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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PETROLEUM GEO-SERVICES INC.
`Petitioner
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`v.
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`WESTERNGECO, LLC
`Patent Owner
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`Case IPR2014-01477
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`U.S. Patent No. 7,080,607
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`PETROLEUM GEO-SERVICES INC.’S LIST OF
`ANTICIPATED PROPOSED MOTIONS
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`Pursuant to the Trial Practice Guide, 77 Fed. Reg. 48,756, 48,765-66
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`(Aug. 14, 2012), in advance of the initial conference call with the Board scheduled
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`for Monday, April 13, at 1:00 p.m. EST, Petitioner Petroleum Geo-Services Inc.
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`(“PGS”) submits the following list of motions that PGS is considering filing in this
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`matter. The list includes motions that are anticipated as of the date of this filing.
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`PGS may seek Board authorization to file additional motions in the future, and this
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`list is not meant to be an exhaustive list of PGS’s potential motions.
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`A. Motion to Exclude Evidence Under 37 C.F.R. § 42.64(c)
`PGS may file a motion to exclude any exhibit to which it serves objections
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`to pursuant to 37 C.F.R. § 42.64(b)(1), which PGS may do within five business
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`days of receipt of Patent Owner’s Response to the Petition. The bases for any such
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`motion would be as set forth in objections served pursuant to 37 C.F.R.
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`§ 42.64(b)(1) and expanded upon in the motion to exclude.
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`B. Motion for Additional Discovery Under 37 C.F.R. § 42.51(b)(2)
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`If PGS needs additional discovery and the parties are unable to reach an
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`agreement regarding such additional discovery, PGS may file a motion for
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`additional discovery, including in relation to any arguments relating to objective
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`indicia advanced by patent owner.
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`Dated: April 9, 2015
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`Respectfully submitted,
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` /David I. Berl/
`David I. Berl
`Reg. No. 72,751
`Williams & Connolly LLP
`725 Twelfth Street, N.W.
`Washington, DC 20005
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`Phone: 202-434-5491
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`2
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the above-captioned Petroleum Geo-
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`Services Inc.’s List of Anticipated Proposed Motions was served on April 9, 2015,
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`by delivering a copy via electronic mail upon the following attorneys of record for
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`the Petitioner:
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`Michael Kiklis
`CPDocketKiklis@oblon.com
`Scott McKeown
`CPDocketMcKeown@oblon.com
`Kevin Laurence
`CPDocketLaurence@oblon.com
`Katherine Cappaert
`CPDocketCappaert@oblon.com
`Christopher Ricciuti
`CPDocketRicciuti@oblon.com
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`Oblon, McClelland, Maier & Neustadt, LLP
`1940 Duke Street
`Alexandria, Virginia 22314
`703-413-3000
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`Dated: April 9, 2015
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`Respectfully submitted,
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` /David I. Berl/
`David I. Berl
`Reg. No. 72,751
`Williams & Connolly LLP
`725 Twelfth Street, N.W.
`Washington, DC 20005
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`Phone: 202-434-5491
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