`
`Subject: IPR2014-00687; 00688; 00689
`Date:
`4/15/2015 4:34 PM
`From:
`"Michael L. Kiklis" <MKiklis@oblon.com>
`To:
`"trials@uspto.gov" <trials@uspto.gov>
`Cc:
`"CP Docket Kiklis" <CPDocketKiklis@oblon.com>, "CPDocketRicciuti"
`<CPDocketRicciuti@oblon.com>, "CP Docket Cappaert"
`<CPDocketCappaert@oblon.com>, "dberl@wc.com" <dberl@wc.com>, "Berniker,
`Jessamyn (JBerniker@wc.com)" <JBerniker@wc.com>, "CSuarez@wc.com"
`<CSuarez@wc.com>
`
`Trials,
`
`The Patent Owner noticed a typographical omission in Ex. 2077 of each Patent Owner Response in the above
`noted IPRs and now seeks permission from this Board to fix the error by filing corrected declarations with the
`Board in each case.
`
`The Patent Owner filed its Patent Owner Responses in IPR201400687, 00688, and 00689, where each Response
`included the same declaration from Mr. Robin Walker as Ex. 2077. The Petitioner objected to this exhibit, and in
`responding to the objections, the Patent Owner noticed that it had inadvertently omitted an oath in the
`declaration. The Patent Owner timely served a corrected declaration on the Petitioner as supplemental
`evidence where the only changes were (1) the inclusion of an oath and (2) a change in the title to indicate that
`the exhibit was a “corrected” declaration. No substantive changes, and indeed, no other changes of any kind
`were made to the declaration. The Patent Owner now seeks to file this corrected declaration with the Board in
`each case so that the Board will have an accurate record and to show the Board that this oversight has been
`corrected.
`
`The Petitioner does not consent to this request.
`
`Respectfully submitted,
`
`Michael L. Kiklis
`Lead Counsel for Patent Owner, WesternGeco
`
`Michael L. Kiklis
`Attorney at Law
`1940 Duke Street
`Alexandria, Virginia 22314
`Main Line: 703.413.3000
`Direct Line: 703.413.2707
`Mobile: 202.262.5741
`Fax: 703.413.2220
`MKiklis@oblon.com
`
`Oblon, McClelland,
`Maier & Neustadt, L.L.P.
`www.oblon.com
`
`about:blank
`
`7/3/2015
`
`WESTERNGECO Exhibit 2171, pg. 1
`PGS v. WESTERNGECO
`IPR2014-00689