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)
`———————————
`
`SUPPLEMENTAL DECLARATION OF ROBIN C. WALKER
`
`
`
`Pursuant to 28 U.S.C. § 1746, I, Robin C. Walker, the undersigned, hereby declare as
`
`follows:
`
`1.
`
`My name is Robin C. Walker. 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 have worked in the marine seismic industry for 30 years in technical,
`
`research and customer-facing roles. Through my experience, I have developed first-hand
`
`knowledge of the technologies that have driven customer demand and enabled effective
`
`acquisition techniques in this industry. During my 30 year tenure at Schlumberger, I rose to be
`
`the Vice President of Sales and Marketing Director for WesternGeco from March 2008 to March
`
`2013 and a Global Account Director for Schlumberger from March 2013 to January 2015. I am
`
`WESTERNGECO Exhibit 2104, pg. 1
`PGS v. WESTERNGECO
`IPR2014-00689
`
`
`
`———————————
`
`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)
`———————————
`
`SUPPLEMENTAL DECLARATION OF ROBIN C. WALKER
`
`
`
`Pursuant to 28 U.S.C. § 1746, I, Robin C. Walker, the undersigned, hereby declare as
`
`follows:
`
`1.
`
`My name is Robin C. Walker. 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 have worked in the marine seismic industry for 30 years in technical,
`
`research and customer-facing roles. Through my experience, I have developed first-hand
`
`knowledge of the technologies that have driven customer demand and enabled effective
`
`acquisition techniques in this industry. During my 30 year tenure at Schlumberger, I rose to be
`
`the Vice President of Sales and Marketing Director for WesternGeco from March 2008 to March
`
`2013 and a Global Account Director for Schlumberger from March 2013 to January 2015. I am
`
`WESTERNGECO Exhibit 2104, pg. 1
`PGS v. WESTERNGECO
`IPR2014-00689
`
`
`
`particularly knowledgeable about the development, marketing and sales of WesternGeco’s Q-
`
`Marine System and the market’s reception of Q-Marine and other systems that practice the
`
`patents I understand to be at issue in this proceeding (“Bittleston patents”).
`
`3.
`
`Exhibit 2079 is a true and correct copy of a final draft of an industry
`
`magazine article entitled “Application of Q-Marine Technology for SPC; Imaging for Pinghu
`
`field gas reservoirs” that was produced by employees at WesternGeco and SPC (a customer of
`
`WesternGeco) in 2008 and that I received in 2008 and approved in my role as the worldwide Q
`
`Product Manager. This article was made and kept in the ordinary course of WesternGeco’s
`
`business.
`
`4.
`
`Exhibit 2080 is a true and correct copy of a customer and marketing
`
`presentation entitled “Q-Marine improvements.” I produced and gave this presentation during
`
`my time at WesternGeco, specifically during the early to mid-2000s. This presentation was
`
`made and kept in the ordinary course of WesternGeco’s business.
`
`5.
`
`Exhibit 2086 is a true and correct copy of a presentation entitled “4D
`
`Acquisition with Q-Marine - Experiences and Strategies” that was produced by employees at
`
`WesternGeco and that I received during my time at WesternGeco. Specifically, I received this
`
`presentation on or around December 1, 2004. This presentation was made and kept in the
`
`ordinary course of WesternGeco’s business.
`
`6.
`
`Exhibit 2088 is a true and correct copy of an article entitled “Mapping the
`
`fluid front and pressure buildup using 4D data on Norne Field” from the September 2006 issue of
`
`The Leading Edge, an industry magazine of the Society of Exploration Geophysicists (SEG). I
`
`received this article during my time at WesternGeco and kept it in the ordinary course of
`
`WesternGeco’s business.
`
`WESTERNGECO Exhibit 2104, pg. 2
`PGS v. WESTERNGECO
`IPR2014-00689
`
`
`
`7.
`
`Exhibit 2089 is a true and correct copy of an article entitled “Interpreting
`
`reservoir talk” from the September 4, 2003 issue of Offshore Engineer. I received this article
`
`during my time at WesternGeco and kept it in the ordinary course of WesternGeco’s business.
`
`8.
`
`Exhibit 2090 is a true and correct copy of an article entitled “Making a
`
`good recovery” from the March 14, 2005 issue of Offshore Engineer. I received this article
`
`during my time at WesternGeco and kept it in the ordinary course of WesternGeco’s business.
`
`9.
`
`Exhibit 2091 is a true and correct copy of ION Technical Forum (ITF)
`
`2010’s Book of Abstracts. A version of this document is available for download from ION’s
`
`website. See http://www.iongeo.com/content/documents/pdfs/ITF_2010_Abstracts_.pdf.
`
`10.
`
`Exhibit 2092 is a true and correct copy of an article entitled “Intelligent
`
`Infill for Cost Effective 3D Seismic Marine Acquisitions” from the 71st EAGE Conference and
`
`Exhibition.
`
`11.
`
`Exhibit 2093 is a true and correct copy of a draft of an industry magazine
`
`article entitled “Evolution Through New Functionality and Applications, Q-Marine gets even
`
`better” that was produced by employees at WesternGeco. This article was made and kept in the
`
`ordinary course of WesternGeco’s business.
`
`12.
`
`Exhibit 2094 is a true and correct copy of an article entitled “Q-
`
`Technology - moving into the mainstream” from the July/August 2003 issue of The Journal of
`
`Offshore Technology. Employees at WesternGeco contributed significantly to the content of this
`
`article. I received this article during my time at WesternGeco and kept it in the ordinary course
`
`of WesternGeco’s business.
`
`13.
`
`Exhibit 2100
`
`is a
`
`true and correct copy of an article entitled
`
`“WesternGeco, Seeing Below the Surface” from the May 2002 issue of Shell E&P Technology.
`
`WESTERNGECO Exhibit 2104, pg. 3
`PGS v. WESTERNGECO
`IPR2014-00689
`
`
`
`I received this article during my time at WestemGeco and kept it in the ordinary course of
`
`WesternGeco’s business.
`
`14.
`
`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.
`
`15.
`
`I declare under penalty of perjury under the laws of the United States of
`
`America that the foregoing is true and correct.
`
`Date: April 9, 2015
`
`
`
`Robin C. Walker: T
`
`WESTERNGECO Exhibit 2104, pg. 4
`PGS V. WESTERNGECO
`|PR20’|4-00689
`
`WESTERNGECO Exhibit 2104, pg. 4
`PGS v. WESTERNGECO
`IPR2014-00689
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