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UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF TEXAS
`HOUSTON DIVISION
`
`WESTERNGECO LLC
`
`VS.
`
`ION GEOPHYSICAL
`
`CORPORATION, EUGRO
`GEOTEAM,
`INC., ET AL
`
`O9—CV—1827
`
`Houston, Texas
`
`7:35 a.m.
`
`July 31, 2012
`
`JURY TRIAL
`
`Volume 7
`
`Morning Session
`
`BEFORE THE HONORABLE KEITH P. ELLISON
`UNITED STATES DISTRICT JUDGE
`
`10
`
`11
`
`12
`
`13
`
`14 APEEARANCES:
`
`15
`
`F0 TH PLAINTIFF:
`
`16 Lee L. Kaplan
`SMISER, KAPLAN & VESELKA, LLP
`17 700 Louisiana, Suite 2300
`Houston, Texas 77002
`18 713.221.2300
`
`19
`
`Gregg F. LoCascio
`20 KIRKLAND & ELLIS LLP
`655 Fifteenth Street Northwest
`21 Washington, DC 20005
`202.879.5290
`
`22
`
`Sarah Tsou
`23 Timothy K. Gilman
`KIRKLAND & ELLIS LLP
`24 Citigroup Center
`153 East 53rd Street
`25 New York, New York 10022
`212.446.6435
`
`Tang GOPYICERTIFY
`TTEST:
`”'
`
`'
`
`‘V
`
`Johnny C. Sanchez, RMR, CRR — jcscourtreporterfiaol.com
`
`WESTERNGECO Exhibit 2118, pg. 1
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`Direct—MoJ:ton/By Ms . Tsou
`
`(I.)\l®U1»J>0Ol\)I-‘
`
`in your opinion?
`
`A. Well,
`
`the biggest role is to be able to repeat
`
`exactly what you did last time, as well as close that
`
`hole. Because if a 4D is a tool to manage an oil field,
`
`that's really what it is, it's a tool to manage an oil
`
`I'll field.
`
`And if you've got this big hole where the
`
`oil field is —— a big hole in the data where your oil
`
`field is, you can't use it very effectively.
`
`Q.
`
`Let's turn to PTX 398. What is this document? Did _
`
`you consider this docuent?
`
`A.
`
`Yes, ma'am.
`
`Q. What is it?
`
`A.
`
`This is a document talking about steerable streamer
`
`benefits, and they list who is --
`
`Q.
`
`I know it's small, but I think the bottom it says --
`
`it's coming from Fugro's files, but is this an ION
`
`document?
`
`A.
`
`Q.
`
`That is my understanding.
`
`Now, what is —— does part of the document show on
`
`Page I44?
`
`A. Well, basically, you know, it says there are two
`
`benefits to using steerable streamers utilizing DigiFIN
`
`devices. And the two aspects to the benefits are seismic
`
`contractors are looking for cost and time efficiency as
`
`Johnny C. Sanchez, RMR, CRR — jcscourtreporter@aol.com
`
`WESTERNGECO Exhibit 2118, pg. 2
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`Direct—Morton/By Ms . Tsou
`
`well as, you know,
`
`the HSE benefit is clearly not sending
`
`out some guy in a little Zodiac back—to—back. And the
`
`oil companies are looking for geophysical benefits. And I
`
`think this confirms my opinion of both of the benefits
`
`that I concluded with -- they're agreeing with my
`
`conclusions here.
`
`Q.
`
`And the next section on this page, does that address
`
`your opinions regarding the need for lateral steering for
`
`4D?
`
`A.
`
`Yes.
`
`It is widely known among the oil companies that
`
`the steerability is important there.
`
`So they do know that
`
`it's a key factor in influencing the success of 4D‘s
`
`repeatability.
`
`That's why we use the word repeatability.
`
`I mean, if you put your receiver here on where I'm
`
`sitting, and or back at the back door I actually haven't
`
`repeated it.
`
`If the receiver is in a different place
`
`you're not repeating it. And the whole term is
`
`repeatability through the industry.
`
`Q.
`
`That last part of the page —- of the section I should
`
`say, it says,
`
`"Most 3D seismic shot in North Sea has some
`
`4D objective. And this is increasingly the case in other
`
`regions of the world where environmental conditions make
`
`4D surveys feasible."
`
`Do you agree with that statement?
`
`A.
`
`Yes,
`
`I do. Having worked I was -- I was manager of
`
`Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`ll
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`WESTERNGECO Exhibit 2118, pg. 3
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`Direct—Morton/By Ms . Tsou
`
`(D\lO‘\U‘|n.l>U.)k)|—‘
`
`subsurface technology for Kerr-McGee for the North Sea and
`
`that involved geophysics and reservoir simulation, which
`
`is part of reservoir management.
`
`And when I was over there, it was really
`
`clear that the fields were being shot with the idea that
`
`we're going to use 4D down the road. And so, it is
`
`becoming widespread around the world.
`
`Q.
`
`So in the North Sea, even if it's a 3D survey,
`
`the
`
`idea is it could very well be a 4D down the road?
`
`A.
`
`Yes.
`
`I don't think you can count any 3D.
`
`If I go
`
`get a survey,
`
`I may not tell the contractor that it's
`
`going to be used in 4D because he doesn't necessarily need
`
`to know at this time. And —— but I may —— and I may not
`
`know because I don't know whether I'm going to be able to
`
`sell it to my management, hey, let's go spend another
`
`$5 million again.
`
`So sometimes it's tough to get that
`
`money.
`
`Q.
`
`Can lateral steering play a role in that first survey
`
`if you think it might be repeated down the road?
`
`A.
`
`I think if you have an inclination or even an inkling
`
`down that it might be 4D down the road, you ought to use
`
`lateral steering.
`
`Q.
`
`Why is that?
`
`A.
`
`So that you'll know where your cables and shots were.
`
`Without the lateral steering you really don't know quite
`
`Johnny C. Sanchez, RMR, CRR — jcscourtreportert-7aol.com
`
`WESTERNGECO Exhibit 2118, pg. 4
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`Direct—Morton/By Ms . Tsou
`
`where everything is.
`
`I mean, you kind of have a close
`
`approximation, but the error bar is very, very big, and
`
`you need that knowledge reduced down so that you can put
`
`your cables back where they were.
`
`Q.
`
`A.
`
`Let's turn together to PTX 214.
`
`214.
`
`Q.
`
`I believe we've seen this before, but let's look at
`
`Page 209. And this is that ION presentation saying,
`
`"Irregularities of streamer shape increase 4D noise, and
`
`reduce repeatability."
`
`A.
`
`Yes, ma'am.
`
`Q. What does this mean to you?
`
`A.
`
`This is an ION document and this is basically them
`
`saying that irregularities and streamer shape, which
`
`really means irregularities and where you put -- where the
`
`cable —— are you repeatable are increasing the noise and
`
`they use repeatability.
`
`If your old survey is kind of all over the
`
`place, you don't quite know where it is, you can't
`
`quite -- you can't ever repeat it when you go back.
`
`So
`
`basically they're saying that by having a straight
`
`streamer or at least a well behaved set of streamers, you
`
`can reduce that noise out of the 4D signal.
`
`Q.
`
`So having a straighter or more well behaved array in
`
`the first survey makes it easier to review?
`
`Johnny C. Sanchez, RMR, CRR — jcscourtreporter@aol.com
`
`WESTERNGECO Exhibit 2118, pg. 5
`PGS v. WESTERNGECO
`IPR2014-00689

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