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`That's correct.
`A
`And you can't see the boat?
`Q
`That's correct.
`A
`So now you are trying to grab a streamer?
`Q
`Yeah. Well, one person would be driving and the other two
`A
`folks will grab -- they'll literally -- it has gotten a lot
`better, we now have mechanical devices. But at the time we
`would get our arms around it and you would want to get it so
`you could attach and detach pieces. You don't want to tie it
`to your boat because if something goes wrong, it will flip your
`boat, and you want to stay in your boat.
`And so we would work on it and manage it and
`manhandle it. And we would sometimes have a spare section on
`the boat, and we would try to hook it up and swap it out. It
`was a lot of work.
`Q
`Are there people that don't want to get this job?
`A
`The small boat you have to volunteer to do. You can't
`force anyone to do this. But if it is your department and it
`is your equipment and you don't volunteer and no one else does,
`then you learn to like it.
`Q
`And what happens if you can't fix the tangle when you are
`back there in the boat?
`A
`If you can't fix the tangle by boat, because boat is always
`the best option because you don't have to pull everything back
`onboard the ship, you then use these large hydraulic winches to
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`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
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`managing the crew, you're managing the equipment. You are
`basically the representative on the beach for the boat, so you
`are their conduit to everything. You do all the ordering.
`When the client orders something, you talk to them. The time
`lines, delivery schedule, where the boat is, when it is going
`to be there.
`Q
`In that work, did you learn what was valuable to other U.S.
`companies?
`A
`Certainly.
`Q
`What was that?
`A
`Well, they want everything better, they want everything
`faster and they want everything safer.
`Q
`Do they care about value?
`A
`They do.
`Q
`And how do they measure that?
`A
`Value is normally measured in time. It is also measured in
`the quality of what you are doing, which is a function of time
`quite often.
`Q
`Let's talk a bit about the inventions in this case, sir.
`When did you first hear about a system that could steer
`streamers laterally?
`A
`I mentioned I worked for a company called Western
`Geophysical, and we did not have this. We wanted it but we
`didn't have it. It didn't exist, to my knowledge.
`Around 2000, we merged with a company called
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`slowly pull all the equipment back onboard the boat and repair
`it.
`Couldn't you just cut the cable loose?
`Q
`No. We are a zero discharge company. We don't disturb --
`A
`we don't cut anything. The only time you are ever allowed to
`dump something over the side of the boat is if somebody's life
`is in immediate danger. Otherwise, you take the time to
`retrieve it. And if somebody's life is in danger and you cut
`something, the first thing you do after you secure that person
`is you go get whatever you put over the side of the boat.
`Q
`How long were you in this role where you were at the back
`of the boat responsible for the streamers and the array?
`A
`I was offshore my first two years, but I did doubles, so I
`ended up working about ten months each year offshore, and then
`I moved on to a different role.
`Q
`And what was your next job?
`A
`I was what was called an assistant party chief, assistant
`party manager. So I became the shore-based logistical manager
`for a group of vessels in the Gulf of Mexico. I was brought
`off the boats to manage some of the crews in Houston.
`Q
`In those roles, did you interact with customers?
`A
`I did.
`Q
`In what manner?
`A
`Well, every day you talk to the customer -- in that role,
`you are managing all the logistics for the boat, you are
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`mayramalone@comcast.net
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`Geco, and they had it. And when we became a joint company, we
`were very, very pleased. The first time I got to see it was in
`2000.
`Q
`Prior to Western and Geco coming together, which side were
`you on? The Western side?
`A
`I was on the Western side.
`Q
`And did Western have a lateral steering system?
`A
`We did not.
`Q
`Was that something you wanted for a long time?
`A
`Oh, certainly.
`Q
`Why?
`A
`Through all the problems I mentioned earlier, to keep these
`cables from separating, all we had was -- we had two other
`options. We had -- we attempted to put -- steer our tail
`buoys, but none of those ever worked. We ended up either
`breaking the tail buoy off or floating them.
`The other thing we had was something called
`cross-tagging, which was basically a rope between the cables,
`which turns your seismic array into a bit of a trawler net,
`so...
`Q
`When you mentioned a second ago that you had these two
`options, the rope and this steerable tail buoy, what was that?
`A
`It was at the back of this cable, you have a float, and the
`float has a radar detector and a GPS antenna or something so
`you can position it. And we basically put a fin that you can
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
`WESTERNGECO Exhibit 2035, pg. 1
`PGS v WESTERNGECO
`IPR2014-01478
`
`

`

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`control to try and drive this tail buoy around.
`Q
`Okay. Was there anything else between the end of the
`streamer and the ship that was attempting to steer it?
`A
`Not laterally, no.
`Q
`And did this tail buoy work to steer the streamer?
`A
`No. They broke off. The most you could do was to try to
`get a tail buoy to work a little bit, but even then -- I never
`saw one successfully work in the field.
`Q
`Had Western tried to solve this lateral steering problem
`and failed?
`A
`We had wanted to try, but we had never been successful at
`anything.
`THE COURT: The lateral steering mechanism you were
`using, was that patented?
`THE WITNESS: I don't know. It was on the tail buoy,
`but it was very different than an inline streaming device.
`BY MR. LoCASCIO:
`Q
`Let me talk for a second about this Western and Geco
`combination or merger. What did Geco Limited do?
`A
`Geco had a different acquisition system than we did, which
`was called a Q, and it had lateral steering.
`Q
`And what did Western bring to the table?
`A
`Western brought a lot of people, a lots of boats, a lot of
`experience, so it was a pretty good merger of people and
`technology. We weren't looking forward to the merger
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`How did the demo go?
`Q
`The Geco equipment won.
`A
`You said it made you happy that you were now going to have
`Q
`this technology. Why, from an industry standpoint?
`A
`Well, it was a competitive advantage. If you can steer the
`cable, you can shoot your surveys safer, you can shoot them
`faster, you can position them better. It is -- I think it's
`one of the most incredible developments in the field I have
`ever seen.
`Q
`Prior to Geco's development of this technology, was this a
`problem people were trying to solve?
`A
`Certainly.
`Q
`Was this the first time you had seen it solved?
`A
`I had never seen it solved. I had never seen anything even
`approach this that worked. It wasn't just one bird. It was a
`system that moved in tandem. You could move all these cables
`around. You could actually control this thing for the first
`time.
`Q
`Q-Marine, which is the name the Geco system had, has that
`been successful?
`A
`It's been very successful.
`Q
`Why, do you think?
`A
`Well, we started out with one Q-Marine crew and we are
`still rolling out. We're eventually converting the entire
`fleet. The majority of our fleet today is Q. I think 11 boats
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`beforehand, but once we saw what they had, some of us were
`happy.
`Q
`Were you happy?
`A
`I was happy. I am happy.
`Q
`What is it about the merger that you thought was a good
`thing for the company?
`A
`Well, they had a much, much better acquisition system than
`we did, and they had the ability to steer the streamers. They
`had technology that was far and above better than ours.
`Q
`What time period was this?
`A
`This was 2000.
`Q
`And did you see the Geco steering system after the merger
`took place?
`A
`I did.
`Q
`What did you see?
`A
`I was an operations manager at this point, so I was
`still -- I was part of the field crew, managing field crews.
`And so I spent a lot of time on the boat, still going out and
`at the docks. And I got to see one of the vessels where we
`tested WesternGeco's two cables and Geco's two cables alongside
`each other.
`Q
`So Western and Geco sort of had a showdown?
`A
`They put all four cables on the back of the vessel. I
`wasn't part of the test group itself, but it was all logistics
`team down there helping get it down there to the boat.
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
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`are. The goal is to replace every single vessel we have with
`this stuff because we get a premium for it when we work. It is
`demanded by the customers, and it has been very successful.
`Q
`You indicated that the customers want the surveys to be
`faster, better and safer. Can we take those one by one with
`connection to lateral steering?
`A
`Sure.
`Q
`How does lateral steering allow you to conduct a survey
`faster?
`A
`Right off the bat, having streamer control is -- it's
`important for something we called "infill" earlier when we were
`referencing it. And this is when you are shooting prime or
`you're shooting infill, and infill is the bits of unmowed lawn.
`I made a board. I can show you if you like.
`The simplest analogy is the lawnmower analogy,
`and you are trying to mow a yard, and you're trying to mow the
`data. This is my boat and this is my yard, and you do your
`pass moving upwards. You now have one pass where you have
`essentially cleaned that data.
`Q
`How long does it take for the ship to make that pass
`typically?
`A
`It can be -- the length of a line is dependent -- in the
`Gulf of Mexico, the average lines that we have been shooting
`have been ten to 12 hours.
`Q
`Just to go up once?
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
`WESTERNGECO Exhibit 2035, pg. 2
`PGS v WESTERNGECO
`IPR2014-01478
`
`

`

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`Just to go one pass up.
`A
`And what happens then?
`Q
`We then want to turn around. It is something called a
`A
`"line change." So we then take the boat. Now, if you just
`pivot, you have to remember you have cables which might be the
`length of the survey, so the boat has to go all the way up
`here.
`
`Now, in order to turn around, you can do one of
`two things. If you want to take the line directly beside you,
`you have to do a big, giant turn, like you have a trailer on
`your car. That adds a couple hours to your turn. It is not
`efficient.
`
`So you do something called a "racetrack." You
`come up, and then you come down in another location over here.
`As you go down, you do your second pass, and so now you have
`two clean lines in your yard and you have a bunch of grass
`still to mow. Sorry for the analogy, but it was the one first
`used to me when I went offshore, and it makes sense.
`You then come back around, and you want to line
`up. This has now been ten to 12 hours. It could be longer, it
`could be shorter. I'm not arguing that. And then you have
`added three to six hours for each of these line changes, so it
`might be a day or two later when you are coming back on the
`second line. The weather could have changed, the currents
`could have changed. And you come on, and you are trying to
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`you can try to plan on. But you have to remember, if you have
`this vessel that's towing 6 miles of cable, if they see a ship
`and even if they answer, if they don't get out of the way fast
`enough, the only thing you can do is turn very, very slowly.
`It's a slow-motion nightmare when things don't go very right.
`So if you have this tree in the middle, you have
`to come in and get the tree and you have to go around it. If
`you come in like this and try and go around the tree, you will
`get it on one side. If you then come back the other direction,
`you leave a large hole around that tree, so that creates even
`more infill.
`Q
`How does the lateral steering system allow you to improve
`on this?
`A
`So lateral steering, if you are actively controlling where
`your lawnmower is going, it gives you the chance so that if you
`are moving here and you see the current starts to push your
`cable over, when you are getting this line the first time, you
`can swing them over and attempt to catch that.
`In addition, when you're going around
`obstructions, you can get closer, which is important because
`the oil rig is normally the most important part of the survey.
`The oil is underneath that thing, so you want to get as close
`as possible. But you want to do it safely, you don't want to
`hit it.
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`The other thing you can do is, if you do see a
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`match this vessel alongside again. You start out with the best
`of intentions on your line, but as the currents come, you might
`leave a pass of infill. And as you go up, you then have an
`element of basically unmowed yard.
`As the survey continues, you are trying really
`hard. We were trying really hard. We spent a lot of time
`watching those cables and moving the boat around. You end up
`with chunks of unknown grass. That's the infill that you have
`to come back.
`Q
`How is it that you would come back to get it?
`A
`You do it one of two ways. You either clean it up as you
`go, which is very rare, because every job has a budget and you
`have so much money you can spend, or you come back at the end
`of the job and you pick up these passes.
`Q
`To clean up one of those strips of grass or pieces of
`infill, how much additional time does that take?
`A
`If the pass is not located directly in line with another
`pass, so you have to do a whole line for it, it is like
`shooting an entire line over again. So you might spent 18,
`20 hours to go back and get that one piece of grass.
`Q
`Are there ever obstructions in the field?
`A
`Okay. So this is another yard example. If you have trees
`in your yard, if you have toys in the yard when you are mowing,
`it's the same as if you have oil platforms or ships. The oil
`platforms you can plan on. The ships, if they are responding,
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`mayramalone@comcast.net
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`vessel coming across, a ship or otherwise, you can react in a
`safer, more controlled manner than just driving in a big loop
`and coming back and doing it again.
`Q
`Thank you, sir.
`A
`Sorry. I'm not an artist.
`Q
`Can you explain to the jury what repeatability is in
`surveys?
`A
`I have some examples of a 4D survey. But repeatability is,
`once a company found its reservoir, they want to try and
`produce it efficiently. Oil fields are not like a triangle
`with a spigot on the top. The best shape I have ever seen is
`more like a potato, a very misshapen potato.
`They want to produce this. So with
`repeatability, they want to go back and take multiple pictures
`of this reservoir through the life of production.
`Q
`You mentioned you might have a slide that might help
`explain this to the jury.
`A
`Yes. This one is built learning. If you go to Slide 7 and
`you show the reservoir.
`MR. LoCASCIO: Let's get that on the screen.
`THE WITNESS: So this is your reservoir. They have
`decided to start producing it. In this function of production,
`they are going to do many things to this reservoir. They're
`going to put a hole in the top.
`As production starts to slow down, they are going
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
`WESTERNGECO Exhibit 2035, pg. 3
`PGS v WESTERNGECO
`IPR2014-01478
`
`

`

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`to do many different things to get the oil and gas out. They
`may inject air into the reservoir. They may inject water into
`the reservoir, and the reservoir wall is going to change.
`So if you go to the next image, this is Slide A.
`So in '09, you have the first image. You do what's called a
`baseline survey. So you get your very first picture. And this
`is a snapshot of what the reservoir looks like. You come back
`later in '12, you shoot another picture, and you want to
`compare the difference in those. So after you have the two
`surveys, you start to see how the oil and gas is moving around
`the reservoir.
`Now, mentioning a camera, this very much equates
`to setting up a camera in front of an object and trying to spot
`the difference in one specific item. If you take that picture
`over and over, you can see what has changed when you look at
`these pictures side by side. If you start moving the camera
`around, you lose -- you start -- it gets much more difficult to
`find out what is actually changing in that reservoir. The
`reason this is important is to efficiently extract that,
`because you want to get as much oil and gas out of that as you
`can onshore, into your production facility.
`Q
`And how does lateral steering of the system that does it
`allow you to get a better 4D image?
`A
`So lateral steering helps in actually multiple ways in a 4D
`survey. First and foremost, when you shoot that baseline
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`would all try to take an image of it, but the oil companies
`would consider their final interpretation as their property, so
`that is going to be the property of the oil company.
`THE COURT: So is it a little bit like a radiologist
`taking an image and showing it to a surgeon?
`THE WITNESS: Yes. And three surgeons are going to
`have different opinions on where to cut but...
`THE COURT: Yeah.
`BY MR. LoCASCIO:
`Q
`Going back to the benefits of Q-Marine, how does Q-Marine
`make surveys safer?
`A
`Well, by being able to control these streamers, you can
`reduce -- number one, you can reduce your likelihood of hitting
`something. You don't ever want to do that. You can reduce the
`instances of tangles, and the fewer tangles you have, the less
`people you are putting in the back of the vessels.
`Q
`Do streamers still get tangled, or is this the 100 percent
`solution?
`A
`The streamers still get tangled, that's true. But let's
`say, for example, you had ten cables out and you hit a tree --
`Q
`I assume that's a floating tree?
`A
`A floating tree. We had a telephone pole come in one of
`our lanes Christmas Day, I remember.
`So this thing starts to go crazy on the right.
`If you can't control your streamers, there's a good chance that
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`survey, you know where your cables are, so you know where your
`camera is. If you can steer your cables and you are not
`dependent on the currents, you can accurately put that camera
`back in the right place. You can put those cables almost in
`the exact same heading, weather-dependent, or as close as
`possible to. So you start to remove -- you start to remove
`elements that are not part of your original -- your 4D image.
`You start to remove the noise.
`In addition, a 4D production means that's
`somebody found oil and gas there, so they've gone and put a rig
`right on top of where you are trying to be looking. So they
`put a tree on top of your -- in the middle of your yard. So by
`adding a service stream, it allows you to effectively get
`around those obstructions. So it makes your 4D surveys much
`more efficient.
`Q
`Didn't people do 3D and 4D surveys before this technology
`existed?
`A
`We did. But they have gotten much, much better since we
`have been able to steer streamers laterally.
`Q
`Has that difference been valuable to customers?
`A
`It has been very valuable to customers.
`THE COURT: Who would read the end product? Would it
`be somebody with WesternGeco or would it be a client,
`geologist?
`THE WITNESS: Geologist in the oil company -- well, we
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
` 302
`
`LOCASCIO Continued Direct of THOMAS SCOULIOS
`
`outside cable is going to break off and it's going to start to
`fall backwards. If your cables are all drifting to the right
`and your right side cable breaks, it is going to catch it and
`then you could have a domino effect. I have been on a job
`where I have seen all ten cables get ripped off one by one.
`100 kilometers of cable ended up getting ripped off the back of
`the boat, which is a nightmare.
`If you can steer your streamers and you start to
`have an incident on the outside cable, you quickly get the
`other nine and get out of the way, and you have one break off
`and you send one back and hopefully you can pick it up.
`Because it hasn't touched any of the others, it is much easier
`to fix and repair, and you can get it going hopefully in less
`than a day. That is the goal anyway.
`Q
`You mentioned earlier shooting around a rig and shooting
`around other obstructions. Can you give the jury a
`particularly complicated example of doing that?
`A
`I can. I have got some examples for this. The most
`complicated example of steerable streamer I have ever seen was
`actually in the Gulf of Mexico. This was a very, very bad
`incident. I think everybody is familiar with BP when they had
`the Macondo oil spill. We were not involved before, but we
`were asked to help in fixing it.
`So this survey was called the Moses survey. It
`was a Mississippi offshore bird and seismic evaluation survey,
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
`WESTERNGECO Exhibit 2035, pg. 4
`PGS v WESTERNGECO
`IPR2014-01478
`
`

`

`LOCASCIO Continued Direct of THOMAS SCOULIOS
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`and they had something like 100 vessels out there trying to fix
`this oil spill. This is while the oil spill was actually
`happening, not before.
`They gave us this map and they said: This red
`line we would like you to shoot and two more red lines that
`were in different azimuths as well.
`How this came to be is, Secretary Chu, who is the
`secretary of energy for the United States, with BP, evaluated
`our technology. They called us directly on the phone, and they
`said: Can you guys go in there and can you thread the needle?
`Can you put your cable three times a day over the top of the
`wellhead?
`
`Now, this was after the spill. You guys are
`saying: Well, why would you guys go in after the spill? We
`know where the reservoir is.
`The reason why is, when they were drilling the
`two relief wells -- I don't know if everybody remembers this,
`but they were drilling two holes in the ground, and it was
`going to take a long time. In order to speed that up, they
`wanted to try something called a top hat, which was basically
`to put a cork in a hose pipe.
`The fear was that BP had cracked the casing.
`Now, this is bad because if you have a hose pipe with a bunch
`of cracks in it and you put a cork in it, it's going to start
`to leak. If there are faults, that oil is going to come out of
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
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`LOCASCIO Continued Direct of THOMAS SCOULIOS
`
`I have one or two other pictures which
`demonstrate exactly how close the boats were. But for
`perspective, those two vessels are 400 meters apart. So you
`have two ships, which were the DD1 and DD2, 400 meters apart.
`They were both drilling the relief wells, and they were not
`allowed to move. Our boat was coming through, I believe, with
`a 3-kilometer cable, which is 30 football fields long. We are
`trying to drive this thing through there every day in three
`different directions. We didn't go every day. We attempted
`to.
`
`And I think we have one more picture of what the
`captain actually saw. This was the captain's view out of his
`window. We put multiple captains on there because we had -- we
`had multiple captains on the bridge working around the clock.
`But this is an example of how much -- what you
`can do if you actually have control, if you can laterally steer
`that cable.
`Q
`Is this typically the distance that you would get from an
`obstruction?
`A
`We would never go within -- normally our safety rule says
`prudence, within 500 meters. To be less than 200 meters is not
`something we would do.
`Q
`Now, is this a 2D, 3D or a 4D survey?
`A
`This is a 2D, 4D survey. So we did a bunch of 2D surveys
`over and over to create a 4D image.
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`those faults and travel up the fault lines, and then you will
`have three or four oil spills which you could not contain.
`So they said: We need to, number one, wait
`another 60 days for the relief well to be drilled and, number
`two, we come in here and try and fix it sooner.
`So the U.S. government and BP came and they said:
`Please do this for us.
`Now, this was a tragedy. It is not a survey that
`we would have ever jumped at doing; however, there is no way we
`could say no to doing something like this if we had the
`technology.
`
`So we took a vessel with a couple-mile cable, and
`we put it in between -- the goal was to shoot three times a day
`in between these boats. Every night a helicopter came and took
`that data. Every night it came onshore for 30 days, and they
`processed it and they made 30 time slots. And once they were
`confident that the casing was intact, they allowed the top hot
`procedure to go forward, which allowed the capping of the well
`sooner.
`
`So while this was a horrible incident, I was
`extremely -- and not what I wanted to be called to do, I was
`extremely proud we were able to help. I was extremely proud of
`the crew, and I was extremely proud that we had the equipment
`and the cable. And the lateral steering was the only way we
`could have ever done this survey safely.
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
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`LOCASCIO Continued Direct of THOMAS SCOULIOS
`
`Why not have more streamers and do 4D?
`Q
`They simply wouldn't fit in between the vessels. This is
`A
`just an example of showing how important this -- how you can
`control a system.
`Q
`Let's talk for a second about more typical jobs than that
`one. For customers, the benefits from Q-Marine are something
`they are willing to pay for?
`A
`They are.
`Q
`How do you know that?
`A
`They regularly -- well, number one, we have become the
`largest marine seismic company not by choice but by having the
`best equipment, the best service quality. We are regularly
`paid a premium for what we do.
`Q
`Go ahead.
`A
`And we are -- it has been so successful that we have a plan
`since day one to convert every single vessel we have to Q and
`steerable streamer, which is going on.
`Q
`Were you in the room yesterday for opening statements?
`A
`I was.
`Q
`There was a statement by Mr. Torgerson that WesternGeco
`still had boats at some point that had conventional streamers
`that had not been converted over to steerable streamers.
`Is that the case?
`That is true.
`Can you explain why?
`
`A
`Q
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
`WESTERNGECO Exhibit 2035, pg. 5
`PGS v WESTERNGECO
`IPR2014-01478
`
`

`

`LOCASCIO Continued Direct of THOMAS SCOULIOS
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`Well, certainly. All of our boats were conventional before
`A
`we came up with the stuff. It costs quite a bit, well over
`$100 million to invent the stuff. We then started using it in
`the year 2000. We had to prove it to the marketplace. We had
`to prove to our customers it worked. We then had to slowly
`start rolling it out and building a marketplace and
`demonstrating.
`Now, we had all this other equipment that we had
`invested in. We couldn't just throw it away. As it reaches
`its end of life, every single system year on year has been
`replaced. I think we have one of our conventional Nessie crews
`left, one of our -- and then I think we have two legacy --
`yeah. So if we have -- we have 11 Q and we have three of the
`other vessels, and those are all on a plan to be replaced with
`steerable streamer as soon as that technology is -- we are not
`going to throw it away just because it is old, it is too
`expensive. But it was an incredibly big investment and our
`plan is to roll it out as soon as we get there.
`Q
`You indicate you think you have 11 ships that have lateral
`steering systems on the whole ship?
`A
`Correct.
`Q
`Have you ever seen a situation where you give a customer a
`choice between conventional and lateral steering?
`A
`Certainly.
`Q
`What happens?
`
`Mayra Malone, CSR, RMR, CRR
`mayramalone@comcast.net
`
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`LOCASCIO Continued Direct of THOMAS SCOULIOS
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`objection, they are en bloc admitted.
`MR. LoCASCIO: Thank you. I assume, Your Honor, if we
`want to publish one to the jury, I can go ahead and do that?
`THE COURT: You may.
`MR. LoCASCIO: Thank you.
`BY MR. LoCASCIO:
`Q
`If we can pull up Plaintiff's Exhibit Number 1 for a
`moment. Plaintiff's 1 is what we have called a few times the
`'520 patent in this case.
`MR. LoCASCIO: If we can go to the second page. And
`if you can blow up the upper corner.
`BY MR. LoCASCIO:
`Q
`Plaintiff's Exhibit Number 1 is one of the four patents at
`issue in this case, the '520 patent. I want to ask you if you
`can tell me from the face of this patent who owns it.
`MR. LoCASCIO: Dave, let's blow up that left side.
`Thank you.
`THE WITNESS: WesternGeco.
`BY MR. LoCASCIO:
`Q
`And where are you looking?
`A
`Line 73, assignee, WesternGeco, LLC.
`Q
`Is that the company you were president of?
`A
`I was president of WesternGeco, LLC from February 2008
`until October 2011.
`Q
`Are all four of these patents -- the '520 patent,
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`Well, most often the lateral steering system is chosen, the
`A
`Q system. It is always priced more expensively in the tender,
`and we are quite often paid more than we would be for our
`conventional system.
`THE COURT: Are the profit margins similar or not?
`THE WITNESS: No, they're higher on the steerable, the
`la