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UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`
`
`
`
`
`PETROLEUM GEO-SERVICES INC.
`
`Petitioner,
`
`v.
`
`WESTERNGECO L.L.C.
`
`Patent Owner.
`______________
`
`Case IPR2014-00689
`
`Patent 7,293,520
`
`____________
`
`
`
`PATENT OWNER WESTERNGECO L.L.C. SUPPLEMENTAL
`EVIDENCE IN TO RESPONSE TO PETITIONER’S OBJECTIONS TO
`EVIDENCE DATED DECEMBER 30, 2014
`
`
`
`
`
`
`WESTERNGECO Exhibit 2166, pg. 1
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`Pursuant to 37 C.F.R. §42.64(b)(2), attached is supplemental evidence in
`
`WESTERNGECO L.L.C.
`Case IPR2014-00689
`U.S. Patent 7,293,520
`
`
`response to the Objections to Evidence dated December 30, 2014 submitted in
`
`IPRs 2014-00687, 00688, and 00689. Specifically:
`
`• The attached deposition transcripts of Clement B. Guilliot, III and Charles
`
`Joseph Ledet in response to objections to Exhibits 2002 in IPRs 2014-
`
`00687, 00688, and 00689.
`
`• The attached declaration of Timothy K. Gilman in response to objections to
`
`Exhibits 2008, 2009, 2013, and 2032 in IPRs 2014-00687, 00688, and
`
`00689.
`
`• The attached declaration of Scott A. McKeown in response to objections to
`
`Exhibit 2025 in in IPRs 2014-00687, 00688, and 00689.
`
`• The attached trial transcripts that were filed in WesternGeco L.L.C. v. Ion
`
`Geophysical Corporation, Civil Action No. 4:09-CV-01827 (“the ION
`
`litigation”), as downloaded from the Public Access to Court Electronic
`
`Records (PACER), in response to the numerous authentication objections to
`
`the same in IPRs 2014-00687, 00688, and 00689.
`
`
`
`
`
`WESTERNGECO Exhibit 2166, pg. 2
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`WESTERNGECO L.L.C.
`Case IPR2014-00689
`U.S. Patent 7,293,520
`
`
`Respectfully submitted,
`
`
`
`/Scott A. McKeown/
`Scott A. McKeown (Reg. No. 42,866)
`Attorney for Patent Owner
` WESTERNGECO L.L.C.
`
`
`
`
`
`
`
`
`
`Date: January 14, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`OBLON, SPIVAK, McCLELLAND,
`MAIER & NEUSTADT, L.L.P.
`1940 Duke Street
`Alexandria, Virginia 22314
`703-413-3000
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`WESTERNGECO Exhibit 2166, pg. 3
`PGS v. WESTERNGECO
`IPR2014-00689
`
`

`
`WESTERNGECO L.L.C.
`Case IPR2014-00689
`U.S. Patent 7,293,520
`
`
`CERTIFICATE OF SERVICE
`
`
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies service of PATENT
`
`OWNER WESTERNGECO L.L.C. SUPPLEMENTAL EVIDENCE IN TO
`
`RESPONSE TO PETITIONER’S OBJECTIONS TO EVIDENCE DATED
`
`DECEMBER 30, 2014 on the counsel of record for the Petitioner via electronic
`
`mail to the following address:
`
`David Berl
`Williams & Connolly, LLP
`725 Twelfth St. N.W.
`Washington, DC 20005
`DBerl@wc.com
`
`Christopher Suarez
`Williams & Connolly, LLP
`725 Twelfth St. N.W.
`Washington, DC 20005
`Csuarez@wc.com
`
`
`
`Respectfully submitted,
`
`
`
`Date: January 14, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Scott A. McKeown/
`Scott A. McKeown (Reg. No. 42,866)
`Attorney for Patent Owner
`WESTERNGECO L.L.C.
`
`WESTERNGECO Exhibit 2166, pg. 4
`PGS v. WESTERNGECO
`IPR2014-00689

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