`________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_________________________
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`PETROLEUM GEO-SERVICES INC.
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`Petitioner,
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`v.
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`WESTERNGECO LLC
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`Patent Owner.
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`____________
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`Case IPR2014-01478
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`U.S. Patent No. 7,293,520
`____________
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`PATENT OWNER’S UNOPPOSED MOTION TO SEAL UNDER
`37 C.F.R. §§ 42.14 AND 42.54
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`Patent Owner’s Unopposed Motion to Seal
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
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`Pursuant to 37 C.F.R. §§ 42.14 and 42.54, Patent Owner, WesternGeco
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`L.L.C (“WesternGeco” or “Patent Owner”) files this Motion to seal certain exhibits
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`submitted with Patent Owner’s Opposition to Petitioner Petroleum Geo-Services
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`Inc.’s Motion to Exclude (“Patent Owner’s Opposition”) filed on October 28,
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`2015.
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`The following exhibits were filed under seal because they contain
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`information designated as confidential by Patent Owner or ION Geophysical
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`S.A.R.L. The below table lists those documents that the Patent Owner believes
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`should remain under seal.
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`I.
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`Reasons for Sealing Certain Confidential Information
`A.
`Exhibits 2149-2152 and 2158-2160 were filed under seal. As set forth in
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`Patent Owner Opposition Exhibits
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`Table 1, below, good cause exists for maintaining these exhibits under seal. It is
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`noted that each of these exhibits is identical to exhibits with the same number in
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`related proceedings IPR2014-01475 and IPR2014-01477.
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`Table 1: Exhibits to Patent Owner’s Opposition that Should
`Remain Under Seal
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`Good Cause
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`Exhibit
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`Description
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`2149
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`Excerpt of Deposition
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`This exhibit contains party
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`2
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`Exhibit
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`Description
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`Patent Owner’s Unopposed Motion to Seal
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
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`Good Cause
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`Transcript of Michael M.
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`confidential information and is
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`Burnham
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`subject to a protective order in
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`Excerpt of Deposition
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`2150
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`Transcript of Jeffrey Wayne
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`Cunkelman
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`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
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`This exhibit contains party
`
`confidential information and is
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`subject to a protective order in
`
`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
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`This exhibit contains party
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`confidential information and is
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`2151
`
`Excerpt of Deposition
`
`subject to a protective order in
`
`Transcript of Hans Ivar Meyer
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`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
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`
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`3
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`Exhibit
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`Description
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`Excerpt of Deposition
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`2152
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`Transcript of Hans Christian
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`Vaage
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`Patent Owner’s Unopposed Motion to Seal
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
`
`Good Cause
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`This exhibit contains party
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`confidential information and is
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`subject to a protective order in
`
`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
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`This exhibit contains party
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`confidential information and is
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`2158
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`Excerpt of Deposition
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`subject to a protective order in
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`Transcript of David Gentle
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`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
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`This exhibit contains party
`
`confidential information and is
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`subject to a protective order in
`
`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
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`2159
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`Excerpt of Deposition
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`Transcript of David Moffat
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`4
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`Exhibit
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`Description
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`Patent Owner’s Unopposed Motion to Seal
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
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`Good Cause
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`Action No. 4:09-CV-01827.
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`This exhibit contains party
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`confidential information and is
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`2160
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`Excerpt of Deposition
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`subject to a protective order in
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`Transcript of Svein Dale
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`WesternGeco L.L.C. v. ION
`
`Geophysical Corporation, Civil
`
`Action No. 4:09-CV-01827.
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`II. Certification of Non-Publication Status
`Patent Owner’s undersigned counsel certifies that the information sought to
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`be sealed by this motion has not been published or otherwise made public to the
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`best of his knowledge.
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`III. Certification of Conference with Opposing Party Pursuant to 37 C.F.R.
`§ 42.54
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`The parties have conferred regarding a protective order and have agreed to
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`the protective order in this case, Ex. 2038. Also, Patent Owner has conferred with
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`Petitioner about this motion, and Petitioner does not oppose it.
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`5
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`Patent Owner’s Unopposed Motion to Seal
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
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`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.
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`6
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`2149-2152 and 2158-2160.
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`Dated: October 28, 2015
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`Customer Number
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`Tel. (703) 413-3000
`Fax. (703) 413-2220
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`Patent Owner’s Unopposed Motion to Seal
`Case IPR2014-01478
`U.S. Patent No. 7,293,520
`
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies service of PATENT OWNER’S
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`UNOPPOSED MOTION TO SEAL UNDER 37 C.F.R. §§ 42.14 AND 42.54 on
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`the counsel of record for the Petitioner by filing this document through the Patent
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`Review Processing System as well as by delivering a copy via electronic mail to
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`the following addresses:
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`David Berl
`dberl@wc.com
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`Jessamyn Berniker
`jberniker@wc.com
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`Thomas S. Fletcher
`tfletcher@wc.com
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`Christopher Suarez
`csuarez@wc.com
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`Date: October 28, 2015
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`/Michael L. Kiklis/
`Michael L. Kiklis
`Registration No. 38,939
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`Attorney for Patent Owner
`WESTERNGECO L.L.C.
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`7