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` LoCascio Cross of Robert Brune
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`And you know, sir, that there are people -- you have heard
`Q
`testimony from some -- that at the time of the invention were
`skeptical of if you could put a system together that would
`actually be able to steer these streamers that are this long
`and this far apart, correct?
`A
`Yeah. I guess with the caution or additional comment there
`has been many proposals, as we looked at some of the prior arts
`you showed before, for a long time the skepticism has usually
`been about efficiency in cost and ease of doing it as opposed
`to thinking that it simply could or could not be done.
`Q
`The first one to actually do it after all of those years
`was WesternGeco, right?
`A
`In a commercial implementation that had some commercial
`success, yes.
`Q
`There was some skepticism -- you could debate if it was
`skepticism that you could commercialize it or skepticism that
`you could make it work. That's your point?
`A
`Yes.
`Q
`You know there is testimony about a long-felt need in the
`industry to have this technology, correct?
`A
`Yes. And I would offer up the notion that there is maybe a
`secondary issue there that is significant. For many years,
`through the 1990s, typical streamer spacings were on the order
`of 160 meters, and concerns about entanglement and the ability
`to go to many streamers, more than four or six, was really
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
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`WESTERNGECO Exhibit 2036, pg. 1
`PGS v WESTERNGECO
`IPR2014-01475
`
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` LoCascio Cross of Robert Brune
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`greatly enhanced when vessels of the Ramform style became
`common.
`
`So I would add the concept that it was roughly in
`the late '90s, early 2000s that the need ratcheted up to a much
`higher level in the industry and, no surprise, commensurate
`with when a lot of the commercial activity started.
`Q
`So there was a long-felt need for lateral steering, and
`that continued to perhaps get more significant as more and more
`streamers were put on the back of boats?
`A
`Yeah, and put closer to 100 meters, and even shorter is a
`typical separation now.
`Q
`You know there was a long-felt need to get those streamers
`closer together that was met by the inventions in this case,
`correct?
`A
`Yes. There is a bit of a chicken-and-egg issue there in
`terms of willingness to put streamers in the water close
`together.
`Q
`You have seen testimony about the failure of others,
`including some of the other WesternGeco people like Workman and
`folks like that, to actually get this to work, right?
`A
`Yeah. I have personal knowledge of some of those dating
`back in the late '80s.
`Q
`In your own personal experience, you saw people try to do
`this and fail?
`A
`Yes. Fail usually for commercial reasons as much as
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`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
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`WESTERNGECO Exhibit 2036, pg. 2
`PGS v WESTERNGECO
`IPR2014-01475
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` LoCascio Cross of Robert Brune
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`technical.
`Q
`And the next one is praise of the invention by the
`infringer or others in the field. You understand, sir, that
`there was praise for WesternGeco in the industry after Q-Fin
`lateral steering was introduced?
`A
`Yeah. And most significantly the phrase "from oil and gas
`companies that are willing to pay for it."
`Q
`And, sir, all of those are factors that point to these
`patents not being obvious, correct?
`A
`They point to it not being obvious but with the cautions I
`mentioned about commercial issues being important. Certainly
`to do it in a commercial widespread practical version, no
`question that it was the Q-Fin in the 2000 time frame and
`beyond that really established it as an accepted technology.
`Q
`And these commercial success, skepticism, et cetera, these
`considerations of non-obviousness are not something that you
`took into account in providing your opinions this morning to
`the jury, correct?
`A
`I did take them into account in doing my analysis, but I
`didn't talk about them in the testimony, obviously, today.
`MR. LoCASCIO: No further questions, Your Honor. Pass
`the witness.
`THE COURT: Redirect?
`MR. PIERCE: Unfortunately for Mr. Brune, Your Honor,
`I do have some redirect.
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`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
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`WESTERNGECO Exhibit 2036, pg. 3
`PGS v WESTERNGECO
`IPR2014-01475
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