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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————————
`
`PETROLEUM GEO-SERVICES INC.,
`Petitioner
`
`v.
`
`WESTERNGECO LLC
`Patent Owner
`
`———————————
`
`Cases
`IPR2014-00687 (U.S. Patent No. 7,162,967)
`IPR2014-00688 (U.S. Patent No. 7,080,607)
`IPR2014-00689 (U.S. Patent No. 7,293,520)
`———————————
`
`SECOND DECLARATION OF TIMOTHY K. GILMAN
`
`
`
`Pursuant to 28 U.S.C. § 1746, I, Timothy K. Gilman, the undersigned, hereby declare as
`
`follows:
`
`1.
`
`My name is Timothy K. Gilman. I am over eighteen years of age, of
`
`sound mind, and in all ways qualified and competent to make this declaration. I have personal
`
`knowledge of the facts contained in this declaration and they are true and correct.
`
`2.
`
`I am a partner in the law firm of Kirkland & Ellis, L.L.P., counsel for
`
`WesternGeco L.L.C. (“WesternGeco”).
`
`3.
`
`Exhibit 2051 is a true and correct copy of PTX 73, an exhibit that was
`
`admitted into evidence during the trial in WesternGeco L.L.C. v. ION Geophysical Corp., et al.,
`
`Civ. No. 4:09-cv-01872 (S.D. Tex.).
`
`
`
`
`
`
`WESTERNGECO Exhibit 2101, pg. 1
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`
`
`4.
`
`Exhibit 2052 is a true and correct copy of excerpts from the deposition
`
`transcript of Oyvind Hillesund dated October 20, 2010.
`
`5.
`
`Exhibit 2054 is a true and correct copy of Dr. John Leonard’s trial
`
`demonstrative number 8 from the trial in WesternGeco L.L.C. v. ION Geophysical Corp., et al.,
`
`Civ. No. 4:09-cv-01872 (S.D. Tex.).
`
`6.
`
`Exhibit 2055 is a true and correct copy of excerpts from Dr. John
`
`Leonard’s trial testimony from the trial in WesternGeco L.L.C. v. ION Geophysical Corp., et al.,
`
`Civ. No. 4:09-cv-01872 (S.D. Tex.).
`
`7.
`
`Exhibit 2072 is a true and correct copy of a discovery order dated
`
`February 14, 2014 from WesternGeco LLC v. Petroleum Geo-Services, Inc., et al., Civ. No. H-
`
`13-2725 (S.D. Tex.).
`
`8.
`
`Exhibit 2073 is a true and correct copy of WesternGeco’s First Amended
`
`Complaint and associated exhibits from WesternGeco LLC v. Petroleum Geo-Services, Inc., et
`
`al., Civ. No. H-13-2725 (S.D. Tex.).
`
`9.
`
`Exhibit 2074 is a true and correct copy of excerpts from Multi Klient AS’
`
`“Application for Permit to Conduct Geological or Geophysical Exploration for Mineral
`
`Resources or Scientific Research on the Outer Continental Shelf,” which can be found on the
`
`U.S. Department of
`
`the
`
`Interior Bureau of Ocean Energy Management website:
`
`https://www.data.boem.gov/homepg/data_center/other/WebStore/pimaster.asp?appid=5
`
`(last
`
`accessed 3/31/15).
`
`10.
`
`Exhibit 2076 is a true and correct copy of a Certificate of Financially
`
`Interested Persons filed by Petroleum Geo-Services, Inc., Multi Klient Invest AS, and PGS
`
`
`
`
`2
`
`WESTERNGECO Exhibit 2101, pg. 2
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`
`
`Geophysical AS from WesternGeco L.L.C. v. Multi Klient Invest AS, et al., Civ. No. 14-cv-3118
`
`(S.D. Tex.).
`
`11.
`
`Exhibit 2078 is a true and correct copy of excerpts from Robin Walker’s
`
`trial testimony from the trial in WesternGeco L.L.C. v. ION Geophysical Corp., et al., Civ. No.
`
`4:09-cv-01872 (S.D. Tex.).
`
`12.
`
`Exhibit 2081 is a true and correct copy of admitted trial exhibit PTX 214
`
`also labeled Burnham Exhibit 3 from WesternGeco L.L.C. v. ION Geophysical Corp., et al., Civ.
`
`No. 4:09-cv-01872 (S.D. Tex.).
`
`13.
`
`Exhibit 2082 is a true and correct copy of admitted trial exhibit PTX 309
`
`also labeled Meyer Exhibit 7 from WesternGeco L.L.C. v. ION Geophysical Corp., et al., Civ.
`
`No. 4:09-cv-01872 (S.D. Tex.).
`
`14.
`
`Exhibit 2083 is a true and correct copy of admitted trial exhibit PTX 398
`
`also labeled Vaage Exhibit 5 from WesternGeco L.L.C. v. ION Geophysical Corp., et al., Civ.
`
`No. 4:09-cv-01872 (S.D. Tex.).
`
`15.
`
`Exhibit 2084 is a true and correct copy of excerpts from Raymond Sims’
`
`trial testimony from the trial in WesternGeco L.L.C. v. ION Geophysical Corp., et al., Civ. No.
`
`4:09-cv-01872 (S.D. Tex.).
`
`16.
`
`Exhibit 2085 is a true and correct copy of admitted trial exhibit ION 465
`
`from WesternGeco L.L.C. v. ION Geophysical Corp., et al., Civ. No. 4:09-cv-01872 (S.D. Tex.).
`
`17.
`
`Exhibit 2087 is a true and correct copy of admitted trial exhibit PTX 95
`
`from WesternGeco L.L.C. v. ION Geophysical Corp., et al., Civ. No. 4:09-cv-01872 (S.D. Tex.).
`
`18.
`
`Exhibit 2091 is a true and correct copy of ION Technical Forum (ITF)
`
`2010
`
`Book
`
`of
`
`Abstracts,
`
`which
`
`can
`
`be
`
`found
`
`at
`
`
`
`
`3
`
`WESTERNGECO Exhibit 2101, pg. 3
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`
`
`http://www.iongeo.com/content/documents/pdfs/ITF_2010_Abstracts_.pdf
`
`(last
`
`accessed
`
`3/30/2015).
`
`19.
`
`Exhibit 2093 is a true and correct copy of admitted trial exhibit PTX 114
`
`from WesternGeco L.L.C. v. ION Geophysical Corp., et al., Civ. No. 4:09-cv-01872 (S.D. Tex.).
`
`20.
`
`Exhibit 2094 is a true and correct copy of admitted trial exhibit PTX 94
`
`from WesternGeco L.L.C. v. ION Geophysical Corp., et al., Civ. No. 4:09-cv-01872 (S.D. Tex.).
`
`21.
`
`Exhibit 2095 is a true and correct copy of admitted trial exhibit ION 125
`
`also labeled Moffat Exhibit 5 and Gentle Exhibit 4 from WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01872 (S.D. Tex.).
`
`22.
`
`Exhibit 2096 is a true and correct copy of admitted trial exhibit PTX 257
`
`from WesternGeco L.L.C. v. ION Geophysical Corp., et al., Civ. No. 4:09-cv-01872 (S.D. Tex.).
`
`23.
`
`Exhibit 2097 is a true and correct copy of admitted trial exhibit PTX 315
`
`also labeled Wagner Exhibit 7 and Dale Exhibit 12 from WesternGeco L.L.C. v. ION
`
`Geophysical Corp., et al., Civ. No. 4:09-cv-01872 (S.D. Tex.).
`
`24.
`
`Exhibit 2098 is a true and correct copy of admitted trial exhibit PTX 543
`
`from WesternGeco L.L.C. v. ION Geophysical Corp., et al., Civ. No. 4:09-cv-01872 (S.D. Tex.).
`
`25.
`
`Exhibit 2099 is a true and correct copy of the Verdict Form from
`
`WesternGeco L.L.C. v. ION Geophysical Corp., et al., Civ. No. 4:09-cv-01872 (S.D. Tex.).
`
`26.
`
`Exhibit 2102 is a true and correct copy of Multi Klient AS’ “Application
`
`for Permit to Conduct Geological or Geophysical Exploration for Mineral Resources or
`
`Scientific Research on the Outer Continental Shelf,” which can be found on the U.S. Department
`
`of
`
`the
`
`Interior
`
`Bureau
`
`of
`
`Ocean
`
`Energy
`
`Management
`
`website:
`
`
`
`
`4
`
`WESTERNGECO Exhibit 2101, pg. 4
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`
`
`https://www.data.boem.gov/homepg/data_center/other/WebStore/pimaster.asp?appid=5
`
`(last
`
`accessed 3/31/15).
`
`27.
`
`I hereby declare that all statements made herein of my own knowledge are
`
`true and that all statements made on information and belief are believed to be true; and further
`
`that these statements were made with the knowledge that willful false statements and the like so
`
`made are punishable by fine or imprisonment, or both, under Section 1001 of Title 18 of the
`
`United States Code and that such willful false statements may jeopardize the results of these
`
`proceedings.
`
`28.
`
`I declare under penalty of perjury under the laws of the United States of
`
`America that the foregoing is true and correct.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`__________________
` Timothy K. Gilman
`
`
`
`April 9, 2015
`New York, New York
`
`
`
`
`5
`
`WESTERNGECO Exhibit 2101, pg. 5
`PGS v. WESTERNGECO
`IPR2014-00689

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