`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF TEXAS
`HOUSTON DIVISION
`
`
`WESTERNGECO LLC, . 4:09-CV-01827
` . HOUSTON, TEXAS
`PLAINTIFF, .
` .
` vs. .
` .
`ION GEOPHYSICAL .
`CORPORATION, FUGRO GEOTEAM, .
`INC., ET AL, . VOLUME 11
` . AFTERNOON SESSION
`DEFENDANTS . AUGUST 7, 2012
`. . . . . . . . . . . . . . . 12:30 P.M.
`
`
`TRANSCRIPT OF JURY TRIAL
`BEFORE THE HONORABLE KEITH P. ELLISON
`UNITED STATES DISTRICT JUDGE
`
` A
`
`
`
`
`
` P P E A R A N C E S:
`
`FOR THE PLAINTIFF:
`
`Lee K. Kaplan
`SMYSER KAPLAN & VESELKA LLP
`Bank of America Center
`700 Louisiana, Suite 2300
`Houston, Texas 77002
`Gregg F. LoCascio
`KIRKLAND & ELLIS LLP
`655 Fifteenth Street Northwest
`Washington, DC 20005
`Sarah Tsou
`Timothy K. Gilman
`KIRKLAND & ELLIS LLP
`Citigroup Center
`153 East 53rd Street
`New York, New York 10022
`
`
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
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`WESTERNGECO Exhibit 2140, pg. 1
`PGS v. WESTERNGECO
`IPR2014-01478
`
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`12:57
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`12:58
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`12:58
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`12:58
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`12:58
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`12:59
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` 3636
`
` Gilman Cross of Charles Ledet
`
`That's the same thing as the APS system you were talking
`Q
`about earlier?
`A
`Yes. Those terms are used interchangeably.
`Q
`You see the third bullet point, cable steering, there?
`A
`Yes.
`Q
`That refers to lateral steering of the streamers, correct?
`A
`That's correct.
`Q
`We see further down towards the bottom, the presentation
`states that PGS positioning system requirements were driven by
`Q system features, right?
`A
`PGS wanted a competitive solution to the Q system, yes.
`Q
`Q-Marine was already out in the market with a steerable
`streamer system at this time?
`A
`I believe that is the case, yes.
`Q
`And your customer came to you and said, We want a competing
`system for Q Marine?
`A
`Yes. We were seen as the positioning system experts. We
`were in the best position to develop a competing offering.
`Q
`If we turn back to the page 14 in this exhibit, 934, here
`is another slide on the next-generation positioning system.
`And then there's a project description, there is a question of
`why, and the answer is: Answer to Q positioning system, right?
`A
`Yes. That was, you know, a competitive offering to Q, yes.
`Q
`We see some of the benefits that we all agree on come from
`streamer steering?
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
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`WESTERNGECO Exhibit 2140, pg. 2
`PGS v. WESTERNGECO
`IPR2014-01478
`
`
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`12:59
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`12:59
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`13:00
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`13:00
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`13:01
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` 3637
`
` Gilman Cross of Charles Ledet
`
`Yes. And those are the exact same benefits that we
`A
`identified early on in the '90s, yes.
`Q
`And this next-generation positioning system was a concerted
`effort by ION to match the features that WesternGeco had with
`Q?
`It was to develop a competitive offering. The Q-Marine
`A
`system had several features that were not intended to be
`offered in our system. Cable steering was one of them, and we
`felt like we had an approach that was better than what was
`incorporated in the Q-Marine system.
`Q
`You wanted to be able to offer your customers something
`that would compete with Q's streamer steering?
`A
`Our customers were asking us for that and that was our
`business, to provide positioning devices and controllers to
`control streamers. So we usually did what our customers asked
`us to do.
`Q
`And ION did not have streamer steering capabilities at the
`time?
`A
`We did not have a commercialized offering at the time.
`Q
`I would like to take a look at how our customers were
`viewing the Q streamer steering system at the time. I will
`show you an email you received in 2004, which is ION
`Exhibit 303.
`We see at the top this is an email from Dave
`Ridyard to yourself in 2004?
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
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`WESTERNGECO Exhibit 2140, pg. 3
`PGS v. WESTERNGECO
`IPR2014-01478
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