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`'6
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`3-:
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`14 AP :
`
`15
`
`FOR THE PLAINTIFF:
`16 Lee L. Kaplan
`SJYSER,
`IGAPLAN & VESELKA, LLP
`17 700 Louisiana, Suite 2300
`Houston, Texas 77002
`18 713.221.2300
`
`19
`
`Gregg F. LoCasCio
`20 HRKIAND & ELLIS LLP
`
`655 Fifteenth Street Northwest
`21 Washington, DC 20005
`202.879.5290
`
`22
`
`Sarah Tsou
`23 Timothy K. Gihnan
`KIRKLAND & ELLIS LLP
`24 Citigroup Center
`153 East 53rd Street
`25 New York, New York 10022
`212.446.6435
`
`Johnny C. Sanchez, RMR, CRR — jcscourtreporter@aol.com
`
`‘
`
`3
`
`WESTERNGECO Exhibit 2156, pg. 1
`PGS V. WESTERNGECO
`IPR2014-01478
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT or TEXAS
`
`HOUSTON DIVISION
`
`09—CV—1827
`
`Houston, Texas
`
`7:49 a.m.
`August 2, 2012
`
`*
`
`*
`
`*-
`
`k
`
`*
`*
`*
`
`WESTERNGECO LLC
`
`5 VS.
`
`ION GEOPHYSICAL
`CORPORATION, FUGRO
`GEOTEAM,
`INC., ET AL
`
`JURY TRIAL
`
`Volume 9
`
`Morning Session
`
`BEFORE THE HONORABLE KEITH P. ELLISON
`UNITED STATES DISTRICT JUDGE
`
`1
`
`2
`
`3 4
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`WESTERNGECO Exhibit 2156, pg. 1
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`Direct—Moffat/By Mr. Wade
`
`2842
`
`technology on 2D vessels.
`
`Q.
`
`A.
`
`Give us an example.
`
`2D vessels we tend to use for exploration. One of
`
`the areas where exploration is big right now is the
`
`Arctic.
`
`So there's a lot of 2D vessels going into the
`
`Arctic,
`
`the single streamers, working in ice conditions.
`
`So we have a lot of specialized technology going in these
`
`vessels.
`
`1
`
`2 3 O
`
`D~JO\LN
`
`Q.
`
`How does your lateral steering assist in 2D surveys
`
`10:38:03
`
`10:38:16
`
`10
`
`in the Arctic?
`
`11
`
`12
`
`13
`
`A. Well,
`
`I think we heard previously that icebergs are a
`
`bit of a problem out there, and you know, having some
`
`ability to steer your streamer is very, very useful.
`
`14
`
`Q.
`
`Is that similar to the environment that Mr. Scoulios
`
`10:38:27
`
`15
`
`16
`
`17
`
`talked about at the beginning of his case when they did
`
`work on the OFFSHORE HORIZON where they had to snake a
`
`single streamer through all the equipment being used out
`
`18
`
`there in the Gulf?
`
`10:38:39
`
`19
`
`A.
`
`20
`
`Q.
`
`I guess you could say it's very similar.
`
`Let's take a look at an early business plan for the
`
`21
`
`22
`
`23
`
`24
`
`DigiFIN system.
`
`M. WADE:
`
`I'd like to look at Trial Exhibit ——
`
`Defendant's Trial Exhibit 125. Pull that up.
`
`And, Mr. Carlock, if you could bring up
`
`10:39:10
`
`25 the top portion of the document, expand a little bit.
`
`All
`
`Johnny C. Sanchez, RMR, CRR — jcscourtreporter@aol.com
`
`WESTERNGECO Exhibit 2156, pg. 2
`PGS V. WESTERNGECO
`IPR2014-01478
`
`WESTERNGECO Exhibit 2156, pg. 2
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`Direct—Moffat/By Mr. Wade
`
`2843
`
`1 right.
`
`2 BY MR. WADE:
`
`3 Q.
`
`Exhibit 125 is titled "Business Plan."
`
`See in the
`
`10:39:25
`
`4
`
`5
`
`left "Project DigiFIN. Originator: Clem Guillot.
`
`Who is Mr. Guillot?
`
`6 A.
`
`Clem is the product service line manager, for our
`
`7 positioning products.
`
`8 Q.
`
`Does he ultimately report to you?
`
`9 A.
`
`Yes, he does.
`
`10:39:33
`
`10 Q.
`
`All right. And you see on the left, "Input/Output
`
`11 Division, MISD."
`
`12
`
`Is that the marine imaging systems
`
`13 division?
`
`14 A.
`
`Yes, it is.
`
`10:39:41
`
`15 Q.
`
`And we have a date of 8-3-06?
`
`16
`
`A.
`
`Correct.
`
`17
`
`18
`
`19
`
`MR. WADE:
`
`Just to clarify a date issue, please
`
`turn to the next page, if you would, Mr. Carlock, and go to
`
`the upper right.
`
`10:39:55
`
`20
`
`BY MR. WADE:
`
`21
`
`Q.
`
`And we see in the upper right date, July 13,
`
`'06.
`
`22
`
`You see that?
`
`23
`
`A.
`
`Yes.
`
`24
`
`25
`
`10:40:08
`
`Q.
`
`All right.
`
`It's a little unclear what version of
`
`this document is.
`
`It's probably the August version.
`
`Johnny C. Sanchez, RMR, CRR — jcscourtreporter@aol.com
`
`WESTERNGECO Exhibit 2156, pg. 3
`PGS V. WESTERNGECO
`IPRZO14-01478
`
`WESTERNGECO Exhibit 2156, pg. 3
`PGS v. WESTERNGECO
`IPR2014-01478
`
`

`
`Direct~Moffa t/By Mr. Wade
`
`2844
`
`But do you know what a living document is?
`
`\J03LN¢>LUPOF4
`
`10:40:16
`
`A.
`
`Yes.
`
`Q. What's a living document?
`
`A. Well,
`
`these typical —— these business plans are not
`
`static documents. As we're developing the technology,
`
`the
`
`document gets upgraded when new information becomes
`
`available. We may have to change direction anytime. We
`
`may have new information.
`
`So we have to react to that, so
`
`9
`
`these are live documents.
`
`10:40:29
`
`10
`
`Q.
`
`Okay. But these two dates are prior to the
`
`ll
`
`introduction of DigiFIN to the market?
`
`12
`
`A.
`
`Yes.
`
`13
`
`Q.
`
`All right. Let's take a look at the first paragraph,
`
`10:40:41
`
`14
`
`15
`
`16
`
`the executive sumary.
`
`Look at your business plan for
`
`developing DigiFIN.
`
`M. WADE: Blow up the first paragraph,
`
`17
`
`Mr. Carlock.
`
`18
`
`BY MR. WADE:
`
`19
`
`Q.
`
`All right.
`
`Up in the first sentence, "DigiFIN
`
`10:40:50
`
`20
`
`21
`
`addresses the towed marine seismic data acquisition needs
`
`for lateral controller streamers on all existing marine
`
`22
`
`seismic streamers."
`
`23
`
`24
`
`25
`
`10:41:11
`
`And reading further right here, "DigiFIN
`
`has been well received by customers that have seen the
`
`presentation given after the Alpha test."
`
`Johnny C. Sanchez, RMR, CRR — jcscourtreporter@aol.com
`
`WESTERNGECO Exhibit 2156, pg. 4
`PGS V. WESTERNGECO
`IPRZO14-01478
`
`WESTERNGECO Exhibit 2156, pg. 4
`PGS v. WESTERNGECO
`IPR2014-01478

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