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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 L.L.C.
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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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`____________
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`1 Case IPR2015-00565 has been joined with this proceeding.
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`Patent Owner’s Request for Oral Argument
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
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`Pursuant to the Board’s December 15, 2014 Scheduling Order (Paper 33)
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`and the parties’ Joint Notice of Stipulation to Revised Schedule (Paper 77), Patent
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`Owner WesternGeco L.L.C. respectfully requests oral argument, currently
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`scheduled on July 30, 2015. Patent Owner requests that argument in IPR2014-
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`00689 be consolidated with argument in IPR2014-00687 and IPR2014-00688 and
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`requests three hours to present its arguments: (a) two hours for oral argument for
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`all three proceedings, and (b) one hour of live testimony by Mr. Robin C. Walker.
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`Pursuant to 37 C.F.R. § 42.70, Patent Owner specifies the following issues to be
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`argued:
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`1. Claims 1 and 18 are not anticipated by Workman;
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`2. Claims 1, 2, 18, and 19 are not obvious over Workman;
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`3. Claims 1, 2, 18, and 19 are not anticipated by Hedberg;
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`4. Claims 1, 2, 18, and 19 are not obvious over Hedberg;
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`5. Construction of claims 1, 2, 18, and 19;
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`6. Secondary considerations of non-obviousness;
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`7. Petitioners’ identification of Real Parties in Interest;
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`8. Whether Petitioners are in privity with each other;
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`9. Collateral estoppel and res judicata;
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`10. Whether the petition is time-barred under 35 U.S.C. § 315(b); and
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`2
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`Patent Owner’s Request for Oral Argument
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
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`11. Whether Patent Owner has been afforded due process in this
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`proceeding.
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`Patent Owner also requests that Robin C. Walker be allowed to provide live
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`testimony at the oral hearing on the issue of secondary considerations of non-
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`obviousness.2 Mr. Walker submitted a declaration and provided deposition
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`testimony in support of Patent Owner’s secondary considerations argument.
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`Petitioners provided no rebuttal evidence on secondary considerations in their
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`reply brief. Instead, Petitioners’ sole response to this evidence was to attack Mr.
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`Walker’s credibility. Mr. Walker’s credibility and testimony are therefore central
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`to this Board’s secondary considerations determination. Patent Owner thus
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`respectfully requests that Mr. Walker be allowed to testify. In addition to the two
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`hours that Patent Owner requests for oral argument, Patent Owner requests one
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`hour for Mr. Walker’s live witness testimony to be divided equally between
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`Petitioner Petroleum Geo-Services, Inc. (“PGS”) and Patent Owner. Specifically,
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`2 Patent Owner and Petitioner Petroleum Geo-Services Inc. (“PGS”) have
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`conferred and it is Patent Owner’s understanding that PGS will oppose this request.
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`3
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`Patent Owner’s Request for Oral Argument
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
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`Patent Owner proposes that it receives 30 minutes for direct examination and that
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`PGS receives 30 minutes for cross examination.3
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`In the event any fees are required for this Request, please charge Deposit
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`Respectfully submitted,
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`Oblon, McClelland, Maier &
`Neustadt, LLP
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`
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`
`
`/Michael L. Kiklis/
`Michael L. Kiklis (Reg. No. 38,939)
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`Account No. 15-0030.
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`Dated: June 29, 2015
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`Customer Number
` 22850
`Tel. (703) 413-3000
`Fax. (703) 413-2220
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`3 Patent Owner reserves the right to request additional time for redirect at the oral
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`hearing.
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`4
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`Patent Owner’s Request for Oral Argument
`Case IPR2014-00689
`U.S. Patent No. 7,293,520
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`CERTIFICATE OF SERVICE
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`
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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 REQUEST FOR ORAL ARGUMENT on the counsel of
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`record for the Petitioners by filing this document through the Patent Review
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`Processing System as well as delivering a copy via electronic mail to the following
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`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 (Reg. No. 38,939)
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`5
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`Dated: June 29, 2015