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`
` B. Evans
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________________________
` PETROLEUM GEO-SERVICES INC.
` Petitioner
` v.
` WESTERNGECO LLC
` Patent Owner
` _____________________________
`Case No. IPR2014-01475, -01476, -01477, -91478
` Patent No. 7,162,520 B2
` Patent No. 7,162,967 B2
` Patent No. 7,080,607
` _____________________________
`
` DEPOSITION OF DR. BRIAN EVANS
` Washington, D.C.
` Volume Two - July 10, 2015
`
` Reported by: Mary Ann Payonk
` Job No. 94682
`
`TSG Reporting - Worldwide
`(877) 702-9580
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`WESTERNGECO Exhibit 2052, pg. 1
`PGS v. WESTERNGECO
`IPR2014-01477
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`

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` B. Evans
`APPEARANCES:
`ON BEHALF OF PETITIONER:
` THOMAS FLETCHER, ESQUIRE
` JESSAMYN BERNIKER, ESQUIRE
` DAVID BERL, ESQUIRE
` CHRISTOPHER SUAREZ, ESQUIRE
` WILLIAMS & CONNOLLY
` 725 Twelfth Street, N.W.
` Washington, D.C. 20005
`
`ON BEHALF OF PATENT OWNER:
` MICHAEL KIKLIS, ESQUIRE
` CHRISTOPHER RICCIUTI, ESQUIRE
` KATHERINE CAPPAERT, ESQUIRE
` OBLON, McCLELLAND, MAIER & NEUSTADT
` 1940 Duke Street
` Alexandria, VA 22314
`
` SIMEON PAPACOSTAS, ESQUIRE
` KIRKLAND & ELLIS
` 300 North LaSalle
` Chicago, IL 60654
`ALSO PRESENT:
` Kevin Hart, Petroleum Geo-Services
`
`Page 223
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` B. Evans
` Q. I hope you feel better today because
`we have a lot of work to do. So why don't we
`just jump in and get started, okay?
` A. Yeah.
` MR. KIKLIS: I'm going to ask you
` guys to try to keep our breaks short
` because it's simply not a possibility to
` extend over to tomorrow. I have a
` preplanned and prepaid vacation tomorrow
` morning, so we're going to finish today.
` MS. BERNIKER: Obviously, we will
` try to keep our breaks short like we did
` yesterday.
` As to tomorrow, you requested 17
` hours -- scheduled for 17 hours of
` deposition and obviously, that's not
` possible to finish in two days so it's
` conceivable we will be here tomorrow.
` But we too hope that we will not be.
`BY MR. KIKLIS:
` Q. So I want to direct your attention to
`paragraph 231 of the '520 declaration,
`Dr. Evans. To refresh your recollection, the
`first sentence, you talk about setting
`
` B. Evans
`
` July 10, 2015
` 8:01 a.m.
`
` Deposition of DR. BRIAN J. EVANS,
`Ph.D., Volume Two, held at the offices of
`Williams & Connolly, 725 Twelfth Street, N.W.,
`Washington, D.C., pursuant to Notice before
`Mary Ann Payonk, Nationally Certified Realtime
`Reporter and Notary Public of the District of
`Columbia, Commonwealth of Virginia, and New
`York, CA-CSR No. 13431.
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`Page 222
`
` B. Evans
`BRIAN J. EVANS, Ph.D.,
` recalled as a witness, having been duly
` sworn, was admonished of his former
` oath, examined and testified as follows:
` EXAMINATION (Cont'd.)
`BY MR. KIKLIS:
` Q. Good morning, Dr. Evans.
` A. Good morning.
` Q. Do you understand that you are still
`under oath from yesterday?
` A. I do.
` Q. Okay. And you have to testify
`truthfully and honestly today?
` A. I do.
` Q. Okay. Are you feeling better today,
`Dr. Evans?
` A. Much.
` Q. I understand you had a headache
`yesterday afternoon.
` A. I did.
` Q. Do you normally get migraines or --
` A. I have the onset of migraine
`occasionally, occasionally, though the previous
`time was about two weeks ago.
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`WESTERNGECO Exhibit 2052, pg. 2
`PGS v. WESTERNGECO
`IPR2014-01477
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`Page 224
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` B. Evans
`threshold parameter in Workman's control system
`to a maximum distance.
` Do you see that?
` A. I see the first sentence says that.
` Q. The first sentence says that; right?
` A. Yeah.
` Q. So my question to you, sir, is if you
`set the steerable components along the length
`of the streamer in Workman to enforce a maximum
`distance separation, wouldn't those steerable
`components generate a lot of turbulence?
` MS. BERNIKER: Objection.
` A. This depends on when -- on the reason
`for setting the components for a maximum
`distance.
`BY MR. KIKLIS:
` Q. Okay. Could you explain that?
` A. Under some conditions, poor weather,
`high sea state levels, causes noise. The
`separation of streamers makes no difference to
`the noise, in many cases, under poor weather
`conditions.
` Q. Assuming that there weren't poor
`weather conditions.
`
`Page 226
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` B. Evans
`streamer in Workman to enforce a maximum
`distance separation, wouldn't these steerable
`components generate a lot of turbulence?
` MS. BERNIKER: Objection.
` THE WITNESS: Could you rephrase
` that, that long question?
` MR. KIKLIS: I will say it again.
`BY MR. KIKLIS:
` Q. So assuming there was no force that
`was pulling the streamers to their maximum
`distance -- are you with me so far?
` A. Yes.
` Q. So we don't have a situation where
`there are currents pulling the streamers apart.
`In that situation, if you set the steerable
`components along the length of the streamer in
`Workman to enforce a maximum distance
`separation, wouldn't those steerable components
`generate a lot of turbulence?
` MS. BERNIKER: Objection.
` A. The paravane or paravanes are at the
`front of the cable or cables. They can be
`totally independent of any streamer recording
`hydrophones, and they may take all of the noise
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` B. Evans
` MS. BERNIKER: Objection.
` A. If there were normal weather
`conditions, the maximizing of streamer
`separation could still remain within threshold
`levels of the noise limits.
`BY MR. KIKLIS:
` Q. Well, my question is -- let me start
`over.
` To enforce a maximum distance by the
`steerable components along the length of the
`streamer would require a significant amount of
`steering; isn't that right?
` MS. BERNIKER: Objection.
` A. Not necessarily.
`BY MR. KIKLIS:
` Q. Okay. And what do you mean by that?
` MS. BERNIKER: Objection.
` A. It depends on current directions,
`near-surface wind forces, sea state.
`BY MR. KIKLIS:
` Q. So assuming that there was no force
`that is pulling the streamers to their maximum
`distance, with that assumption, if you set the
`steerable components along the length of the
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`Page 227
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` B. Evans
`to pull the front ends over.
` And that does not mean that any force
`is then exerted on the other streamer steering
`devices, they take the force on their own.
`That's their raison d'etre.
`BY MR. KIKLIS:
` Q. But in the situation you just
`described, the paravanes would be creating a
`lot of turbulence, wouldn't they?
` A. The paravanes may create turbulence,
`but this does not follow that it's passed onto
`the seismic cable. Paravanes do not need to be
`established at the head of each streamer.
` Q. So assuming a situation where there
`is now a current, a small current going from
`right to left, to maintain -- I'm sorry, let me
`start over.
` So now assume that there's a small
`current going from right to left. In that
`situation, if you set the steerable components
`along the length of the streamer in Workman to
`enforce a maximum distance separation, wouldn't
`those steerable components generate a lot of
`turbulence?
`
`TSG Reporting - Worldwide
`(877) 702-9580
`
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`
`WESTERNGECO Exhibit 2052, pg. 3
`PGS v. WESTERNGECO
`IPR2014-01477
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`

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`Page 228
`
` B. Evans
` MS. BERNIKER: Objection.
`BY MR. KIKLIS:
` Q. So I'm not talking about a stormy
`situation.
` A. First of all --
` Q. Let me just -- I want to make sure
`we're clear on the hypothetical, okay? Not
`talking about a stormy situation. All I'm
`talking about is a small current traveling from
`right to left. We're assuming the vessel is
`going straight.
` A. That's what I was going to say. I
`don't know which way the vessel's going.
` Q. Polar coordinates, I guess. So the
`vessel --
` A. Cartesian.
` Q. The Cartesian. Okay. So let's
`assume that the vessel is traveling north.
` A. Okay.
` Q. Due north, okay? Streamers of course
`trailing south. There is a small current going
`from east to west, and those are -- and that's
`all there is to the hypothetical, and those
`storms -- nothing else. In that situation, if
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`Page 230
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` B. Evans
` MS. BERNIKER: He answered it.
` MR. KIKLIS: -- question, and your
` objection is --
` MS. BERNIKER: He told you it
` wouldn't happen.
` MR. KIKLIS: Okay.
`BY MR. KIKLIS:
` Q. Do you understand my hypothetical,
`sir?
` You have a vessel traveling due north
`with streamers -- towing an array of streamers.
`You have a small current traveling from east to
`west. And we're talking about the Workman
`patent, okay?
` Now, if you set the steerable
`components along the length of the streamer in
`Workman to enforce a maximum distance
`separation, wouldn't those steerable components
`generate a lot of turbulence?
` MS. BERNIKER: Objection, asked and
` answered.
` A. I made the comment before that you
`would not place the streamers wide if there was
`not an at-risk situation.
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` B. Evans
`you set the steerable components along the
`length of the streamer in Workman to enforce a
`maximum distance situation, wouldn't those
`steerable components generate a lot of
`turbulence?
` MS. BERNIKER: Objection.
` A. In this hypothetical, why would you
`put the streamer where there are normal
`currents at a maximum distance? I don't
`understand the -- even the hypothetical.
`BY MR. KIKLIS:
` Q. I --
` A. We put them at a maximum distance for
`at-risk situations.
` Q. Sir, it's not important that you
`understand why I ask the question. Please
`answer my hypothetical.
` MS. BERNIKER: Objection, asked and
` answered.
` A. The hypothetical --
` MR. KIKLIS: Well, wait. Wait a
` minute. You've got to be kidding me.
` Your witness has refused to answer
` the --
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` B. Evans
` My understanding of your situation is
`that it is not at-risk and that there's a minor
`cross-flowing current. There is no
`hypothetical that -- this would never happen in
`practice, to my understanding, according to
`Workman.
`BY MR. KIKLIS:
` Q. I'm not asking you whether it would
`occur in practice, sir. My question was to
`assume my hypothetical and answer the question.
`If you don't want to answer the question, just
`say so and I'll move on.
` A. I have said that your hypothetical is
`incorrect in its form, and conditions you are
`proposing would not happen even in a
`hypothetical.
` Q. But you're suggesting that nobody
`would want to do this. And I'm asking you that
`if somebody did do this under these
`circumstances, wouldn't there be a lot of
`turbulence?
` A. In these circumstances, I have seen
`streamers not put at their maximum but moved
`over, and it's created no noise, no more noise
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`WESTERNGECO Exhibit 2052, pg. 4
`PGS v. WESTERNGECO
`IPR2014-01477
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` B. Evans
`than was already there.
` Q. Okay. Your answer, sir, you referred
`to streamers not put at their maximum, but --
` A. Right.
` Q. -- I'm asking you, sir, if they were
`put at their maximum, maximum distance in the
`hypothetical that I gave you, wouldn't that
`generate a lot of turbulence?
` MS. BERNIKER: Objection.
` A. I did answer before that the -- the
`paravanes take the maximum noise. They take
`the noise away from the cable when they tow to
`a maximum distance. They don't necessarily
`have to be at the front end of the cable.
` In other words, in that case, the
`cable positioning devices would not have a lot
`of noise and you could, in this situation, in
`your hypothetical, you would not be recording,
`of course.
`BY MR. KIKLIS:
` Q. Why wouldn't you be recording?
` A. You've taken your streamers far away
`from the locations on the pre-plots and you'll
`have shut down recording.
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`Page 234
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` B. Evans
`interpretation would you like me to use?
` Q. Gikas.
` A. You say Gikas? I'll use your
`terminology just to keep you happy.
` Q. Okay.
` A. A paper published in the London
`Hydrographic Journal in July 1995 by Gikas, who
`was a Ph.D. student at the University of New
`Castle. This, as all Ph.D. students have to in
`my department, produce at least one paper per
`year in an accepted publication, journal, or
`conference.
` The title is, "A Rigorous and
`Integrated Approach to Hydrophone and Source
`Positioning During Multistreamer Offshore
`Seismic Exploration."
` Q. Can we just refer to Exhibit 1058 as
`Gikas?
` A. Okay, that's fine.
` Q. Have you read Gikas?
` A. I have.
` Q. You understand its contents?
` A. I think I do.
` Q. So I'd like to direct your attention
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` Q. So if you set your streamers to a
`maximum distance, you're not going to be doing
`recording; is that right?
` MS. BERNIKER: Objection.
` A. The reason for setting streamers at a
`maximum distance is to prevent them from
`tangling essentially when weather conditions
`are inclement, poor, rough seas. That is the
`condition. And you make that decision
`abandoning the seismic survey at that point in
`time, and the first to go are the paravanes.
` MR. KIKLIS: I'm handing you what's
` been marked as Exhibit 1058.
` THE WITNESS: We've finished with
` that one, have we?
` MR. KIKLIS: For the moment, yes.
` You can put that aside.
`BY MR. KIKLIS:
` Q. I've handed you what's been marked
`Exhibit 1058, Dr. Evans. Do you recognize
`this?
` A. I do.
` Q. What is it?
` A. A paper by Gikas or Gikas. Which
`
`Page 235
`
` B. Evans
`to page 11.
` A. Yeah.
` Q. Do you see where it says
`"Introduction"?
` A. Yes.
` Q. The first paragraph under
`"Introduction."
` A. Yes.
` Q. There's a few introductory sentences
`which talk about the basic configuration of an
`offshore seismic exploration survey, and then
`at the end of that paragraph is the following
`sentence: "The surveying problem is to
`determine the position of the guns and
`hydrophones at the instance of firing and
`reception respectively."
` Do you see that sentence, sir?
` A. I do.
` Q. Did I read that right?
` A. You read that correctly.
` Q. So the problem that Gikas is trying
`to address is to determine the position of the
`guns and hydrophones, isn't it?
` MS. BERNIKER: Objection.
`
`TSG Reporting - Worldwide
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`PGS v. WESTERNGECO
`IPR2014-01477
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` B. Evans
` A. It is not the problem.
`BY MR. KIKLIS:
` Q. I'm sorry, did you say that that is
`not the problem?
` A. As it appears, it is the fact that
`Gikas is trying to predict the positions of the
`guns and hydrophones at the instance of firing
`and reception respectively. That is the
`correct interpretation at that time that was
`inferred by Gikas.
` Q. Okay. Let me direct your attention
`to the second-to-last sentence of this
`paragraph.
` That sentence says that the surveying
`problem is to determine the position of the
`guns and hydrophones at the instance of firing
`and reception respectively, doesn't it?
` A. That's the statement it makes.
` Q. And that's -- and that sentence
`appears in the first paragraph of the
`introduction, doesn't it?
` A. It does.
` Q. And nowhere in that sentence does it
`refer to prediction, does it?
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`Page 238
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` B. Evans
`these sources at the time of firing and the
`receiver location in order to maintain the
`operations within specified limits from a
`contractual standpoint.
`BY MR. KIKLIS:
` Q. Well, isn't the location of the guns
`and hydrophones at the instance of firing and
`reception important to interpret the data
`that's generated?
` MS. BERNIKER: Objection.
` A. It is not possible to know the
`precise location of the sources or receivers at
`the point, at the instant of firing, because we
`have a moving configuration.
` It is not standing still as it would
`have done on land; it is moving. You cannot
`get a precise position on location when the
`guns are fired; you can only predict the
`location.
`BY MR. KIKLIS:
` Q. Your -- so your testimony is that
`Gikas is predicting where the guns and
`hydrophones were at the time of firing and
`reception? Is that what you're saying?
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`Page 237
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` B. Evans
` A. As a person of ordinary skill in the
`art, I would read it as being prediction.
` Q. Why would it be important to know the
`position of the guns and hydrophones at the
`time that they fire and receive signals?
` A. Your question is ill-posed because we
`cannot fire the guns and receive signals at the
`same time.
` Q. Well, I'm just paraphrasing the
`sentence that says "at the instance of firing
`and reception respectively." I don't think my
`question said they would occur at the same
`time.
` So my question is, sir, why is it
`important to determine the position of the guns
`and hydrophones at the instance of firing and
`reception respectively?
` MS. BERNIKER: Objection.
` A. The service company, through its
`contract with the operator of the permit survey
`area, has a contractual obligation to maintain
`the location of sources and receivers within
`specified contractual limits. It would be of
`great importance to understand the location of
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` B. Evans
` MS. BERNIKER: Objection.
` A. I am saying that in the statement of
`the surveying problem within the confines of
`this particular statement Gikas has made, he
`already is aware of the fact that the vessel is
`moving and that he, being a person of ordinary
`skill in the art, would use this terminology to
`refer to the fact that you cannot obtain an
`actual position in real time. You can only
`obtain a predicted position in real time.
`BY MR. KIKLIS:
` Q. So what Gikas is attempting to do is
`obtain the best estimate for the location of
`the guns and hydrophones at the time of firing
`and reception; isn't that right?
` A. He is trying to predict in whichever
`way or form he can as a best estimate.
` Q. So then the purpose of Gikas is to
`generate a best estimate of the location of the
`guns and hydrophones at the instant of firing
`and reception; right?
` A. The thrust of this Gikas publication
`is around using a modified version of the
`Kalman filter to use prior positions of the
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`WESTERNGECO Exhibit 2052, pg. 6
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`guns and streamers to be able to predict the
`location of the next upcoming shot point, shot
`location, and receiver locations.
` Q. But the purpose is to provide a best
`estimate of the guns and hydrophones at the
`time that they fired and received so that you
`can have a better quality interpretation of the
`seismic data; isn't that right?
` MS. BERNIKER: Objection.
` A. The initial purpose of Gikas
`surrounds obtaining a prediction of location as
`fine as is possible, with the tools available
`at the time. And the philosophy of that this
`improves data quality is totally secondary to
`this paper.
`BY MR. KIKLIS:
` Q. Are you saying that Gikas' estimation
`of the location of the guns and hydrophones at
`the instance of firing and reception does not
`improve data quality?
` MS. BERNIKER: Objection.
` A. Data quality is a function of many
`aspects, and improved prediction of positioning
`is only one aspect of many inputs into data
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`Page 242
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`can the industry at that time in 1995.
`BY MR. KIKLIS:
` Q. Objection, nonresponsive.
` I asked you, sir -- let me direct
`your attention to page 24.
` A. Of?
` Q. Of the document you have in front of
`you, sir.
` A. Of the Gikas paper. Yes.
` Q. Under "Conclusions," do you see that?
` A. I see "Conclusions."
` Q. Okay. The first sentence under
`"Conclusions," do you see that first sentence?
` A. I see that first sentence.
` Q. It says: "It is apparent from the
`results of the tests that the suggested method
`is a highly realistic approach to the problem
`of integrated processing of 3D marine seismic
`data."
` Did I read that right?
` A. You did.
` Q. And that's the first sentence under
`"Conclusions" in Gikas, isn't it?
` A. It is.
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`quality improvement.
`BY MR. KIKLIS:
` Q. Are you testifying then that Gikas
`provides other inputs to improve data quality?
` MS. BERNIKER: Objection.
` A. I am testifying that Gikas has only
`one part of data inputs to data quality by his
`modifications laid out in his paper of the
`Kalman filter approach.
`BY MR. KIKLIS:
` Q. The Kalman filter approach to
`estimating a location of the guns -- the
`position of the guns and hydrophones at the
`instances of firing and reception; right?
` MS. BERNIKER: Objection.
` A. The Kalman filter is a mathematical
`methodology of developing a predicted location
`using prior information, and Gikas simply
`modifies that filter, which, because this is
`1995, and he makes quite clear that the Kalman
`filter is used by -- on UNIX platforms
`throughout the commercial seismic industry, he
`argues that if his own desktop computer can
`perform this modification in real time, then so
`
`Page 243
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` B. Evans
` Q. Okay. It seems that Gikas' primary
`objective is data quality, isn't it?
` MS. BERNIKER: Objection.
` A. No.
`BY MR. KIKLIS:
` Q. So your testimony here, sir, is
`that -- so your testimony is, sir, that even
`though the introduction paragraph says "The
`surveying problem is to determine the position
`of guns and hydrophones at the instance of
`firing and reception respectively," and then
`the -- the first sentence of the conclusion
`says "It is apparent from the results of the
`tests that the suggested method is highly
`realistic approach to the problem of integrated
`processing of 3D marine seismic data," your
`testimony is that data quality is not the
`primary objective of Gikas; correct?
` MS. BERNIKER: Objection.
` A. This is a paper --
`BY MR. KIKLIS:
` Q. Yes or no question, sir.
` A. Can I -- can I please --
` Q. It --
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`WESTERNGECO Exhibit 2052, pg. 7
`PGS v. WESTERNGECO
`IPR2014-01477
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` A. -- answer this comprehensively?
` Q. It --
` A. This is a paper which describes
`positioning. This describes positioning. In
`the "Conclusion" sentence you have just read to
`me, it describes integrated 3D seismic
`processing. I'm sorry, but that does not refer
`to data quality. It's a totally different
`industry from seismic interpretation.
` Q. So then is your testimony that Gikas
`is directed to seismic data interpretation?
` MS. BERNIKER: Objection.
` A. This statement in the conclusions is
`all about improving the prediction of
`positioning data to improve an integrated
`processing -- computer processing
`methodologies.
`BY MR. KIKLIS:
` Q. Why would you want to know the
`positions to improve the integrated processing?
` A. Seismic data processing has many
`input variables, and a fine-tune of any of
`those input variables as is being presented by
`the Gikas paper provides a marginal improvement
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`Page 246
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` MS. BERNIKER: Objection.
`BY MR. KIKLIS:
` Q. Right?
` A. Gikas is all about predicting in real
`time the locations of guns and hydrophones.
` Q. And if you have a better
`identification of the location of where the
`guns and hydrophones were at the time of firing
`and reception, then you can render better
`results from the seismic data; isn't that
`right?
` MS. BERNIKER: Objection.
` A. You can more accurately process the
`seismic data. That's what the first sentence
`says.
`BY MR. KIKLIS:
` Q. So then Gikas is directed to better
`estimating the locations of the guns and
`hydrophones at the time of firing and reception
`to more accurately process the seismic data; is
`that right?
` MS. BERNIKER: Objection.
` A. In the industry, we have a statement
`that says garbage in is garbage out.
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`in how you manipulate the prestacked seismic
`data.
` Q. So then is it your testimony that
`Gikas is directed to more accurate position
`detection of guns and hydrophones for use with
`prestacked seismic data?
` MS. BERNIKER: Objection.
` A. Could you repeat the sentence?
`Because --
`BY MR. KIKLIS:
` Q. What I'm trying to get at, sir, is
`that Gikas is directed to better identifying
`the location of guns and hydrophones; right?
` A. That's identifying a methodology of
`prediction of those locations, not the actual
`locations.
` Q. Okay. An estimate, if you will, of
`where the guns and hydrophones were at the time
`of firing and reception; right?
` MS. BERNIKER: Objection.
`BY MR. KIKLIS:
` Q. Because, as you testified, it's
`impossible to know their exact location or
`precise location, as you said.
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`Page 247
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`BY MR. KIKLIS:
` Q. I've actually heard that before.
` A. Good. And it means that if you can
`improve your input data, be it navigation, be
`it seismic, then you would hope that you could
`improve your output data, be it navigation, be
`it seismic.
` Q. And that's what Gikas is directed to;
`correct?
` MS. BERNIKER: Objection.
` A. Gikas is only directed to prediction
`of improved positioning in real time in the
`hope that that might improve 3D seismic
`processing of the same data of the seismic
`recording data.
`BY MR. KIKLIS:
` Q. Let me direct your attention to
`page -- I think we're still on 11. Go back to
`11, please.
` A. Right, 11.
` Q. At the very bottom of that page in
`the right-hand column, sir, tell me when you're
`focused on that.
` A. Column -- second column?
`
`TSG Reporting - Worldwide
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`WESTERNGECO Exhibit 2052, pg. 8
`PGS v. WESTERNGECO
`IPR2014-01477
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` Q. Second column, page 11, spilling over
`to page 12.
` A. Oh.
` Q. It says: "Secondly and probably most
`importantly, it is extremely difficult to
`analyze the error propagation through such a
`process - hence, it is almost impossible to
`describe the precision and reliability of the
`final gun and hydrophone positions."
` Do you see that?
` A. I see that.
` Q. Did I read that right?
` A. You read that correctly.
` Q. So it's a very difficult task to
`describe with any precision the final gun and
`hydrophone positions; right?
` MS. BERNIKER: Objection.
` A. At what time are you referring to?
`BY MR. KIKLIS:
` Q. Well, I think what we're talking
`about is at the time of firing and receiving.
` A. So you are aware of the fact that
`when the guns fire and the recording process
`then commences after they fire, within
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`Page 250
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`there is occasionally performed an onboard
`interpretation.
` In the vast majority of surveys,
`however, it can take three to six months to
`process a 3D seismic survey before the seismic
`interpretation is performed.
` So anywhere between having massive
`computing onboard ship and being able to
`commence a fundamental seismic interpretation
`to actually waiting six months and therefore
`performing the interpretation six months after
`completion of survey in the office, that's the
`bandwidth when a seismic survey is interpreted.
`BY MR. KIKLIS:
` Q. So what kind of interpretation is
`done on the seismic data on the boat?
` MS. BERNIKER: Objection.
` A. I need clarification. Are we talking
`about seismic interpretation or processing
`data?
`BY MR. KIKLIS:
` Q. Well, you testified in your answer,
`sir, that there were circumstances under which
`there was seismic data interpretation onboard
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`milliseconds -- 52 milliseconds, I think it
`is -- that the whole array is in motion.
` And so that's why I asked you when,
`because the array can be -- is in motion at the
`time of firing and is in a different location
`on conclusion of recording. And that is the
`reason why it is very difficult to predict
`precise positions at the point of firing or any
`point during recording thereafter.
` And that is the emphasis on Gikas'
`paper is that he best wishes to make that
`prediction. And when he says it's extremely
`difficult to analyze the error propagation
`during the time of movement, errors are being
`built up in any propagation prediction.
` Q. So when it comes time to interpret
`the seismic data, is that done on boat or is
`that done in a lab afterwards?
` MS. BERNIKER: Objection.
` A. It cannot be performed until the
`seismic data is processed. In the case of
`recording 4D surveys, it requires massively
`parallelled computers to be able to process the
`4D. And in those very expensive occasions,
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`the vessel. And I'm just trying to find out,
`sir, what did you mean by that?
` A. I mean that when a seismic
`interpreter has a chance, which is very rare,
`to interpret data on a vessel during a 3D
`survey, that person must understand
`conventional vertical slice clastic geology and
`interpretation, and also horizontal fluvial or
`carbonate geological interpretation to perform.
`You are entering a very large area of science
`in -- in such a study.
` Q. So in addition to the knowledge that
`someone would need for this onboard
`interpretation, you'd also need some serious
`computing power; right?
` MS. BERNIKER: Objection.
` A. Compared with any other industry,
`seismic computing power is probably one of the
`greatest. Some banks consider they have
`similar power, and maybe NASA.
` But you need very large, I did say,
`massively parallel