correct to say that you have
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`designed zero marine seismic surveys.
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` A Design in the sense of actually doing
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`them, this is not my business. I'm a professional
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`who develops concepts and new technology.
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` Q But with respect to designing how a
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`survey should be conducted in a particular area,
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`let's say the Gulf of Mexico, in a marine seismic
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`survey, that's not your area.
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` MR. KIKLIS: Objection. Form.
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` THE WITNESS: There are aspects of it
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`which I'm very pertinent with, okay? So if someone
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`in the industry calls me up, it's usually for some
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`advanced problem, and I will be part of the team.
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`Now, how you want to grade this up or down, it's a
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`personal choice.
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`additional lines, in those areas Dr. Evans has more
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`expertise?
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` A He has expertise in certain areas. I'm
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`not sure that this is the specific one. I'm just
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`saying that -- I don't want to compare the other
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`areas, but in the specific area of the patents which
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`we're talking about today, I believe I have more
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`expertise than he does.
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` Q And that specific area that you said you
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`think you have more expertise is the dynamics of
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`towed arrays, correct?
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` A And control, yes.
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` Q And with regard to designing marine
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`seismic surveys, you would agree that Dr. Evans has
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`15 more expertise than you.
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` A I would put the doubt on this because in
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`order to do proper design of the arrays, you have to
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`know about the dynamics of the control. You may know
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`19 more on acoustics or anything else. I'm not saying
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`that Dr. Evens does or does not, but I'm saying in
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`the field of study today.
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` Q Let me ask the question this way since
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`BY MR. BERL:
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` Q But you don't actually design the surveys
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`to determine how long it will be, where the boats
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`should go, how many streamers, where the streamers
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`go, et cetera.
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` MR. KIKLIS: Objection. Form.
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` THE WITNESS: I may provide an opinion on
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`such things.
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`BY MR. BERL:
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` Q But you don't --
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` A I'm a part of the team, if -- if you
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`want.
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` Q When was the last time you actually
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`helped design a marine seismic survey?
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` A I don't recall in my discussions with the
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`oil industry, but I do not recall it now.
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` Q To --
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` A I do not recall it now.
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` Q You can't give me a specific instance
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`where you helped --
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` A No, I cannot.
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` Q Sorry. Let me finish my question.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`PGS Exhibit 1091, pg. 7
`PGS v. WesternGeco (IPR2014-00689)
`
`

`

`DEPOSITION OF MICHAEL S. TRIANTAFYLLOU, Sc.D
`CONDUCTED ON FRIDAY, MAY 22, 2015
`
`25
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`7 (Pages 25 to 28)
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`27
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` You cannot provide a specific instance in
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`which you helped design a marine seismic survey.
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` A I cannot give you a specific instance
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`today. I have to think about it.
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` Q Okay. With regard to interpreting the
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`data from marine seismic surveys, that's not your
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`area either, right?
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` A If you are talking interpreting the data
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`on finding the underground oil and gas or
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`interpreting the data of the hydrophones that come
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`for control. Which of the two do you want?
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` Q Interpreting the data that's obtained
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`from the marine seismic survey.
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` A This is typically handled by
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`acousticians.
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` Q Not -- not you, not people in your field.
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` A I may have an opinion, but I'm not
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`someone who will be doing this.
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` Q Dr. Evans wrote an entire book on marine
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`seismic surveying, correct?
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` A Yes.
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`down whether it carries a title. It's applying to
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`all those things and other things as well. Okay?
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` Q So I understand that's a question you may
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`want to answer. But my question is, can you identify
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`for me a single thing you have ever written, other
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`than your -- in your expert reports in this case or
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`the ION litigation, that uses the term "marine
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`seismic survey"?
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` MR. KIKLIS: Objection to form.
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` THE WITNESS: I told you that my review
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`papers apply to towing arrays, okay? You want -- for
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`us, towed arrays is equivalent to whether it's a
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`towed array behind a submarine or whether it's behind
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`-- towed arrays behind a vehicle. So it's similar to
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`what you are talking about.
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`BY MR. BERL:
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` Q And I think the answer to my question,
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`but please confirm for me if I'm wrong, is you cannot
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`identify for me a single thing you have ever written
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`in your entire career, other than your expert reports
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`in the ION case and this case, that uses the term
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`"marine seismic survey."
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` Q And that book was directed to addressing
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`issues that arise in the context of marine seismic
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`surveying, correct?
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` A I haven't read his book, so I'm not
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`familiar with the content.
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` Q You haven't looked at his book?
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` A I may have used it, but not in a deep way
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`to give you an opinion, no.
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` Q You've never written a book about the
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` MR. KIKLIS: Objection. Misstates.
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` THE WITNESS: And I told you that they
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`are synonymous. I have written things about the
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`synonymous, so I cannot say -- it's a wrong answer to
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`say that I have not written. It will surprise people
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`in the industry if I made such a statement. It would
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`irritate them if I said -- they are using my thing --
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`problems associated with marine seismic surveys, have
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`9 my derivations and my equations and my advice for
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`you?
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` A I have written notes which provide the
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`fundamentals of dynamics and control, which apply to
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`it, yes.
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` Q Doctor, can you identify a single thing
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`you've ever written, other than your expert reports
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`in the ION case and this case, that uses the term
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`"marine seismic survey"?
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` A You are asking me to say whether any --
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`everything that I published in the area of cables and
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`things is used widely in the offshore industry. I
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`have all sorts of applications.
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` So the question is you want to narrow it
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`conducting such arrays, and for me to state that I
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`have written nothing would be outrageous.
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`BY MR. BERL:
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` Q Okay. Let me ask it this way then: Can
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`you identify for me anything you've ever written,
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`whether on your CV or anything, a note to your wife,
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`I don't care what it is, anything, other than your
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`expert reports in the ION case and in this case, that
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`uses the term "marine seismic survey"? If you can
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`identify it for me, please do. If you can't, just
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`tell me you can't.
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` MR. KIKLIS: Objection. Form.
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`Argumentative.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`PGS Exhibit 1091, pg. 8
`PGS v. WesternGeco (IPR2014-00689)
`
`

`

`DEPOSITION OF MICHAEL S. TRIANTAFYLLOU, Sc.D
`CONDUCTED ON FRIDAY, MAY 22, 2015
`
`29
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`8 (Pages 29 to 32)
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` THE WITNESS: For a person like yourself,
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`a layperson, the words that you are saying "marine"
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`and the like have a specific meaning, and for a
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`specialist "towed arrays" has another meaning. So
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`5 what we're talking about today comes out of all this.
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`So for me to say an answer yes to your question would
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`be outrageous.
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`and the like, it's a straitjacket and it's
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`outrageous.
` Q So I think the answer to my question was
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`that you've written a lot about towed arrays that you
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`think applies to marine seismic surveys, but as to
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`the specific issue of marine seismic surveys, you are
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`unable to provide me a single document you've ever
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` I've written the basic equations for
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`8 written other than your expert report in front of you
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`towed arrays. I've written controls for towed
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`arrays. I've written predictive control for towing
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`things. I'm doing right now, I just completed eight
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`years study for the Navy for high speed towing
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`arrays. High speed towing arrays.
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`and your reports in the ION case, correct?
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` MR. KIKLIS: Objection. Misstates.
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`Form.
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`BY MR. BERL:
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` Q If you have such a document, just tell me
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` And for me to come here and say marine
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`14 where it is.
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`arrays, I have written nothing about, it's a
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`distortion of words. It's outrageous. I answered it
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`so many times that I will keep repeating it. If you
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`18 want to go along with this game, fine, but I'm just
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`telling you.
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` MR. KIKLIS: Objection. Argumentative.
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` THE WITNESS: You have plenty of
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`documents.
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` MR. KIKLIS: And form.
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` THE WITNESS: The answer was given to
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`BY MR. BERL:
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`you. If you want to keep going down this road, we
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` Q You seem to be getting upset. I'm not
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`21 will get the answer -- the answer you got.
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`trying to irritate you or -- or be disrespectful in
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`BY MR. BERL:
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`any way. I'm simply trying to get an answer to my
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`question which --
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` A And I'm not getting upset. I'm
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`getting -- I have a passion for these things. I
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`gotten tenure at MIT because of these things.
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` Q I -- I appreciate that. And --
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` A And, therefore, you see my passion coming
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`out. I'm not irritated. You're a very pleasant
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`person.
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` Q Thank you.
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` MR. KIKLIS: Objection to the --
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` THE WITNESS: I'm not irritated at all.
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`I'm passionate about this.
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`BY MR. BERL:
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` Q Wonderful.
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` A So I lived my life doing towed arrays. I
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`participated in the discovery of the Titanic with
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`towed arrays. I worked with the Navy for many years
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`on towed arrays.
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` Q I understand.
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` A And for someone to come here and to say,
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`22 Have you written anything on marine -- towed arrays
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` Q Okay. You're familiar with SEG?
` A I'm not going to go along with initials.
`3 You have to spell it out.
` Q You don't know what SEG is, do you?
` MR. KIKLIS: Objection. Form.
` THE WITNESS: One thing I tell my
`students is never to give me initials. And that will
`have to apply to today.
`BY MR. BERL:
` Q Well, I didn't take your class at MIT. I
`apologize for that, but -- but let me just ask you
`the question, do you know what SEG is?
` A You have to spell me out what it says.
` Q I'm happy to do that, but, first, I'd
`like to know if you know what it is without me
`spelling it out.
` A You --
` MR. KIKLIS: Objection. Form.
` THE WITNESS: I don't -- I don't get
`quizzed on initials or anything else. You can go
`down the list, there are technical terms in the
`industry or in the products and the like.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`PGS Exhibit 1091, pg. 9
`PGS v. WesternGeco (IPR2014-00689)
`
`

`

`DEPOSITION OF MICHAEL S. TRIANTAFYLLOU, Sc.D
`CONDUCTED ON FRIDAY, MAY 22, 2015
`
`33
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`9 (Pages 33 to 36)
`
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`BY MR. BERL:
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` Q Okay. Sir, if you don't know what it is,
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`you can just tell me you don't know what it is. My
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`question is simple, do you know what SEG is?
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` A I don't identify now --
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` MR. KIKLIS: Objection. Misstates.
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` THE WITNESS: I don't identify now with
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`three initials what it is or what it is not.
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`BY MR. BERL:
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` Q Okay. The Society of Exploration
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`Geophysicists, are