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UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________________
`
`PETROLEUM GEO-SERVICES INC.
`
`Petitioner
`
`v.
`
`WESTERNGECO, LLC
`
`Patent Owner
`
`________________________
`
`Case IPR2014-01477
`U.S. Patent No. 7,080,607
`________________________
`
`PATENT OWNER’S MOTION TO SEAL UNDER
`37 C.F.R. §§ 42.14 AND 42.54
`
`
`

`
`Pursuant to 37 C.F.R. §§ 42.14 and 42.54, Patent Owner, WesternGeco
`
`Patent Owner’s Motion to Seal
`Case IPR2014-01477
`U.S. Patent No. 7,080,607
`
`
`L.L.C (“WesternGeco” or “Patent Owner”) submits this Motion to Seal certain
`
`exhibits submitted with Patent Owner’s Response filed on August 7, 2015.
`
`Patent Owner’s Response and certain accompanying exhibits were filed
`
`under seal because they contain information designated as confidential by Patent
`
`Owner, Petitioner, or a Third-Party. The below table lists those documents that the
`
`Patent Owner believes should remain under seal.
`
`I.
`
`Reasons for Sealing Certain Confidential Information
`A.
`Exhibits 2057, 2059–2061, 2067, 2085, 2099, 2101, 2102, 2108, 2127–2132,
`
`Patent Owner Response Exhibits
`
`2142, and 2143 were filed under seal. As set forth in Table 1, below, good cause
`
`exists for maintaining these exhibits under seal. It is noted that each of these
`
`exhibits is identical to exhibits with the same number in related proceedings
`
`IPR2014-01475 and IPR2014-01478.
`
`Table 1: Exhibits to Patent Owner’s Response that Should Remain Under Seal
`
`Exhibit Description
`
`Good Cause
`
`ION’s Response to
`
`This exhibit contains ION’s
`
`2053
`
`WesternGeco’s Motion to
`
`confidential information and is
`
`Disqualify ION’s
`
`subject to a protective order in
`
`
`
`2
`
`

`
`Exhibit Description
`
`Patent Owner’s Motion to Seal
`Case IPR2014-01477
`U.S. Patent No. 7,080,607
`
`
`Good Cause
`
`Consultants/Experts,
`
`WesternGeco L.L.C. v. ION
`
`WesternGeco L.L.C. v. Ion
`
`Geophysical Corporation, Civil
`
`Geophysical Corporation,
`
`Action No. 4:09-CV-01827.
`
`Civil Action No. 4:09-CV-
`
`01827
`
`Agreement Between PGS
`
`This exhibit contains confidential
`
`Geophysical A.S. and another
`
`business information between PGS
`
`party, WesternGeco L.L.C.v.
`
`Geophysical A.S. and a third-party,
`
`2057
`
`Petroleum Geo-Services Inc.,
`
`and is subject to a protective order in
`
`Civil Action No. 4:13-cv-
`
`WesternGeco L.L.C.v. Petroleum
`
`02725, PGS-
`
`Geo-Services Inc., Civil Action No.
`
`JURID_00000158-183.
`
`4:13-cv-02725.
`
`2059
`
`Deposition Transcript of John
`
`Thompson
`
`This exhibit contains party
`
`confidential information and is
`
`subject to a protective order in
`
`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`
`
`3
`
`

`
`Exhibit Description
`
`Patent Owner’s Motion to Seal
`Case IPR2014-01477
`U.S. Patent No. 7,080,607
`
`
`Good Cause
`
`Action No. 4:09-CV-01827.
`
`This exhibit contains party
`
`WesternGeco L.L.C. v. Ion
`
`confidential information and is
`
`Geophysical Corporation,
`
`subject to a protective order in
`
`Civil Action No. 4:09-CV-
`
`WesternGeco L.L.C. v. ION
`
`2060
`
`01827, ION756394
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
`
`This exhibit contains party
`
`2061
`
`2067
`
`WesternGeco L.L.C. v. Ion
`
`confidential information and is
`
`Geophysical Corporation,
`
`subject to a protective order in
`
`Civil Action No. 4:09-CV-
`
`WesternGeco L.L.C. v. ION
`
`01827, ION705039
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
`
`WesternGeco L.L.C. v. Ion
`
`This exhibit contains party
`
`Geophysical Corporation,
`
`confidential information and is
`
`Civil Action No. 4:09-CV-
`
`subject to a protective order in
`
`01827, ION893699
`
`WesternGeco L.L.C. v. ION
`
`
`
`4
`
`

`
`Exhibit Description
`
`Excerpt of Deposition
`
`2085
`
`Transcript of Oyvind
`
`Hillesund
`
`Declaration of Robin C.
`
`2099
`
`Walker (“Walker
`
`Declaration”).
`
`Patent Owner’s Motion to Seal
`Case IPR2014-01477
`U.S. Patent No. 7,080,607
`
`
`Good Cause
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
`
`This exhibit contains party
`
`confidential information and is
`
`subject to a protective order in
`
`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
`
`The Walker declaration is cited in
`
`support of Patent Owner’s Response
`
`and includes confidential business
`
`information of Patent Owner.
`
`Application of Q-Marine
`
`This exhibit is a draft of an article
`
`Technology for SPC; Imaging
`
`published in Offshore magazine (July
`
`2101
`
`the Pinghu Field Gas
`
`2008) containing confidential
`
`Reservoirs by M. Garden, T.
`
`information regarding WesternGeco’s
`
`Bunting
`
`Q-Marine system that was not
`
`
`
`5
`
`

`
`Exhibit Description
`
`Patent Owner’s Motion to Seal
`Case IPR2014-01477
`U.S. Patent No. 7,080,607
`
`
`Good Cause
`
`released in the published article.
`
`This exhibit contains confidential
`
`Presentation Titled: “Q-Marine
`
`business information regarding
`
`2102
`
`Improvements” by Robin
`
`WesternGeco’s Q-Marine system
`
`Walker
`
`included as part of an internal
`
`PowerPoint presentation.
`
`This exhibit contains confidential
`
`Presentation Titled: “4D
`
`business information regarding
`
`2108
`
`Acquisition with Q-Marine
`
`WesternGeco’s Q-Marine system
`
`Experiences and Strategies
`
`included as part of an internal
`
`2127
`
`Spreadsheet titled H12305-
`
`0007-075305
`
`PowerPoint presentation.
`
`This exhibit contains confidential
`
`business information regarding
`
`WesternGeco’s Q-Marine system.
`
`Spreadsheet titled
`
`This exhibit contains confidential
`
`2128
`
`CLIENTEF00502518 – Tims
`
`business information regarding
`
`stats 2005 to 2009 Retrieve 1
`
`WesternGeco’s Q-Marine system.
`
`
`
`6
`
`

`
`Exhibit Description
`
`Patent Owner’s Motion to Seal
`Case IPR2014-01477
`U.S. Patent No. 7,080,607
`
`
`Good Cause
`
`This exhibit contains confidential
`
`2129 WG0000029–WG0000030
`
`business information regarding
`
`WesternGeco’s Q-Marine system.
`
`This exhibit contains confidential
`
`2130 WG0000031–WG0000032
`
`business information regarding
`
`Document bearing Bates Nos.
`
`WG0000023–WG0000027
`
`Document bearing Bates Nos.
`
`WG0000001–WG0000022
`
`Declaration of Dr. Brian Evans
`
`Submitted in IPR2014-00688
`
`WesternGeco’s Q-Marine system.
`
`This exhibit contains confidential
`
`business information regarding
`
`WesternGeco’s Q-Marine system.
`
`This exhibit contains confidential
`
`business information regarding
`
`WesternGeco’s Q-Marine system.
`
`This exhibit was previously
`
`designated as confidential by
`
`Petitioner
`
`Declaration of Dr. Brian Evans
`
`This exhibit was previously
`
`Submitted in IPR2014-01478
`
`designated as confidential by
`
`7
`
`2131
`
`2132
`
`2142
`
`2143
`
`
`
`

`
`Exhibit Description
`
`Patent Owner’s Motion to Seal
`Case IPR2014-01477
`U.S. Patent No. 7,080,607
`
`
`Good Cause
`
`Petitioner
`
`II. Certification of Non-Publication Status
`Patent Owner’s undersigned counsel certifies that the information sought to
`
`be sealed by this motion has not been published or otherwise made public to the
`
`best of his knowledge.
`
`III. Certification of Conference with Opposing Party Pursuant to 37 C.F.R.
`§ 42.54
`
`Patent Owner has in good faith conferred with Petitioner, and the parties
`
`have agreed to a protective order in this case, Ex. 2038. Petitioner has taken no
`
`position on whether it will oppose this motion.
`
`IV. Request For Relief
`Patent Owner requests that the following exhibits remain under seal:
`
`2057, 2059–2061, 2067, 2085, 2099, 2101, 2102, 2108, 2127–2132, 2142,
`
`and 2143.
`
`
`
`
`
`8
`
`

`
`Patent Owner’s Motion to Seal
`Case IPR2014-01477
`U.S. Patent No. 7,080,607
`
`
`Respectfully submitted,
`Oblon, McClelland, Maier &
`Neustadt, LLP
`
`
`
`/Michael L. Kiklis/
`Michael L. Kiklis
`Registration No. 38,939
`
`Attorney for Patent Owner
`WESTERNGECO L.L.C.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Dated: August 7, 2015
`
`
`
`
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`
`
`
`
`
`
`Customer Number
` 22850
`Tel. (703) 413-3000
`Fax. (703) 413-2220
`
`
`
`9
`
`

`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the foregoing MOTION TO SEAL
`
`was served electronically on August 7, 2015, in their entireties upon the following
`
`counsel for Petitioner Petroleum Geo-Services, Inc.:
`
`David Berl
`dberl@wc.com
`
`Jessamyn Berniker
`jberniker@wc.com
`
`Thomas S. Fletcher
`tfletcher@wc.com
`
`Christopher Suarez
`csuarez@wc.com
`
`
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`
`
`/Michael L. Kiklis/
`Michael L. Kiklis
`Registration No. 38,939
`
`
`Attorney for Patent Owner
`WESTERNGECO L.L.C.
`
`
`
`
`
`Date: August 7, 2015

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