UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————————
`
`PETROLEUM GEO-SERVICES INC.,
`Petitioner
`
`v.
`
`WESTERNGECO LLC
`Patent Owner
`
`———————————
`
`Cases
`IPR2014-01475 (U.S. Patent No. 7,162,967)
`IPR2014-01477 (U.S. Patent No. 7,080,607)
`IPR2014-01478 (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 2135, pg. 1
`PGS v. WESTERNGECO
`IPR2014-01475
`
`
`
`———————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————————
`
`PETROLEUM GEO-SERVICES INC.,
`Petitioner
`
`v.
`
`WESTERNGECO LLC
`Patent Owner
`
`———————————
`
`Cases
`IPR2014-01475 (U.S. Patent No. 7,162,967)
`IPR2014-01477 (U.S. Patent No. 7,080,607)
`IPR2014-01478 (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 2135, pg. 1
`PGS v. WESTERNGECO
`IPR2014-01475
`
`
`
`
`
`particularly knowledgeable about the development, marketing and sales of WesternGeco’s
`
`QMarine 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 2101 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 2102 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 2108 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 2110 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.
`
`2
`
`
`
`
`
`WESTERNGECO Exhibit 2135, pg. 2
`PGS v. WESTERNGECO
`IPR2014-01475
`
`
`
`
`
`7.
`
`Exhibit 2111 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 2112 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 2113 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 2114 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 2115 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 2116 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
`
`3
`
`
`
`
`
`WESTERNGECO Exhibit 2135, pg. 3
`PGS v. WESTERNGECO
`IPR2014-01475
`
`
`
`
`
`this article. I received this article during my time at WesternGeco and kept it in the ordinary
`
`course of WesternGeco’s business.
`
`13.
`
`Exhibit 2122 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. I received this article during my time at WestemGeco and kept it in the
`
`ordinary course of WestemGeco's business.
`
`14.
`
`Exhibit 2132 is a true and correct copy of my trial demonstratives in
`
`the WesternGeco L.L.C. v. ION Geophysical Corp. et al., Civ. No. 09-1827 (S.D. Tex.) litigation.
`
`15.
`
`Exhibit 2131 is a true and correct copy of email correspondence
`
`dating from 2007 with subject line “Libya Technical Seminar,” in which I participated during
`
`my time at WesternGeco. This correspondence was made and kept in the ordinary course of
`
`WesternGeco’s business.
`
`16.
`
`Exhibit 2127 is a true and correct copy of a spreadsheet titled “H12305-
`
`0007-075305” that I authored between 1994 and 1996 during my time at WesternGeco. This
`
`spreadsheet was made and kept in the ordinary course of WesternGeco’s business. I understand
`
`that Exhibit 2127 was provided to counsel for Petroleum Geo-Services, Inc. in its native form on
`
`April 28, 2015, prior to my deposition commencing on April 30, 2015. I further understand that
`
`the electronic filing system used in this proceeding does not allow native documents to be
`
`uploaded. I have therefore generated the screenshots attached hereto, which are true and
`
`accurate depictions of the various sheets within the native excel document and representative of
`
`the totality of information contained within Exhibit 2127.
`
`17.
`
`Exhibit 2128 is a true and correct copy of a spreadsheet dating from 2010
`
`titled “Tims stats 2005 to 2009 Retrieve 1” that was produced by employees at WesternGeco and
`
`4
`
`
`
`
`
`WESTERNGECO Exhibit 2135, pg. 4
`PGS v. WESTERNGECO
`IPR2014-01475
`
`
`
`
`
`that I received during my time at WesternGeco. This spreadsheet was made and kept in the
`
`ordinary course of WesternGeco’s business. I understand that Exhibit 2128 was provided to
`
`counsel for Petroleum Geo-Services, Inc. in its native form on April 28, 2015, prior to my
`
`deposition commencing on April 30, 2015. I further understand that the electronic filing system
`
`used in this proceeding does not allow native documents to be uploaded. I have therefore
`
`generated the screenshots attached hereto, which are true and accurate depictions of the various
`
`sheets within the native excel document and representative of the totality of information
`
`contained within Exhibit 2128.
`
`18.
`
`Exhibit 2129 is a true and correct copy of an email dating from 2002 with
`
`subject line “Status report for May, 2002,” which I received during my time at WesternGeco.
`
`This correspondence was made and kept in the ordinary course of WesternGeco’s business.
`
`19.
`
`Exhibit 2130 is a true and correct copy of an email chain dating from
`
`2005 with subject line "Thanks from Captain and ChevronTexaco," in which I participated
`
`during my time at WestemGeco. This correspondence was made and kept in the ordinary
`
`course of WestemGeco's business.
`
`20.
`
`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.
`
`21.
`
`I declare under penalty of perjury under the laws of the United States of
`
`America that the foregoing is true and correct.
`
`5
`
`
`
`
`
`WESTERNGECO Exhibit 2135, pg. 5
`PGS v. WESTERNGECO
`IPR2014-01475
`
`
`
`
`
`August 7, 2015
`August 7, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`WESTERNGECO Exhibit 2135, pg. 6
`PGS V. WESTERNGECO
`IPR2014-01475
`
`6
`
`
`
`
`
`WESTERNGECO Exhibit 2135, pg. 6
`PGS v. WESTERNGECO
`IPR2014-01475
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