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UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________________
`
`PETROLEUM GEO-SERVICES INC.
`
`
`Petitioner,
`
`v.
`
`WESTERNGECO LLC
`
`Patent Owner.
`
`____________
`
`Case IPR2014-01478
`
`U.S. Patent No. 7,293,520
`____________
`
`PATENT OWNER’S UNOPPOSED MOTION TO SEAL UNDER
`37 C.F.R. §§ 42.14 AND 42.54
`
`
`
`
`

`
`Patent Owner’s Unopposed Motion to Seal
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
`
`Pursuant to 37 C.F.R. §§ 42.14 and 42.54, Patent Owner, WesternGeco
`
`L.L.C (“WesternGeco” or “Patent Owner”) files this Motion to seal certain exhibits
`
`submitted with Patent Owner’s Opposition to Petitioner Petroleum Geo-Services
`
`Inc.’s Motion to Exclude (“Patent Owner’s Opposition”) filed on October 28,
`
`2015.
`
`The following exhibits were filed under seal because they contain
`
`information designated as confidential by Patent Owner or ION Geophysical
`
`S.A.R.L. The below table lists those documents that the Patent Owner believes
`
`should remain under seal.
`
`I.
`
`Reasons for Sealing Certain Confidential Information
`A.
`Exhibits 2149-2152 and 2158-2160 were filed under seal. As set forth in
`
`Patent Owner Opposition Exhibits
`
`Table 1, below, good cause exists for maintaining these exhibits under seal. It is
`
`noted that each of these exhibits is identical to exhibits with the same number in
`
`related proceedings IPR2014-01475 and IPR2014-01477.
`
`Table 1: Exhibits to Patent Owner’s Opposition that Should
`Remain Under Seal
`
`
`Good Cause
`
`Exhibit
`
`Description
`
`2149
`
`Excerpt of Deposition
`
`This exhibit contains party
`
`
`
`2
`
`

`
`Exhibit
`
`Description
`
`Patent Owner’s Unopposed Motion to Seal
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
`
`Good Cause
`
`Transcript of Michael M.
`
`confidential information and is
`
`Burnham
`
`subject to a protective order in
`
`Excerpt of Deposition
`
`2150
`
`Transcript of Jeffrey Wayne
`
`Cunkelman
`
`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
`
`This exhibit contains party
`
`confidential information and is
`
`subject to a protective order in
`
`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
`
`This exhibit contains party
`
`confidential information and is
`
`2151
`
`Excerpt of Deposition
`
`subject to a protective order in
`
`Transcript of Hans Ivar Meyer
`
`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
`
`
`
`3
`
`

`
`Exhibit
`
`Description
`
`Excerpt of Deposition
`
`2152
`
`Transcript of Hans Christian
`
`Vaage
`
`Patent Owner’s Unopposed Motion to Seal
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
`
`Good Cause
`
`This exhibit contains party
`
`confidential information and is
`
`subject to a protective order in
`
`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
`
`This exhibit contains party
`
`confidential information and is
`
`2158
`
`Excerpt of Deposition
`
`subject to a protective order in
`
`Transcript of David Gentle
`
`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
`
`This exhibit contains party
`
`confidential information and is
`
`subject to a protective order in
`
`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`2159
`
`Excerpt of Deposition
`
`Transcript of David Moffat
`
`
`
`4
`
`

`
`Exhibit
`
`Description
`
`Patent Owner’s Unopposed Motion to Seal
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
`
`Good Cause
`
`Action No. 4:09-CV-01827.
`
`This exhibit contains party
`
`confidential information and is
`
`2160
`
`Excerpt of Deposition
`
`subject to a protective order in
`
`Transcript of Svein Dale
`
`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
`
`II. Certification of Non-Publication Status
`Patent Owner’s undersigned counsel certifies that the information sought to
`
`be sealed by this motion has not been published or otherwise made public to the
`
`best of his knowledge.
`
`III. Certification of Conference with Opposing Party Pursuant to 37 C.F.R.
`§ 42.54
`
`The parties have conferred regarding a protective order and have agreed to
`
`the protective order in this case, Ex. 2038. Also, Patent Owner has conferred with
`
`Petitioner about this motion, and Petitioner does not oppose it.
`
`
`
`5
`
`

`
`Patent Owner’s Unopposed Motion to Seal
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
`
`IV. Request For Relief
`Patent Owner requests that the following exhibits remain under seal:
`
`Respectfully submitted,
`Oblon, McClelland, Maier &
`Neustadt, LLP
`
`
`
`/Michael L. Kiklis/
`Michael L. Kiklis
`Registration No. 38,939
`
`Attorney for Patent Owner
`WESTERNGECO L.L.C.
`
`
`
`6
`
`2149-2152 and 2158-2160.
`
`
`
`
`Dated: October 28, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Customer Number
` 22850
`Tel. (703) 413-3000
`Fax. (703) 413-2220
`
`
`
`
`
`

`
`Patent Owner’s Unopposed Motion to Seal
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies service of PATENT OWNER’S
`
`UNOPPOSED MOTION TO SEAL UNDER 37 C.F.R. §§ 42.14 AND 42.54 on
`
`the counsel of record for the Petitioner by filing this document through the Patent
`
`Review Processing System as well as by 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
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Date: October 28, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Michael L. Kiklis/
`Michael L. Kiklis
`Registration No. 38,939
`
`Attorney for Patent Owner
`WESTERNGECO L.L.C.
`
`
`
`7

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