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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
`
`
`Case IPR2014-006891
`
`U.S. Patent No. 7,293,520
`
`PETROLEUM GEO-SERVICES INC.’S REQUEST FOR ORAL
`ARGUMENT
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`
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`1 Case IPR2015-00565 has been joined with this proceeding.
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`
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`Case IPR2014-00687
`Patent 7,293,520
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`
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`Pursuant to the Scheduling Order (Paper 34), Stipulation (Paper 76) and 37
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`C.F.R. § 42.70(a), Petitioner Petroleum Geo-Services Inc. (“PGS”) respectfully
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`requests that the Board hear oral argument in this proceeding on July 30, 2015, see
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`Paper 33 at 6, at 9:00 am, see July 2015 PTAB Public Hearing Schedule. PGS
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`requests that the Board hold the oral argument in this proceeding (IPR2014-00689)
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`in sequence with any oral argument in the two other related proceedings (IPR2014-
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`00687 and IPR2014-00688). PGS requests twenty minutes of oral argument per
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`side for IPR2014-00689. If the hearings in the three matters are combined, PGS
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`requests one hour of oral argument per side.
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`
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`Pursuant to 37 C.F.R. § 42.70(a), PGS requests oral argument on all of the
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`instituted grounds of unpatentability of Claims 1, 2, 18, and 19 of U.S. Patent No.
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`7,293,520.
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`
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`In its Request for Oral Argument, WG included a page of briefing requesting
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`leave to offer live testimony from Robin Walker. PGS opposes this request. The
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`Board permits live testimony “under very limited circumstances” where, for
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`example, “the demeanor of a witness is critical to assessing patentability.” K-40
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`Elecs., LLC v. Escort, Inc., IPR2013-00203, Paper 34 at 2 (May 21, 2014). PGS is
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`aware of the Board granting this relief only once, in a case where the credibility of
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`the inventor’s testimony antedating the two prior art references was “key” and
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`potentially “case dispositive.” Id. Mr. Walker’s testimony does not come close to
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`meeting this exacting standard. Setting aside that Mr. Walker’s testimony is
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`inadmissible for the reasons discussed in PGS’s Motion to Exclude, it purports to
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`bear only on objective indicia of nonobviousness, which are irrelevant to
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`anticipation. In any event, the Board need never reach his testimony because WG
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`does not establish nexus between the Q-Marine and the challenged claims in the
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`first place. And even if credited in full, Mr. Walker’s testimony is irrelevant. His
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`purported evidence of secondary considerations relates only to lateral steering
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`generally, not to the claims of the challenged patent. His testimony is thus neither
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`“key” nor “case dispositive.” Finally, the significant gaps and inconsistencies in
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`Mr. Walker’s testimony can be adequately evaluated from the parties’ submissions
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`and the ten hours of Mr. Walker’s deposition cross examination. There is simply
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`no need for the Board to hear Mr. Walker live.
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`PGS respectfully requests that the Board provide audio/visual equipment to
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`display demonstrative exhibits and evidence of record, including the use of a
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`projector and screen for displaying documents.
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`
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`Respectfully submitted,
`
`
`
` /Jessamyn Berniker/
`Jessamyn Berniker
`Reg. No. 72,328
`Williams & Connolly LLP
`725 Twelfth Street, N.W.
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`3
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`Dated: June 29, 2015
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`Washington, DC 20005
`Phone: 202-434-5474
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`4
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`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the above-captioned Petroleum Geo-
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`Services Inc.’s Request for Oral Argument was served on June 29, 2015, 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.:
`
`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
`
`Oblon
`1940 Duke Street
`Alexandria, Virginia 22314
`703-413-3000
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`
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`5
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`W. Karl Renner
`Roberto Devoto
`IPR37136-0004IP1@fr.com
`
`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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`Respectfully submitted,
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`
`/Jessamyn Berniker/
`Jessamyn Berniker
`Reg. No. 72,328
`Williams & Connolly LLP
`725 Twelfth Street, N.W.
`Washington, DC 20005
`
`Phone: 202-434-5474
`
`
`
`6
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`
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`Dated: June 29, 2015
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