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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`PETROLEUM GEO-SERVICES INC.
`
`Petitioner,
`
`
`
`v.
`
`WESTERNGECO L.L.C.
`
`Patent Owner.
`
`____________
`
`Case IPR2014-01478
`
`U.S. Patent No. 7,293,520
`
`____________
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`

`
`Patent Owner’s Request for Oral Argument
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
`
`Pursuant to the Board’s March 17, 2015 Scheduling Order (Paper 19) and
`
`the parties’ Joint Notice of Stipulation Concerning Scheduling and Discovery
`
`(Paper 30), Patent Owner WesternGeco L.L.C. respectfully requests oral argument,
`
`currently scheduled on November 12, 2015. Patent Owner requests that argument
`
`in IPR2014-01478 be consolidated with argument in IPR2014-01475 and
`
`IPR2014-01477 and requests that each party receives two hours to present its
`
`arguments, with the two hours to be allocated amongst the three cases as each party
`
`sees fit. Pursuant to 37 C.F.R. § 42.70, Patent Owner specifies the following
`
`issues to be argued:
`
`1. Claims 3, 5, 20, and 22 are not rendered obvious by Workman;
`
`2. Claims 13, 14, 30, and 31 are not anticipated by Workman;
`
`3. Claims 13, 14, 30, and 31 are not rendered obvious by Workman;
`
`4. Claims 15-17 and 32-34 are not rendered obvious by Workman and
`
`Dolengowski;
`
`5. Construction of claims 1, 3, 5, 13-18, 20, 22, and 30-34;
`
`6. Secondary considerations of non-obviousness;
`
`7. Petitioner’s identification of Real Parties in Interest;
`
`8. Whether Petitioner is in privity with Ion Geophysical Corporation and
`
`ION International S.A.R.L.;
`
`
`
`
`
`2
`
`

`
`Patent Owner’s Request for Oral Argument
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
`
`9. Whether the petition is time-barred under 35 U.S.C. § 315(b); and
`
`10. Whether Patent Owner has been afforded due process in this proceeding.
`
`In the event any fees are required for this Request, please charge Deposit
`
`Respectfully submitted,
`
`Oblon, McClelland, Maier &
`Neustadt, LLP
`
`
`
`
`
`/Michael L. Kiklis/
`Michael L. Kiklis (Reg. No. 38,939)
`
`
`
`
`
`
`
`
`
`
`
`
`
`Account No. 15-0030.
`
`
`
`
`
`
`
`
`
`
`
`
`
`Dated: October 14, 2015
`
`
`
`
`
`
`
`
`Customer Number
` 22850
`Tel. (703) 413-3000
`Fax. (703) 413-2220
`
`
`
`
`
`
`
`3
`
`

`
`Patent Owner’s Request for Oral Argument
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
`
`CERTIFICATE OF SERVICE
`
`
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies service of
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT on the counsel of
`
`record for the Petitioner by filing this document through the Patent Review
`
`Processing System as well as delivering a copy via electronic mail to the following
`
`addresses:
`
`David Berl
`dberl@wc.com
`
`Jessamyn Berniker
`jberniker@wc.com
`
`Thomas S. Fletcher
`tfletcher@wc.com
`
`Christopher Suarez
`csuarez@wc.com
`
`
`
`
`
`
`
`
`/Michael L. Kiklis/
`Michael L. Kiklis (Reg. No. 38,939)
`
`
`
`
`
`4
`
`
`
`Dated: October 14, 2015

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