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` J. Cole
` 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 JACK H. COLE, Ph.D.
` Washington, D.C.
` Volume Two - June 26, 2015
`
` Reported by: Mary Ann Payonk
` Job No. 94685
`
`TSG Reporting - Worldwide 877-702-9580
`
`WESTERNGECO Exhibit 2045, pg. 1
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

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`Page 280
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`Page 281
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` J. Cole
`
` June 26, 2015
` 9:03 a.m.
`
` Deposition of DR. JACK H. COLE, Ph.D.,
` Volume Two, held at the offices of Williams &
` Connolly, 725 12th 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, States of Maryland
` and New York, CA-CSR No. 13431.
`
`Page 282
`
` J. Cole
` Appearances (Cont'd.):
` ON BEHALF OF PATENT OWNER:
` SIMEON PAPACOSTAS, ESQUIRE
` KIRKLAND & ELLIS
` 300 North LaSalle
`
`
`
` ALSO PRESENT:
` Kevin Hart, (by Internet Realtime)
` Petroleum Geo-Services, Inc.
`
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` J. Cole
` APPEARANCES:
` ON BEHALF OF PETITIONER:
` THOMAS FLETCHER, ESQUIRE
` ALEC SWAFFORD, ESQUIRE
` JESSAMYN BERNIKER, ESQUIRE
` WILLIAMS & CONNOLLY
` 725 12th Street N.W.
` Washington, D.C. 20005
`
`
` ON BEHALF OF PATENT OWNER:
` MICHAEL KIKLIS, ESQUIRE
` CHRISTOPHER RUCCIUTI, ESQUIRE
` KATHERINE CAPPAERT, ESQUIRE
` OBLON McCLELLAND MAIER
` & NEUSTADT
` 1940 Duke Street
` Alexandria, VA 22314
`
`
`
`Page 283
`
` J. Cole
` JACK H. COLE, 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: 09:03:03
` Q. Good morning, Dr. Cole. 09:03:04
` A. Good morning. 09:03:05
` Q. You understand that you're still 09:03:06
` under oath from yesterday? 09:03:07
` A. Yes, sir. 09:03:09
` Q. Is that your understanding? 09:03:09
` A. Yes, sir. 09:03:11
` Q. And you promise to testify truthfully 09:03:11
` and honestly today? 09:03:14
` A. Yes, sir. 09:03:15
` MR. KIKLIS: Before we get started, 09:03:16
` I see we have a new face at the table. 09:03:16
` MR. FLETCHER: Christopher Suarez 09:03:19
` from Williams & Connolly on behalf of 09:03:21
` Petroleum GeoServices, Inc. 09:03:25
` MR. KIKLIS: Welcome. 09:03:30
` BY MR. KIKLIS: 09:03:32
` Q. Dr. Cole, yesterday at any of the 09:03:34
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`TSG Reporting - Worldwide 877-702-9580
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`WESTERNGECO Exhibit 2045, pg. 2
`PGS v. WESTERNGECO
`IPR2014-01478
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`Page 284
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` J. Cole
` breaks or in the evening, did you speak with 09:03:37
` your counsel about your deposition? 09:03:40
` A. No, sir. 09:03:43
` Q. Do you have any conversations with 09:03:44
` anybody about your deposition? 09:03:46
` A. No, sir. 09:03:50
` Q. Or your testimony from yesterday? 09:03:50
` A. No, sir. 09:03:52
` Q. Did you go directly back to your 09:03:53
` hotel after the deposition yesterday? 09:03:55
` A. No, sir. Tom showed me where I might 09:03:59
` be able to get a massage, because I was not 09:04:06
` familiar here. So we walked there and then he 09:04:09
` took me back to the hotel so I wouldn't be lost 09:04:13
` and -- 09:04:15
` Q. Oh. 09:04:16
` A. -- we bid goodnight at the door, and 09:04:16
` then I was on my own the rest of the evening. 09:04:19
` I didn't talk to or have conversations with 09:04:21
` anyone regarding this, nor during that time. 09:04:24
` Q. I'd like to have you pull out your 09:04:32
` declaration for the '607 patent. 09:04:38
` A. I have it. 09:04:53
` Q. Would you please turn to paragraph 09:04:55
`
`Page 286
`
` J. Cole
` Q. Okay. Is that a true statement? 09:16:11
` A. Yes. 09:16:19
` Q. Do you know what the word "supra" 09:16:22
` means? 09:16:26
` A. I would like to be refreshed on it. 09:16:27
` I think it -- IB means ibid., which -- 09:16:30
` referring to the same thing. But I would 09:16:32
` really appreciate being refreshed on that 09:16:34
` terminology. It's a legal term which I 09:16:38
` personally don't use, but I think it refers to 09:16:41
` the paragraphs that -- 72, 78 and -- 09:16:47
` Q. So in your sentence here, you say 09:16:55
` that "the system as a whole utilizes a 09:16:57
` distributed processing control architecture and 09:17:02
` behavior-predictive model-based control logic"; 09:17:04
` isn't that correct? 09:17:07
` A. I think if you read that, that's a 09:17:15
` quotation from the '607 patent, yes, so -- 09:17:16
` Q. So -- 09:17:25
` A. -- looks like column 360 to -- let me 09:17:26
` take you there. 09:17:29
` Q. I'm not asking you to go to the 09:17:37
` specific location in the patent. 09:17:38
` MR. FLETCHER: Objection. 09:17:40
`
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` J. Cole
` 40? 09:04:57
` A. Yes, sir, I'm there. 09:05:05
` Q. At the bottom of paragraph 40, which 09:05:19
` is on the top of page 20, tell me when you get 09:05:21
` there. 09:05:36
` A. Yes, I'm there. 09:05:37
` MR. KIKLIS: I'm not getting any 09:08:04
` feed on this. 09:08:04
` (Recess taken.) 09:05:39
` BY MR. KIKLIS: 09:15:29
` Q. Dr. Cole, I'd like to direct your 09:15:30
` attention, sir, to the bottom of paragraph 40 09:15:32
` on the top of page 20 in your '607 declaration. 09:15:34
` Are you there, Dr. Cole? 09:15:39
` A. Yes, sir. 09:15:41
` Q. Okay. Now, in there you say, "The 09:15:41
` system as a whole," in quotes, "utilizes a 09:15:45
` distributed processing control architecture and 09:15:48
` behavior-predictive model-based control logic 09:15:51
` to properly control the streamer positioning 09:15:56
` devices which I discuss in paragraphs 72 09:16:00
` through 88, supra." 09:16:04
` Did I read that correctly? 09:16:07
` A. I think you read it verbatim. 09:16:09
`
`Page 287
`
` J. Cole
` BY MR. KIKLIS: 09:17:49
` Q. My question is, sir, is it your 09:17:50
` understanding that the '607 patent utilizes 09:17:52
` behavior-predictive model-based control logic? 09:17:57
` MR. FLETCHER: Objection. 09:18:03
` A. The answer to that is no. I read 09:18:08
` that the patent says that, as it's quoted. 09:18:10
` That's what I'm aware of. 09:18:17
` BY MR. KIKLIS: 09:18:25
` Q. So are you saying that -- 09:18:25
` THE WITNESS: Excuse me, that was a 09:18:27
` distraction. When I hear an alarm goes 09:18:28
` off, I tend to panic just a little bit. 09:18:34
` MR. KIKLIS: Could you silence your 09:18:39
` cell phones please? 09:18:40
` MR. SUAREZ: Sorry. 09:18:43
` MR. KIKLIS: Thank you very much. 09:18:44
` THE WITNESS: I apologize, but I'm 09:18:44
` a little bit stressed, so -- so go 09:18:46
` ahead. 09:18:48
` BY MR. KIKLIS: 09:18:50
` Q. So are you saying that the '607 09:18:52
` patent does not describe a system that utilizes 09:18:55
` behavior-predictive model-based control logic? 09:19:02
`
`TSG Reporting - Worldwide 877-702-9580
`
`3
`
`WESTERNGECO Exhibit 2045, pg. 3
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`Page 288
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` J. Cole
` MR. FLETCHER: Objection. 09:19:06
` A. I don't recall having said that, sir. 09:19:06
` BY MR. KIKLIS: 09:19:09
` Q. Okay. Then are you -- is it your 09:19:10
` opinion that the '607 patent describes a system 09:19:13
` that utilizes behavior-predictive model-based 09:19:18
` control logic? 09:19:21
` MR. FLETCHER: Objection. 09:19:25
` A. I think again what is here is a -- is 09:19:31
` a -- is a quotation and has nothing to do with 09:19:33
` that question that you asked me. I think I -- 09:19:39
` I would respond that this is a quotation from 09:19:43
` the patent. 09:19:48
` BY MR. KIKLIS: 09:19:49
` Q. Sir, but the words before the 09:19:50
` quotation, "the system as a whole," are your 09:19:52
` words, aren't they? 09:19:56
` A. Wait a minute. 09:19:59
` Q. Can you answer that question? 09:20:54
` MR. FLETCHER: Objection. 09:20:57
` BY MR. KIKLIS: 09:20:57
` Q. I see you're reading the patent, and 09:20:58
` my question is that the words "the system as a 09:21:00
` whole" are not in quotation marks. And doesn't 09:21:02
`
`Page 290
`
` J. Cole
` BY MR. KIKLIS: 09:22:00
` Q. I'm sorry, sir. If you answered the 09:22:04
` question, just tell me what it was. Maybe I 09:22:06
` didn't hear it. 09:22:08
` A. I said that I did not answer the 09:22:09
` question, sir. I was -- 09:22:11
` Q. Oh. 09:22:12
` A. -- attempting to answer the question 09:22:13
` when you interrupted me and then asked another 09:22:14
` question, which I have not answered. 09:22:17
` MR. KIKLIS: Okay. Okay, Tom, you 09:22:18
` were wrong. 09:22:19
` MR. FLETCHER: Well, the record 09:22:20
` will actually reflect who's right about 09:22:21
` that. 09:22:23
` MR. KIKLIS: Okay. 09:22:24
` BY MR. KIKLIS: 09:22:25
` Q. So my question, sir, is this 09:22:25
` sentence, the last sentence of paragraph 40 of 09:22:28
` your '607 declaration utilizes the words "the 09:22:31
` system as a whole" not in quotation marks. And 09:22:37
` my question, to you, sir, is whether those 09:22:42
` words are yours. 09:22:46
` A. I'm not sure if those are -- are my 09:22:54
`
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` J. Cole
` that mean, sir, that those are your words? 09:21:07
` A. Is that a new question? 09:21:13
` Q. That's my question, sir. Please 09:21:15
` answer that question. 09:21:17
` A. You asked two questions, and -- 09:21:18
` Q. Sir? Sir? 09:21:19
` A. -- I had not answered the -- the 09:21:19
` first one and you're asking me a second one, 09:21:20
` so -- 09:21:22
` Q. Sir, I'm -- 09:21:24
` A. -- I guess what I'm answering -- 09:21:24
` Q. Sir, I asked -- I asked -- answer the 09:21:24
` question that I asked you. 09:21:26
` My question is: The words "the 09:21:28
` system as a whole" do not appear in quotation 09:21:31
` marks. Now, doesn't -- 09:21:35
` A. That -- that's incorrect. That -- 09:21:39
` Q. -- that -- doesn't that mean that 09:21:41
` those are your words? Can you answer that 09:21:43
` question? 09:21:47
` MR. FLETCHER: Objection, asked and 09:21:49
` answered. I know you don't have the 09:21:49
` realtime, but he did just answer that 09:21:58
` question. 09:22:00
`
`Page 291
`
` J. Cole
` words exactly or as I read them from the patent 09:22:59
` and that's why I'm looking at the patent. And 09:23:01
` if you're not going to allow me to do that, I 09:23:03
` don't know how to answer that, sir, truthfully. 09:23:06
` They may or not be my words, but I prefer to 09:23:12
` look at the patent to see if -- if the system 09:23:17
` as a whole is also included in the quotation. 09:23:22
` Q. Sure. Look at the -- look at the 09:23:27
` quotation. I believe your citation is column 09:23:27
` 4, lines 11 through 14. 09:23:30
` A. Yeah. 09:24:27
` Q. You beat me there, Dr. Cole. 09:24:27
` A. Go ahead. 09:24:33
` Q. Okay. I'm sorry, sir. So my 09:24:34
` question is -- 09:24:37
` A. Let me tell you why I'm having to 09:24:38
` struggle a little bit. 09:24:42
` Q. Sure. 09:24:43
` A. My eyesight isn't perfect, and -- and 09:24:43
` the -- the print in this patent is -- is -- is 09:24:45
` fairly small and -- and sometimes, it's 09:24:49
` difficult for me to -- to read it clearly with 09:24:54
` my vision. And I'm -- I'm sorry this -- that 09:24:59
` this -- if this were in larger font, as is the 09:25:04
`
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`PGS v. WESTERNGECO
`IPR2014-01478
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` J. Cole
` declaration, I assure you that it would go 09:25:09
` faster. 09:25:11
` I'm going as fast as I -- I'm able 09:25:12
` with my vision, sir, and not trying to delay. 09:25:14
` I'm just trying to see if -- if that's said 09:25:18
` verbatim in the patent or is there something 09:25:22
` that I said. And it -- it -- just a minute. 09:25:24
` Okay, it says -- okay. 09:25:30
` Q. Okay, fair enough. 09:25:33
` A. I -- 09:25:33
` Q. Let -- 09:25:33
` A. I -- 09:25:33
` Q. -- me -- 09:25:33
` (Overlapping simultaneous speaking.) 09:25:33
` A. I agree with you that -- 09:25:33
` Q. -- ask -- 09:25:34
` MR. FLETCHER: Objection. 09:25:36
` MR. KIKLIS: Hold on. Do you guys 09:25:36
` have a magnifying glass that we can use? 09:25:37
` MR. FLETCHER: I don't have one 09:25:40
` handy. I don't carry one. 09:25:40
` MS. BERNIKER: You're welcome to 09:25:42
` put it on the screen. 09:25:43
` MR. KIKLIS: Oh, that would be 09:25:45
`
`Page 294
`
` J. Cole
` we can project it on a screen as widely as you 09:41:44
` like. 09:41:46
` A. I appreciate that. Thank you, sir. 09:41:47
` Q. So now let's get back to the 09:41:49
` questions. The question, sir, that was 09:41:51
` pending, with respect to your declaration, 09:41:54
` paragraph 40, last sentence, you say "the 09:41:57
` system as a whole." And my question to you, 09:42:02
` sir, is whether those words are your words. 09:42:06
` A. And I would like to take this 09:42:10
` opportunity to apologize, counselor, for the 09:42:12
` confusion. The reason for that is that I was 09:42:17
` sworn to tell the whole truth, nothing but the 09:42:20
` truth. 09:42:23
` The reason I was deferring to the 09:42:23
` patent was to be sure that I didn't get those 09:42:25
` words from the patent. As to their being my 09:42:28
` words, I will state they are the words as are 09:42:35
` shown in this declaration, which I approve. 09:42:38
` Whether they're -- they're actually my words or 09:42:45
` not, I'm not sure, but I agree with what's said 09:42:47
` here. 09:42:51
` Q. Okay. Then you agree that the system 09:42:51
` as a whole utilizes a behavior-predictive 09:42:53
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` great. 09:25:46
` THE WITNESS: Yeah. 09:25:46
` MR. KIKLIS: Okay. 09:25:47
` THE WITNESS: Is -- is that okay? 09:25:51
` MR. FLETCHER: We can set that up. 09:25:53
` MS. BERNIKER: I'll look for a 09:25:57
` magnifying glass. 09:25:58
` MR. KIKLIS: Why don't we take a 09:25:59
` five-minute break? Why don't we take a 09:26:00
` five-minute break? The court reporter 09:26:02
` needs a five-minute break. We will get 09:26:05
` Dr. Cole a magnifying glass, then we can 09:26:07
` have a lot of fun for the rest of the 09:26:10
` day, okay? 09:26:12
` MR. FLETCHER: Fine. 09:26:13
` (Recess taken.) 09:31:22
` BY MR. KIKLIS: 09:41:16
` Q. Sorry for the interruption, Dr. Cole, 09:41:25
` but we have requested a magnifying glass to 09:41:28
` assist you with reading the patent. 09:41:32
` A. Yes, sir. 09:41:35
` Q. And so we have now provided you with 09:41:35
` the option of three. And if it becomes 09:41:37
` difficult, we have it loaded on a computer and 09:41:41
`
`Page 295
`
` J. Cole
` model-based control logic? 09:42:59
` MR. FLETCHER: Objection. 09:43:01
` BY MR. KIKLIS: 09:43:03
` Q. Is that correct? 09:43:03
` A. What I -- I'm saying here is the 09:43:05
` system as a whole, and -- and then quoting what 09:43:09
` the patent says, uses that. 09:43:14
` Q. Okay. But part of that -- 09:43:17
` A. And I didn't say that it uses -- I 09:43:20
` said as a whole, quotation, and this is -- 09:43:21
` rather than trying to use exactly the words, 09:43:27
` that this is what I understand, is that the 09:43:30
` system as a whole, quote, that -- 09:43:33
` Q. Right. 09:43:38
` A. And -- and that's all I said. That's 09:43:39
` all I've done is quote that. 09:43:41
` Q. Understood. 09:43:42
` A. Okay. 09:43:43
` Q. But your testimony in your 09:43:44
` declaration is that the system as a whole 09:43:46
` utilizes behavior-predictive model-based 09:43:49
` control logic; isn't that correct? 09:43:53
` MR. FLETCHER: Objection. 09:43:57
` A. I think the statement stands on its 09:44:03
`
`TSG Reporting - Worldwide 877-702-9580
`
`5
`
`WESTERNGECO Exhibit 2045, pg. 5
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

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` own. I think it contains a quotation mark, and 09:44:08
` I don't think that that infers that I say that. 09:44:11
` I'm saying this is what the patent says. The 09:44:15
` system as a whole, quote, uses that according 09:44:19
` to what the patent says, not that I say that. 09:44:25
` That's -- that's a quotation, sir. 09:44:30
` BY MR. KIKLIS: 09:44:32
` Q. So you're saying that the patent says 09:44:33
` that the system as a whole utilizes 09:44:36
` behavior-predictive model-based control logic; 09:44:39
` is that correct? 09:44:43
` A. That's not correct. I didn't say the 09:44:45
` patent says "the system as a whole." That's my 09:44:49
` understanding of what the system as a whole, in 09:44:52
` quotation -- I didn't say the -- that the 09:45:02
` patent said that. I -- I searched to see if 09:45:05
` the patent said that. I couldn't find it. If 09:45:10
` it's there, I -- I don't know -- I'm not aware 09:45:13
` of it. 09:45:14
` Q. Well, you have a citation here to 09:45:15
` column 4, lines 11 through 14 in the patent, 09:45:19
` and that's the whole purpose why we ran out to 09:45:24
` CVS to buy you a magnifying glass. 09:45:27
` A. Would -- would you speak a little 09:45:30
`
`Page 298
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` J. Cole
` BY MR. KIKLIS: 09:46:19
` Q. So could you please read -- so let me 09:46:20
` direct your attention to column 4, lines 11 09:46:25
` through 14. 09:46:29
` A. Uh-huh. 09:46:30
` Q. It says there: "To compensate for 09:46:31
` these localized current fluctuations, the 09:46:34
` inventive control system utilizes a distributed 09:46:37
` processing control architecture and 09:46:41
` behavior-predictive model-based control logic 09:46:43
` to properly control the streamer positioning 09:46:46
` devices." 09:46:50
` Did I read that correctly? 09:46:50
` A. I think you read that verbatim, sir. 09:46:52
` Q. Okay. And is that what you 09:46:54
` understand the '607 patent to describe? 09:46:57
` A. What I -- and since you -- you don't 09:47:11
` want me to read this '607 patent, which I 09:47:14
` won't, I will say that to my recollection, 09:47:16
` that's the only place where it uses that 09:47:20
` terminology. 09:47:25
` It may have, sir, but it -- for -- 09:47:27
` for the purpose of your question right here, I 09:47:30
` don't recall seeing it anywhere else. I -- I 09:47:33
`
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` J. Cole
` louder, sir? I'm having -- 09:45:30
` Q. Oh, sure. 09:45:32
` A. Thank you. 09:45:34
` Q. So you refer in your declaration to 09:45:35
` column 4, lines 11 through 14 in the patent, 09:45:37
` the '607 patent; correct? 09:45:42
` A. Correct. 09:45:44
` Q. Okay. And you had a problem reading 09:45:45
` that language, so we ran out and got you a 09:45:46
` magnifying glass. 09:45:50
` A. I think that was -- if you'll forgive 09:45:51
` me, sir, I think that was a little sarcastic 09:45:53
` and you don't need to do that to me. 09:45:55
` Q. It's a fact, isn't it? 09:45:59
` So we've now -- now, we'd appreciate 09:46:00
` it if you could use the magnifying glass and 09:46:03
` focus on this language. 09:46:06
` MR. FLETCHER: Objection. 09:46:08
` Mr. Kiklis, the magnifying glass is 09:46:08
` sitting next to you. 09:46:09
` MR. KIKLIS: He's got two in front 09:46:12
` of him. 09:46:13
` MR. FLETCHER: The two we gave him. 09:46:14
` MR. KIKLIS: Oh, my God. 09:46:16
`
`Page 299
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` J. Cole
` could be mistaken that it's not there, but my 09:47:36
` recollection is that this is the only place 09:47:40
` that mentions that, or -- or possibly mentions 09:47:42
` it in the preferred embodiment or something. 09:47:45
` But I'll -- I'll pursue that just to be sure 09:47:48
` I'm telling the truth here. 09:47:53
` Q. So, sir -- 09:48:06
` MR. FLETCHER: Objection. He's not 09:48:08
` finished, Mr. Kiklis. He just told you 09:48:09
` he's -- 09:48:10
` MR. KIKLIS: Stop the -- 09:48:10
` MR. FLETCHER: -- looking to -- 09:48:11
` MR. KIKLIS: -- speaking 09:48:11
` objections. 09:48:11
` MR. FLETCHER: -- complete his 09:48:12
` answer. 09:48:12
` MR. KIKLIS: Stop the speaking 09:48:13
` objections. One-word objections. 09:48:14
` MR. FLETCHER: Are you finished? I 09:48:15
` just want to say -- 09:48:15
` MR. KIKLIS: One-word objections. 09:48:16
` I've warned you several times. 09:48:17
` MR. FLETCHER: I'm -- 09:48:18
` MR. KIKLIS: I'm getting sick of 09:48:19
`
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`TSG Reporting - Worldwide 877-702-9580
`
`6
`
`WESTERNGECO Exhibit 2045, pg. 6
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
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` J. Cole
` it. 09:48:20
` MR. FLETCHER: I'm happy to call 09:48:20
` the Board about this, because -- 09:48:21
` MR. KIKLIS: No. 09:48:22
` MR. FLETCHER: -- I am well within 09:48:23
` my rights. 09:48:23
` MR. KIKLIS: Stop it. 09:48:24
` MR. FLETCHER: The Trial Practice 09:48:24
` Guide says I can object to the conduct 09:48:25
` of any party. You are interrupting 09:48:27
` Mr. Cole. He's trying to answer your 09:48:28
` question. 09:48:31
` MR. KIKLIS: Stop it. 09:48:31
` MR. FLETCHER: You've asked him 09:48:31
` to -- 09:48:31
` MR. KIKLIS: Stop your speaking 09:48:32
` objections. 09:48:33
` (Simultaneous speaking.) 09:48:33
` MR. FLETCHER: It's not a speaking 09:48:33
` objection. 09:48:33
` MR. KIKLIS: Stop it. Yes, 09:48:34
` you're -- you're sitting here lecturing 09:48:35
` me. Stop it. 09:48:36
` MR. FLETCHER: I'm just -- 09:48:38
`
`Page 302
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` J. Cole
` I read it as best as I could under 09:50:46
` the duress, because you were concerned I was 09:50:49
` taking too much time and so on the basis of 09:50:52
` that, that's the only place I see those words. 09:50:57
` Q. My question, sir, wasn't whether this 09:50:59
` was the only place that this appeared in the 09:51:01
` document. 09:51:04
` My question was that at lines 11 09:51:05
` through 14, the patent states: "To compensate 09:51:10
` for these localized current fluctuations, the 09:51:14
` inventive control system utilizes a distributed 09:51:16
` processing control architecture and 09:51:20
` behavior-predictive model-based control logic 09:51:23
` to properly control the streamer positioning 09:51:26
` devices." 09:51:29
` Did I read that correctly? 09:51:29
` A. You're a good reader, sir. I think 09:51:31
` that's verbatim. 09:51:33
` Q. So my question is, is it your 09:51:34
` understanding that the '607 patent describes a 09:51:37
` system that utilizes behavior-predictive 09:51:40
` model-based control logic? 09:51:44
` MR. FLETCHER: Objection. 09:51:46
` A. The answer is no. 09:51:49
`
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