UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————————
`
`PETROLEUM GEO-SERVICES INC.,
`Petitioner
`
`v.
`
`WESTERNGECO LLC
`Patent Owner
`
`———————————
`
`Cases
`IPR2014-01475 (U.S. Patent No. 7,162,967)
`IPR2014-01477 (U.S. Patent No. 7,080,607)
`IPR2014-01478 (U.S. Patent No. 7,293,520)
`———————————
`
`DECLARATION OF MICHAEL S. TRIANTAFYLLOU
`
`
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`WESTERNGECO Exhibit 2075, pg. 1
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

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`
`
`I.
`
`II.
`
`III.
`
`IV.
`
`V.
`
`VI.
`
`Table of Contents
`
`Introduction ........................................................................................................................4
`
`Legal Standards .................................................................................................................8
`A.
`Claim Construction ..................................................................................................8
`B.
`Anticipation..............................................................................................................8
`C.
`Obviousness .............................................................................................................9
`D.
`Person of Ordinary Skill in the Art ..........................................................................9
`
`Summary of Opinions ......................................................................................................10
`A.
`Summary of Opinions Regarding the ’967 Patent .................................................17
`B.
`Summary of Opinions Regarding the ’607 Patent .................................................18
`C.
`Summary of Opinions Regarding the ’520 Patent .................................................18
`
`Background of the Technology .......................................................................................18
`A.
`Background Technical Principles ..........................................................................18
`B.
`Dr. Bittleston and Mr. Hillesund’s Work...............................................................33
`C.
`The Patents At Issue...............................................................................................35
`1.
`’967 Patent .................................................................................................36
`2.
`’607 Patent .................................................................................................40
`Behavior/Hydrodynamics-based models versus ad-
`a.
`hoc/empirical models .....................................................................43
`’520 Patent .................................................................................................44
`
`3.
`
`Claim Construction ..........................................................................................................47
`A.
`“Streamer Positioning Device” ..............................................................................47
`B.
`“Global Control System” .......................................................................................48
`C.
`“Predicting Positions” ............................................................................................49
`D.
`“Calculate Desired Changes” .................................................................................50
`E.
`“Streamer Separation Mode” .................................................................................51
`F.
`“Feather Angle Mode” ...........................................................................................52
`
`The Alleged Prior Art ......................................................................................................53
`A.
`’636 PCT ................................................................................................................53
`B.
`Gikas ......................................................................................................................55
`Controller and Kalman Filter Design Using Streamer
`a.
`Hydrodynamic Models ...................................................................57
`Spink ......................................................................................................................59
`’394 PCT ................................................................................................................61
`Workman................................................................................................................62
`Dolengowski ..........................................................................................................67
`
`C.
`D.
`E.
`F.
`
`VII. WesternGeco’s Patents Are Not Anticipated or Obvious ............................................69
`A.
`The ’967 Patent ......................................................................................................69
`
`
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`WESTERNGECO Exhibit 2075, pg. 2
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`B.
`
`C.
`
`3.
`
`4.
`
`General Discussion of Claim 1 ..................................................................69
`1.
`Claim 4 Is Not Anticipated or Rendered Obvious by the ’636 PCT .........72
`2.
`The ’607 Patent ......................................................................................................72
`1.
`General Discussion of Claim 15 ................................................................73
`2.
`Claims 16 and 17 Are Not Obvious Due to the ‘636 PCT and
`Gikas ..........................................................................................................81
`Claims 18-20 Are Not Rendered Obvious Over the ‘636 PCT,
`Gikas, and Spink ........................................................................................81
`a.
`Claim 18 .........................................................................................81
`b.
`Claim 19 .........................................................................................82
`c.
`Claim 20 .........................................................................................83
`Claims 21-23 Are Not Rendered Obvious Over the ‘636 PCT,
`Gikas, Spink, and the ‘394 PCT.................................................................83
`a.
`Claim 21 .........................................................................................83
`b.
`Claim 22 .........................................................................................84
`c.
`Claim 23 .........................................................................................85
`The ’520 Patent ......................................................................................................85
`1.
`General Discussion of Claims 1 and 18 .....................................................85
`a.
`Workman Does Not Enable a Streamer Positioning Device .........86
`b.
`Workman Does Not Disclose Model-Based Control .....................90
`c.
`Importance of Control Modes ........................................................90
`Claims 3, 5, 20, and 22 Are Not Obvious Over Workman ........................97
`a.
`Claims 3 and 20 Are Not Obvious Over Workman ........................97
`b.
`Feather Angle Versus The Feather Angle Mode ............................98
`c.
`Claims 5 and 22 Are Not Obvious Over Workman ......................100
`Claims 13, 14, 30, and 31 Are Not Anticipated by or Obvious Over
`Workman..................................................................................................100
`Claims 13 and 30 Are Not Anticipated by or Obvious Over
`a.
`Workman ......................................................................................100
`Claims 14 and 31 Are Not Anticipated by or Obvious Over
`Workman ......................................................................................101
`Claims 15-17 and 32-34 Are Not Obvious Over Workman and
`Dolengowski ............................................................................................105
`
`2.
`
`3.
`
`4.
`
`b.
`
`VIII. Conclusion ......................................................................................................................107
`
`
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`3
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`WESTERNGECO Exhibit 2075, pg. 3
`PGS v. WESTERNGECO
`IPR2014-01478
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`I, Dr. Michael S. Triantafyllou, hereby state the following:
`
`I.
`
`INTRODUCTION
`
`1. I have over 40 years of research and development experience in the dynamics and control of
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`marine vehicles and structures. I specialize in two fields: (1) control theory; and (2) the
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`interactions between fluids and structures, including fluid mechanics and structural
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`dynamics. A copy of my curriculum vitae, including a list of the publications I have
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`authored within the last 10 years, is attached hereto as Exhibit A. I have provided testimony
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`at a deposition and at trial in the past 4 years. These engagements are listed in Exhibit B. I
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`am being compensated at a rate of $350 per hour for the time I devote to this matter. I have
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`no financial interest in the outcome of this litigation. The information I considered in
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`forming my opinions is attached hereto as Exhibit C.
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`2. I earned a bachelor’s degree in Naval Architecture and Marine Engineering in 1974 from the
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`National Technical University of Athens in Athens, Greece. I have also earned the degrees
`
`of Masters of Science in Mechanical Engineering, and Masters of Science in Ocean
`
`Engineering, both awarded in 1977 from the Massachusetts Institute of Technology (“MIT”).
`
`In 1979, I earned a Doctorate of Science in Ocean Engineering from MIT. During the course
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`of my doctorate studies, I conducted research on the dynamics and control of ships and
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`positioning structures for the oil industry.
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`3. Since 1979, I have been a faculty member first in MIT’s Ocean Engineering department and
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`then in MIT’s Mechanical Engineering department. I was an Assistant Professor from 1979
`
`to 1983, and Associate Professor without tenure from 1983 to 1986. Much of my research
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`during this time focused on cable mechanics, and specifically on the design of marine cable
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`WESTERNGECO Exhibit 2075, pg. 4
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`lines subject to large forces, such as ocean currents. Many of the principles of cable
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`mechanics are equally applicable to streamers used in marine seismic surveys. In addition to
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`my research, I taught courses in the design of floating structures and the dynamics of ocean
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`structures.
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`4. I earned permanent tenure status in 1986. I continued my research on cable mechanics,
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`focusing specifically on towed cables, including streamers and towed arrays. In conjunction
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`with the United States Navy, I studied the fluid mechanics of towed arrays for use behind
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`submarines for the detection of other vessels. Though the precise nature of my work for the
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`Navy remains confidential, it involved the development of the boundary layer theory around
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`towed cables, as well as their hydrodynamics and maneuverability.
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`5. In 1990, I earned the title of Professor. I continued to work on the development of cables and
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`towed arrays for the United States Navy, specifically focusing on conducting modeling
`
`studies for the hydrodynamics of marine cables.
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`6. Since 2004, I have served as the Director of the Center for Ocean Engineering at MIT. In
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`2008, I was named Associate Department Head of the Mechanical Engineering Department,
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`and I currently serve as the William I. Koch Chair in Marine Technology. During 2007-
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`2014, I conducted research focused on developing steering capabilities for the Navy’s
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`acoustic towed arrays. The technology is similar to the steerable streamer concepts
`
`employed by the oil exploration industry. Part of my research focused on simulating the
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`overall performance of underwater arrays towed by helicopter at high speed for underwater
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`detection. Arrays towed by helicopter present many of the same challenges as arrays towed
`
`by marine seismic vessels, but also present many additional challenges. For example,
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`
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`5
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`WESTERNGECO Exhibit 2075, pg. 5
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`helicopters tow arrays at much faster speeds, up to twenty miles per hour, than seismic
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`vessels, adding to the complexity of the system.
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`7. In 2013, I became Chairman of the Board of the National Technical University of Athens.
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`8. For approximately twenty years, my research at MIT has also included the development of
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`marine robots with flexible hulls that propel themselves through water, or “swim,” much like
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`fish. In its initial stages, the project involved the design and control of robot bodies that
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`swim like marine creatures, such as dolphins and tuna. These robots are capable of sensing
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`their surrounding environmental conditions in order to achieve optimal propulsion and
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`maneuverability. The robots are capable of adjusting their motion to account for ocean
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`currents and turbulence from structures in the water. They can be controlled remotely, but
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`are also capable of autonomous control. More recently, my research efforts have been
`
`focused on the development of specialized pressure and velocity sensors distributed
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`throughout the robot bodies, which allow the robots to detect flow patterns and other objects
`
`in the water. This research has been featured several times in industry and academic
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`publications, including Physics of Fluids, Discovery Magazine, and The Scientific American.
`
`Ultimately, the practical application of this project will be to apply these principles to larger
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`marine vessels for faster turning and more precise control of, for example, marine cables. In
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`2014 I was elected fellow of the American Physical Society for “pioneering the use of
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`biomimetic robots.”
`
`9. In addition to my responsibilities at MIT, since 1979 I have been a visiting research scientist
`
`at the Woods Hole Oceanographic Institute (“WHOI”) in Woods Hole, Massachusetts.
`
`WHOI is one of the world’s largest ocean research and engineering organizations. Its work
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`
`
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`6
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`WESTERNGECO Exhibit 2075, pg. 6
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`focuses on all aspects of ocean research, including the development of technology for natural
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`resource exploration beneath the ocean subsurface. As part of my research at WHOI, I was
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`part of the team that developed the WHOI-Cable, a simulation program that simulates the
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`fluid mechanics and dynamics for moorings and towed marine cables and arrays.
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`10. I routinely consult on issues related to marine exploration for the petroleum industry,
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`including projects on behalf of ExxonMobil, Mobil, Conoco Philips, Chevron, and Technip.
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`I am also a frequent presenter at several professional society conventions, including the
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`International Society of Offshore Mechanics and Polar Engineers and the Society of Naval
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`Architects and Naval Engineers. My research has been published in a variety of industry and
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`scientific journals, including the Journal of Fluid Mechanics and the Journal of Fluids and
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`Structures.
`
`11. In my career I was involved in the design and implementation of advanced filtering and
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`control systems. My doctoral thesis (1976-1979) was on the dynamic positioning control
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`system used for ships drilling for oil and gas (funded by NSF). From 1979 through 1984 I
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`studied the problem of landing VTOL aircraft on smaller Navy ships using Kalman filtering
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`techniques to estimate and predict ship motions (funded by NASA). In 1986 through 1991 I
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`studied with a colleague at WHOI the dynamic positioning for ships that tow remotely
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`operated vehicles such as the ARGO and JASON vehicles of WHOI (funded by the Navy).
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`From 1991 through 1999 I directed the effort for designing the control systems for the
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`laboratory robot RoboTuna and the autonomous robot RoboPike (funded by ONR, DARPA,
`
`and NOAA). From 1996 through 2006 I directed the development of hybrid control systems
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`that combine in real time simulation and experimentation, a methodology that is now used by
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`several groups worldwide (funded by ONR). From 2000 through 2006 I directed the
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`7
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`WESTERNGECO Exhibit 2075, pg. 7
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`development of the autonomous robot RoboTurtle (funded by DARPA-CEROS and NOAA).
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`Since 2007, I have been involved with the development of pressure sensor arrays for real
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`time estimation of the flow around moving robots and structures, as well as with the design
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`of advanced biomimetic robots.
`
`II.
`
`LEGAL STANDARDS
`
`A.
`
`Claim Construction
`
`12. I understand that in an inter partes review proceeding, the terms in the claims of the patent
`
`are given their broadest reasonable interpretation in light of the specification, as understood
`
`by one having ordinary skill in the relevant art as of the priority date of the patent at issue. I
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`have been informed that the priority date of the patents at issue is October 1, 1998.1
`
`B.
`
`Anticipation
`
`13. I understand that a claim is unpatentable if it is anticipated. Anticipation of a claim requires
`
`that every element of a claim be disclosed expressly or inherently in a single prior art
`
`reference, arranged in the prior reference as arranged in the claim. I understand that for a
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`feature to be “inherent” in a reference, the feature must necessarily be present based on the
`
`details that are disclosed. I also understand that in order to anticipate, a reference must
`
`enable one of skill in the art to practice an embodiment of the claimed invention without
`
`undue experimentation.
`
`
`1 My opinions would not change if the U.S. PCT filing date of September 28, 1999 were used
`as the priority date.
`
`
`
`
`8
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`WESTERNGECO Exhibit 2075, pg. 8
`PGS v. WESTERNGECO
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`
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`C.
`
`Obviousness
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`14. I understand that a claim is unpatentable if it is obvious. Obviousness of a claim requires that
`
`the claim would have been obvious from the perspective of a person having ordinary skill in
`
`the relevant art at the time the invention was made. I understand that a claim may be obvious
`
`from a combination of two or more prior art references.
`
`15. I understand that an obviousness analysis requires an understanding of the scope and content
`
`of the prior art, any differences between the claims of the patent in question and the prior art,
`
`and the level of ordinary skill in the pertinent art.
`
`16. I also understand that objective evidence of nonobviousness should be considered when
`
`evaluating the obviousness of a claim. I understand that this objective evidence may include
`
`the commercial success of the patented invention, any long-felt but unsolved need in the art
`
`that was satisfied by the invention, the failure of others to make the invention, skepticism of
`
`those having ordinary skill in the art at the time of the invention, unexpected results of the
`
`invention, praise of the invention by those having ordinary skill in the art, and copying of the
`
`invention by others in the field.
`
`D.
`
`Person of Ordinary Skill in the Art
`
`17. I understand that a person of ordinary skill in the art (“POSA”) is a hypothetical person that
`
`is presumed to have the level of skill of a typical practitioner of the art at issue and is also
`
`presumed to be aware of all relevant prior art. I also understand that multiple factors are
`
`relevant in determining the level of ordinary skill in the art including, among other things, the
`
`
`
`
`9
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`WESTERNGECO Exhibit 2075, pg. 9
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`educational level of the inventor, the sophistication of the technology, the type of problems
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`encountered in the art, and prior art solutions to those problems.
`
`18. Based on my consideration of those factors and my own experience in the field, it is my
`
`opinion that one of ordinary skill in the art at the time of the ’520 patent, ’607 patent, and
`
`’967 patent would have a Bachelor of Science in ocean engineering or control systems; or
`
`five years of experience in the field of ocean engineering or marine seismic surveys.
`
`III.
`
`SUMMARY OF OPINIONS
`
`19. I have been asked to give an opinion on whether certain claims of the ’520 patent (Ex.
`
`1001.), ’607 patent (Ex. 2076.), and the ’967 (Ex. 2077.) patent are anticipated or obvious
`
`based on certain references. This section contains a summary of my opinions in this matter,
`
`which I explain in further detail below.
`
`20. I have included a table below listing the patents and claims I was asked to consider:
`
`WesternGeco’s Patents At Issue
`
`Patent Number
`
`Claims at Issue
`
`U.S. Pat. No. 7,080,607
`(the ’607 patent)
`
`15. An array of seismic streamers towed by a towing vessel
`comprising:
`(a) a plurality of streamer positioning devices on or inline with each
`streamer;
`(b) a prediction unit adapted to predict positions of at least some of the
`streamer positioning devices; and
`(c) a control unit adapted to use the predicted positions to calculate
`desired changes in positions of one or more of the streamer
`positioning devices.
`
`16. Apparatus as claimed in claim 15, in which each streamer
`
`
`
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`10
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`WESTERNGECO Exhibit 2075, pg. 10
`PGS v. WESTERNGECO
`IPR2014-01478
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`WesternGeco’s Patents At Issue
`
`Patent Number
`
`Claims at Issue
`
`positioning device has a first hydrodynamic deflecting surface and a
`second hydrodynamic deflecting surface, said first deflecting surface
`and said second deflecting surface being independently moveable to
`steer the streamer positioning device laterally and vertically.
`
`17. Apparatus as claimed in claim 16, wherein each streamer
`positioning device is rigidly attached to and unable to rotate with
`respect to its streamer.
`
`18. Apparatus as claimed in claim 17, further including means for
`determining the angular velocity of each streamer positioning device.
`
`19. Apparatus as claimed in claim 18, wherein a global control
`system is located on or near said seismic vessel and a respective local
`control system is located within or near each streamer positioning
`device and said global control system and said local control systems
`communicate using a respective communication line passing through
`each streamer.
`
`20. Apparatus as claimed in claim 19, in which input values for said
`local control systems are downloaded over said communication lines.
`
`21. Apparatus as claimed in claim 20, further including a respective
`backup communications channel in each streamer between the global
`control system and the local control systems of the streamer
`positioning devices of the streamer.
`
`22. Apparatus as claimed in claim 21, in which each local control
`system has a cycle rate that is at least 10 times greater than the data
`transfer rate of said communication line.
`
`23. Apparatus as claimed in claim 22, in which each local control
`system comprises a microprocessor programmed to monitor the
`current orientation of the wing of its streamer positioning device and
`to calculate desired changes to the orientation of said wing based on
`
`11
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`WESTERNGECO Exhibit 2075, pg. 11
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`IPR2014-01478
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`WesternGeco’s Patents At Issue
`
`Patent Number
`
`Claims at Issue
`
`inputs from said global control system.
`
`U.S. Pat. No. 7,162,967
`(the ’967 patent)
`
`U.S. Pat. No. 7,293,520
`(the ’520 patent)
`
`1. A method comprising:
`(a) towing an array of streamers each having a plurality of streamer
`positioning devices there along, at least one of the streamer
`positioning devices having a wing;
`(b) transmitting from a global control system location information to
`at least one local control system on the at least one streamer
`positioning devices having a wing; and
`(c) adjusting the wing using the local control system.
`
`4. The method as claimed in claim 1, wherein the global control
`system transmits a desired vertical depth for the at least one streamer
`positioning device and the local control system calculates magnitude
`and direction of the deviation between the desired vertical depth and
`actual depth.
`
`1. A method comprising:
`(a) towing an array of streamers each having a plurality of streamer
`positioning devices there along contributing to steering the streamers;
`(b) controlling the streamer positioning devices with a control system
`configured to operate in one or more control modes selected from a
`feather angle mode, a turn control mode, and a streamer separation
`mode.
`
`2. The method of claim 1 wherein the control mode is the feather
`angle mode, and the controlling comprises the control system
`attempting to keep each streamer in a straight line offset from a
`towing direction by a feather angle.
`
`3. The method of claim 2 comprising inputting the feather angle
`manually.
`
`5. The method of claim 2 comprising setting the feather angle to zero
`when crosscurrent velocity is very small and desired streamer
`
`
`
`
`12
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`WESTERNGECO Exhibit 2075, pg. 12
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`WesternGeco’s Patents At Issue
`
`Patent Number
`
`Claims at Issue
`
`positions are in alignment with the towing direction.
`
`13. The method of claim 1 wherein the control mode is the streamer
`separation mode, the control system attempting to minimize the risk of
`entanglement of the streamers.
`
`14. The method of claim 13 comprising the control system attempting
`to maximize distance between adjacent streamers.
`
`15. The method of claim 13 comprising separating the streamers in
`depth.
`
`16. The method of claim 15 wherein the array of streamers comprises
`two streamers, and comprising positioning the two streamers as far
`away from each other as possible.
`
`17. The method of claim 15 wherein the array of streamers comprises
`three or more streamers, the array comprising one port-most streamer,
`one starboard-most streamer and at least one inner streamer and
`comprising positioning the port-most and starboard-most streamers as
`far away form [sic] each other as possible.
`
`18. An apparatus comprising:
`(a) an array of streamers each having a plurality of streamer
`positioning devices there along;
`(b) a control system configured to use a control mode selected from a
`feather angle mode, a turn control mode, a streamer separation mode,
`and two or more of these modes.
`
`19. The apparatus of claim 18 wherein the control mode is the feather
`angle mode, and the controlling comprises the control system
`attempting to keep each streamer in a straight line offset from a
`towing direction by a feather angle.
`
`20. The apparatus of claim 19 comprising inputting the feather angle
`
`13
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`WESTERNGECO Exhibit 2075, pg. 13
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`IPR2014-01478
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`
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`WesternGeco’s Patents At Issue
`
`Patent Number
`
`Claims at Issue
`
`manually.
`
`22. The apparatus of claim 19 comprising setting the feather angle to
`zero when crosscurrent velocity is very small and desired streamer
`positions are in alignment with the towing direction.
`
`30. The apparatus of claim 18 wherein the control mode is the
`streamer separation mode, the control system attempting to minimize
`the risk of entanglement of the streamers.
`
`31. The apparatus of claim 30 comprising the control system
`attempting to maximize distance between adjacent streamers.
`
`32. The apparatus of claim 30 comprising separating the streamers in
`depth.
`
`33. The apparatus of claim 32 wherein the array of streamers
`comprises two streamers, and comprising positioning the two
`streamers as far away from each other as possible.
`
`34. The apparatus of claim 32 wherein the array of streamers
`comprises three or more streamers, the array comprising one port-
`most streamer, one starboard-most streamer and at least one inner
`streamer and comprising positioning the port-most and starboard-most
`streamers as far away from each other as possible.
`
`21. The following table lists the references the Board granted institution on:
`
`
`
`
`
`
`
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`14
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`WESTERNGECO Exhibit 2075, pg. 14
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`
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`Alleged Prior Art
`
`Reference Title
`
`Exemplary Figure
`
`Application
`International
`WO 98/28636 PCT
`(the ’636 PCT)
`
`Inventor:
`Simon Bittleston
`
`Title:
`for
`Devices
`Control
`Controlling the Position of a
`Marine Seismic Streamer
`
`Title:
`A Rigorous and Integrated
`Approach
`to Hydrophone
`and
`Source
`Positioning
`During
`Multi-Streamer
`Offshore
`Seismic
`Exploration
`
`Authors:
`V. Gikas, P.A. Cross, and A.
`Asiama-Akuamoa
`(the Gikas paper or Gikas)
`
`Source:
`77 Hydrographic J. 11, 12
`(1995)
`
`
`
`
`15
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`WESTERNGECO Exhibit 2075, pg. 15
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`
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`Alleged Prior Art
`
`Reference Title
`
`Exemplary Figure
`
`U.S. Pat. No. 3,560,912
`
`Inventors:
`Paul G. Spink, Severna
`Park, and James T. Malone
`(the Spink patent
`or
`Spink)
`
`Title:
`Control System for a Towed
`Vehicle
`
`International Application
`WO 97/11394 PCT
`(the ’394 PCT)
`
`Inventor:
`Robert E. Rouquette
`
`Title:
`Power
`Electrical
`and
`Distribution
`Communication System for
`an Underwater Cable
`
`
`
`
`16
`
`
`
`
`
`
`
`WESTERNGECO Exhibit 2075, pg. 16
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`
`
`Alleged Prior Art
`
`Reference Title
`
`Exemplary Figure
`
`U.S. Pat. No. 5,790,472
`
`Inventors:
`Ricky L. Workman and
`Ronald Edward Chambers
`(the Workman patent or
`Workman)
`
`Title:
`Adaptive Control of Marine
`Seismic Streamers
`
`U.S. Pat. No. 4,890,568
`
`Inventor:
`George A. Dolengowski
`(the Dolengowski patent or
`Dolengowski)
`
`Title:
`Steerable Tail Buoy
`
`A.
`
`Summary of Opinions Regarding the ’967 Patent
`
`22. Claim 4 of the ’967 patent is not anticipated by the ’636 PCT.
`
`
`
`
`17
`
`
`
`
`
`WESTERNGECO Exhibit 2075, pg. 17
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`
`
`23. Claim 4 of the ’967 patent is not obvious over the ’636 PCT.
`
`B.
`
`Summary of Opinions Regarding the ’607 Patent
`
`24. Claims 16 and 17 of the ’607 patent are not obvious over the ’636 PCT and Gikas.
`
`25. Claims 18-20 of the ’607 patent are not obvious over the ’636 PCT, Gikas, and Spink.
`
`26. Claims 21-23 of the ’607 patent are not obvious over ’636 PCT, Gikas, Spink, and the ’394
`
`PCT.
`
`C.
`
`Summary of Opinions Regarding the ’520 Patent
`
`27. Claims 3, 5, 20, and 22 of the ’520 patent are not obvious over Workman.
`
`28. Claims 13, 14, 30, and 31 of the ’520 patent are not anticipated by Workman.
`
`29. Claims 13, 14, 30, and 31 of the ’520 patent are not obvious over Workman.
`
`30. Claims 15-17 and 32-34 of the ’520 patent are not obvious over Workman and Dolengowski.
`
`IV.
`
`BACKGROUND OF THE TECHNOLOGY
`
`A.
`
`Background Technical Principles
`
`31. Marine seismic surveys use specialized equipment to discover oil and gas deposits below the
`
`bottom of the ocean. A seismic vessel typically tows a portion of this equipment through the
`
`water, and there is also equipment located on the seismic vessel itself. Devices in the water
`
`are usually called “wet” devices because they are in the water, while devices on the boat are
`
`typically called “dry” devices. A piece of equipment, usually called an “air gun,” is towed in
`
`
`
`
`18
`
`WESTERNGECO Exhibit 2075, pg. 18
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`
`
`the water behind the seismic vessel and causes a small, controlled explosion underwater.
`
`This explosion generates sound waves that travel through the water and penetrate the surface
`
`of the earth; the waves travel through the layers of the earth that lie beneath the ocean floor,
`
`each layer in a different way based on the geological formations found within the earth, and
`
`some of the energy is reflected at the interfaces between layers. Underwater sensors known
`
`as hydrophones pick up these reflections — many sensors are needed to measure the
`
`reflections at several locations, in order to be able to determine the shape of the earth layers
`
`that cause the reflections. Based on these reflected signals, special computer programs are
`
`used to reconstruct the shape of the earth layers based on the hydrophone measurements as
`
`well as to provide information regarding the contents of those layers to reveal whether oil or
`
`another natural resource is present. In order for the measurements to cover a large area, yet
`
`still be accurate, many hydrophones are towed behind the vessel and spread over a large area,
`
`like a large antenna. The hydrophones are contained inside several very long cables called
`
`streamers, which are typically several miles long, and are connected through wires to a
`
`computer system on the towing vessel.
`
`32. Environmental factors, such as current speed and direction, can significantly influence the
`
`path of the towed array. Currents often contain turbulent eddies and therefore exert a non-
`
`uniform force on the streamers. The irregular force of the current changes the shape of the
`
`highly flexible strea