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`UNITED STATES DISTRICT COURT
`SOUTflERN DISTRICT OF TEXAS
`HOUSTON DIVISION
`
`WESTERNGECO LLC,
`
`PLAINTIFF,
`
`VS.
`
`ION GEOPHYSICAL
`CORPORATION, FUGRO GEOTEAM,
`_NC., ET AL,
`
`DEFENDANTS
`
`4:09-CV-01827
`HOUSTON, TEXAS
`
`JULY 24, 2012
`7:37 A.M.
`
`TRANSCRIPT OF JURY
`TRIAL
`BEFORE THE HONORABLE Kfl
`TH P. ELLISON
`UNITED STATES DISTRICT JUDGE
`
`A P P E A R A N C E S:
`
`FOR THE PLAINTIFF:
`
`Lee K. Kaplah
`SMYSER KAPLAN & VESELKA LLP
`Bank of America Center
`Suite 2300
`77002
`
`700 gouisiana,
`HOUSCOD, Texas
`
`Gregg F. Locascio
`KIRKLAND & ELLIS LLP
`655 Fifteenth Street Northwest
`
`Washington, DC 20005
`
`Sarah Tsou
`
`Timothy K. Gilman
`KIRKLAND &
`fiLL
`S LLP
`Citigroup Center
`153 East 53rd Street
`New York, New York
`
`10022
`
`TRHSGQPYEGEREFY
`
`
`
`CSR, RMR,
`Mayra Malone,
`mayramalone@comcast.net
`
`WESTERNGECO Exhibit 2154, pg. 1
`PGSVWNESTERNGECO
`|PR2014~01477
`
`10
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`WESTERNGECO Exhibit 2154, pg. 1
`PGS v. WESTERNGECO
`IPR2014-01477
`
`

`
`LOCASCIO Continued Direct of THOMAS SCOULIOS
`
`316
`
`1
`
`2
`
`3
`
`4
`
`5
`
`Q
`
`A
`
`Same company?
`
`Yes.
`
`Q When you said they were an early adopter of the technology,
`
`what do you mean?
`
`A
`
`Statoil had been using Q for many years.
`
`They had
`
`6 written -— they were very proud of the stuff.
`
`They had worked
`
`7
`
`8
`
`9
`
`10
`
`ll
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`25
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`with us on it. They had written glowing report cards of our
`
`use of it.
`
`They had said that our technology was above and
`
`beyond the best.
`
`MW. LOCASCIOI Pull up Plaintiff's Exhibit Number 95.
`
`BY M. LOCASCIO:
`
`Q What are we looking at here, sir?
`
`A
`
`This is a press release by Schlumberger.
`
`Q What is the title of it?
`
`A
`
`"Realtime news, Statoil awards WesternGeco Q—Marine 4D
`
`projects in Norway."
`
`Q
`
`And it says "repeat surveys," the subheading. What is a
`
`repeat survey?
`
`A
`
`Q
`
`A.
`
`Q
`
`A repeat survey is a 4D survey.
`
`Are there two components to a 4D survey?
`
`Yes.
`
`The second one,
`
`I assume,
`
`is the 4D survey. What is the
`
`other one called?
`
`A.
`
`Q
`
`The first survey is called the baseline survey.
`
`Are there times where you were asked to bid a survey that
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
`WESTERNGECO Exhibit 2154, pg. 2
`PGSVWNESTERNGECO
`|PR2014~01477
`
`WESTERNGECO Exhibit 2154, pg. 2
`PGS v. WESTERNGECO
`IPR2014-01477
`
`

`
`LOCASCIO Continued Direct of THOMAS SCOULIOS
`
`317
`
`will ultimately become the baseline for a later survey but you
`
`are not told it is 4D when you do the first one?
`
`A
`
`Q
`
`Yes.
`
`In that instance, are you just told it is a 3D survey?
`
`A Correct.
`
`MW. LOCHSCIOI Dave, let's pull back from that and
`
`blow up the second paragraph.
`
`The one that begins with "lease
`
`selected."
`
`BY M. LOCASCIO:
`
`Q
`
`You mentioned that Statoil was, if you will, saying nice
`
`things about your product and services.
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`They were.
`
`is this one of those examples?
`
`They did.
`
`Can you read that for the jury?
`
`"We selected the WesternGeco Q—Technology because of the
`
`repeatability provided by steer streaming and minimum azimuth
`
`variation between base and monitor surveys, said Erik
`
`Havarstein, manager, seismic acquisition, Statoil."
`
`MW. LOCHSCIUI Let's go down three paragraphs from
`
`there,
`
`to the one that begins with the other quote.
`
`ZHE WITNESS:
`
`"Our first Q surveys on Norne confirmed
`
`that the repeatability was accurate enough to detect subtle 4D
`
`effects and resulted in changed drilling plans. We expect the
`
`2004 surveys to similarly increase our knowledge of these
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
`10
`
`ll
`
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`17
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`18
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`24
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`25
`
`WESTERNGECO Exhibit 2154, pg. 3
`PGSVWNESTERNGECO
`|PR2014~01477
`
`WESTERNGECO Exhibit 2154, pg. 3
`PGS v. WESTERNGECO
`IPR2014-01477
`
`

`
`LOCASCIO Continued Direct of THOMAS SCOULIOS
`
`318
`
`reservoirs, said Hans A. Aronsen, project leader, seismic
`
`activities, Halten—Nordland area, Statoil Harstad.
`
`BY MR. LOCASCIO:
`
`Q Were these comments consistent with what you heard from
`
`Statoil and others in the field?
`
`A
`
`Q
`
`They were.
`
`We were talking about the Chukchi —- is that how you
`
`pronounce it?
`
`A
`
`Q
`
`Yes, it is.
`
`The Chukchi Sea job in the Arctic for Statoil, which
`
`ultimately didn't go to WesternGeco, correct?
`
`A Correct.
`
`Q
`
`A
`
`Did you at WesternGeco tender on the job?
`
`We did. We provided —- they asked for services, and we
`
`provided a response.
`
`Q
`
`Can you explain how the tender process works from a, if you
`
`will, paperwork standpoint? What comes first?
`
`A
`
`An oil company will put out a request for a tender or a
`
`request for bid.
`
`They have 20 different names for it, but it
`
`is basically, we have this job in this location, we would like
`
`it done on this time frame, use it with these survey
`
`objectives.
`
`Q
`
`And did you receive one of those at WesternGeco for the
`
`Statoil Chukchi
`
`job?
`
`A
`
`We did.
`
`CSR, RMR, CRR
`Mayra Malone,
`mayramalone@comcast.net
`
`10
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`24
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`25
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`WESTERNGECO Exhibit 2154, pg. 4
`PGSVWNESTERNGECO
`|PR2014~01477
`
`WESTERNGECO Exhibit 2154, pg. 4
`PGS v. WESTERNGECO
`IPR2014-01477

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