IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`WESTERNGECO LLC
`Petitioner
`v.
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`PETROLEUM GEO-SERVICES INC.
`Patent Owner
`
`
`
`Case IPR2015-00309
`Case IPR2015-00310
`Case IPR2015-00311
`Patent 6,906,981
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`
`DECLARATION OF WALTER S. LYNN, Ph.D.
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`TABLE OF CONTENTS
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`INTRODUCTION ........................................................................................... 1
`I.
`II. QUALIFICATIONS ........................................................................................ 2
`III. COMPENSATION AND RELATIONSHIP TO THE PARTIES .................. 9
`IV. LEGAL STANDARDS ................................................................................. 10
`A. Priority Date ........................................................................................... 10
`B. Broadest Reasonable Interpretation ....................................................... 10
`C. Anticipation ............................................................................................ 10
`D. Obviousness ........................................................................................... 11
`THE PERSON OF ORDINARY SKILL IN THE ART ............................... 12
`V.
`VI. SUMMARY OF OPINION ........................................................................... 13
`VII. TECHNICAL BACKGROUND ................................................................... 14
`A. Overview of Marine Seismic Surveying ................................................ 14
`B. Conventional Shooting Versus Simultaneous Shooting ........................ 22
`C. Early Land-Based Techniques for Simultaneous Shooting ................... 26
`D. Differences Between Land and Marine Surveying ................................ 28
`VIII. THE VAAGE PATENT ................................................................................ 29
`A. The Claim Language .............................................................................. 38
`1. Claim 1 and Dependent Claims ........................................................ 38
`2. Claim 23 and Dependent Claims ...................................................... 41
`3. Claim 31 and Dependent Claims ...................................................... 43
`B. Claim Construction ................................................................................ 46
`1.
`“Indexed” .......................................................................................... 46
`2.
`“Quasi-Randomly” and “Randomly” ............................................... 49
`3.
`“Wavelet Time” ................................................................................ 55
`IX. THE ASSERTED PRIOR ART .................................................................... 55
`A. Edington ................................................................................................. 55
`B. Beasley ................................................................................................... 60
`C. De Kok ................................................................................................... 66
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`X. DE KOK DOES NOT ANTICIPATE THE CHALLENGED CLAIMS. ..... 78
`A. De Kok Does Not Disclose “Index[ing]” of Source Firing Times.
`(Claims 1, 2, 7, 10–21, 23, 24, 30). ............................................................... 78
`B. De Kok Does Not Teach “Separate Identification of Seismic Events.”
`(Claims 1, 2, 7, 10–21, 23, 24, 30) ................................................................ 82
`C. De Kok Does Not Teach “A Selected Distance” Between Sources.
`(Claims 1, 2, 7, 10–21, 23, 24, 30) ................................................................ 84
`D. De Kok Does Not Teach Determining “Trace to Trace” Coherent
`Components. (Claims 12–15, 17–20) ............................................................ 85
`E. De Kok Does Not Teach “Time Aligning” the Recorded Signals.
`(Claims 14–15, 19–20, 31–32, 36–38) .......................................................... 87
`F. De Kok Does Not Teach the Use of a “Common Midpoint Gather” to
`Determine “Shot to Shot Coherent Components.” (13, 15, 18, 20, 36–37) .. 89
`XI. NONE OF THE CHALLENGED CLAIMS ARE OBVIOUS OVER A
`COMBINATION OF THE BEASLEY AND EDINGTON PATENTS ................. 92
`A. A POSA Would Have Had No Reason to Combine Beasley and
`Edington. ........................................................................................................ 92
`B. Even if Combined, Beasley and Edington Fail to Render Obvious
`Several of the Challenged Claims. ................................................................ 98
`1. Beasley and Edington Do Not Render Quasi-Random or Random
`Time Delays Obvious (Claims 3–4, 25–26, 33–34). ........................ 98
`2. Beasley and Edington Do Not Render Time Delays Varied “In
`Steps of About 100 Milliseconds” Obvious (Claim 5). .................. 100
`3. Beasley and Edington Do Not Render Time Delays Varied “In
`Steps of At Least About 100 Milliseconds” Obvious (Claim 27). . 101
`4. Beasley and Edington Do Not Render Obvious the Use of CMP
`Gathers to Determine Shot to Shot Coherence (Claims 18, 20, 36–
`37). .................................................................................................. 102
`C. Objective Indicia Demonstrate the Non-Obviousness of the Challenged
`Claims .......................................................................................................... 103
`1. Long-Felt but Unmet Need ............................................................. 104
`2.
`Industry Praise and Copying ........................................................... 105
`XII. CONCLUSION ............................................................................................ 109
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`I, Dr. Walter Lynn, hereby state the following:
`I.
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`INTRODUCTION
`1.
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`I have been informed by counsel for Petroleum Geo-Services, Inc.
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`(“PGS”) that the Patent Trial and Appeal Board has granted the petitions of
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`WesternGeco LLC (“WesternGeco”) to institute these Inter Partes Reviews
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`(“IPRs”) regarding the patentability of certain claims of U.S. Patent No. 6,906,981
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`(“Vaage” or “the Vaage Patent”) (Ex. 10011). I understand from counsel that the
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`Board has instituted review on the following grounds:
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`Ground 1: Anticipation of claims 1, 2, 7, 10–21; 23–24, 30; 31–32, and 36–
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`38 of the Vaage Patent by U.S. Patent No. 6,545,944 B2 (“de Kok” or “the
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`de Kok patent”) (Ex. 1003);
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`Ground 2: Obviousness of claims 1–6 and 16–22; 23–29; and 31–37 of the
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`Vaage Patent over the combination of U.S. Patent No. 5,924,049 (“Beasley”
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`or “the Beasley patent”) (Ex. 1004) and U.S. Patent No. 4,953,657
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`(“Edington” or “the Edington patent”) (Ex. 1006).
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`2.
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`I understand that no review was instituted as to claims 8 and 9 of the
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`Vaage Patent, or as to certain additional grounds asserted by WesternGeco and
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`1 By “Ex. 1001,” I mean Exhibit 1001 in Case IPR2015-00309. All citations to
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`exhibits in the Declaration are to the exhibits in Case IPR2015-00309.
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`1
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`discussed by WesternGeco’s expert witness, Dr. Luc Ikelle. I understand that these
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`claims and additional grounds are not at issue in this proceeding.
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`3.
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`I have been retained by PGS as an expert witness to opine on various
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`aspects of the methods and systems claimed in the Vaage Patent, including whether
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`those methods and systems are anticipated by the de Kok patent or would have
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`been obvious to a person of ordinary skill in the art (“POSA”) over the Beasley and
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`Edington references asserted by WesternGeco.
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`4.
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`In reaching my opinions regarding the Vaage Patent, I have reviewed
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`the documents cited herein and have relied on my decades of knowledge and
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`experience in the fields of seismic data acquisition, processing, and interpretation
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`(outlined in Section II), bearing in mind the information available to a person of
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`ordinary skill in the art as of July 17, 2002. This declaration sets forth the bases
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`and reasons for my opinions, including the materials and information relied upon
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`in forming those opinions and conclusions.
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`II. QUALIFICATIONS
`5.
`I am a Geophysicist specializing in the field of reflection seismology,
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`especially in relation to oil and gas exploration. I am currently the Chief Operating
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`Officer and co-owner of Lynn Inc., a privately-owned independent consulting firm
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`which specializes in multi-azimuth, multi-component, and three-dimensional (3D)
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`seismic acquisition, processing, and interpretation. In addition, I am an Adjunct
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`2
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`Professor at the Colorado School of Mines, where I teach a graduate-level course
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`entitled “Seismic Data Processing” each fall semester. As an adjunct professor, I
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`have served on numerous thesis M.S. and Ph.D. committees for students pursuing
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`their master’s and doctorate degrees in the fields of reflection seismology and
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`reservoir characterization.
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`6.
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`Based on my education, background, experience, and expertise, I am
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`qualified to provide an opinion as to what a person of ordinary skill in the art
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`would have understood, known, or concluded regarding the scientific principles
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`and inventions involved in this case as of the priority date.
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`7.
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`I have obtained the following degrees: a bachelor’s of arts in Geology
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`and Geophysics from Princeton University in 1973; a Master’s degree in
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`Geophysics from Oregon State University in 1975, and a Ph.D. in Geophysics,
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`with an emphasis on reflection seismology, from Stanford University in 1979.
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`While at Stanford, I drafted a number of Stanford Exploration Project Research
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`Reports relating to the processing and imaging of reflection seismic data.
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`8.
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`I have worked continuously in the field of reflection seismology since
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`obtaining my Ph.D. in 1979. Immediately after completing my doctorate degree, I
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`accepted a position in Research and Development at Western Geophysical. I held
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`this position for over eleven years from 1979 until 1991. During this time period, I
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`worked on numerous projects including the development of seismic velocity, 2D
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`and 3D imaging and modeling software, several field research projects related to
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`marine seismic-noise suppression techniques; and consulted with company and
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`client personnel on problems and issues related to the acquisition, processing, and
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`interpretation of reflection seismic data.
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`9.
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`From January of 1991 until July of 1991, I served as President of
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`Lynn Inc. During this period, I consulted with two companies, Western Research
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`(my former employer) and Oklahoma Seismic. My work with the former was to
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`finish a major software effort that I had been developing on the manipulation of
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`velocity information. My work with Oklahoma Seismic was writing software
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`modules for its product, MIRA—a PC-based seismic modeling and interpretation
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`package.
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`10.
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`In August of 1991, I was hired as the Executive Vice President for
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`Technology at Grant Tensor Geophysical. In this role, I spearheaded the
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`development of the first commercial 3D pre-stack depth migration capability.
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`Grant-Tensor was dissolved in 1993 and the data processing assets were purchased
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`by and became a part of Petroleum Geoservices (PGS). At the time of the
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`purchase, the data processing company was known as PGS-Tensor. Several years
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`later, it was named PGS Data Processing.
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`11.
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`In July 1994, I was promoted to President of PGS Tensor, Inc., where
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`I was responsible for overseeing PGS seismic data processing operations
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`worldwide. During my tenure, the company grew 65 percent per year in personnel
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`and revenue from 1994 through 1998. From 1999–2002, I worked as the Senior
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`Vice President of Technical Marketing at PGS, the parent company of all PGS
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`subsidiaries, where I was responsible for packaging and presenting all PGS
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`technical products, services, and strategies to both lay-level and expert geophysical
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`audiences as well as financial analysts. During my time with PGS, the company’s
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`commercial strength was in its marine seismic acquisition technology and services.
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`In, or about, 1996, I oversaw the implementation of complete on-board data
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`processing on the PGS vessels. This was a first in the industry and is a common
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`practice throughout the industry today. Although marine simultaneous shooting
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`was not done during this time period, I became very familiar with marine
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`acquisition operations and I draw upon that experience in this declaration.
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`12.
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`I have been a member of the Society of Exploration Geophysicists
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`(“SEG”) for over 40 years (since 1973), and am currently an Honorary Member of
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`SEG. SEG is the largest professional association for exploration geophysics in the
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`world. I was elected President-elect of SEG in 2000 and served as President from
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`September 2001 through August 2002. During this time, SEG had over nineteen-
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`thousand members. As President of SEG, I represented SEG worldwide and
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`worked extensively with regional SEG affiliates and with other professional
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`societies in geophysics around the globe. A short list of countries and geophysical
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`5
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`societies that I interacted with includes Europe (European Association for
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`Geoscientists and Engineers, “EAGE”), Australia (Australia Society of Exploration
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`Geophysicists), Canada (Canadian Society of Exploration Geophysicists,
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`“CSEG”), India (Society of Petroleum Geophysists, “SPG”), China (Chinese
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`Geophysical Society, “CGS”) and Brazil (Brazilian Geophysical Society, “SBGf”).
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`In addition to the SEG, I am also a member of a number of other professional
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`societies in the field of geophysics, including EAGE, the Geophysical Society of
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`Houston, the Denver Geophysical Society, and the U.S. Section of the Russian
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`Academy of Natural Sciences. I am also a member of the scientific research
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`society Sigma Xi and the honor society Phi Kappa Phi.
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`13. After my tenure at PGS, I resumed my work at Lynn Inc. as Chief
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`Operating Officer in 2002. I continue to hold this position today. In this role, I
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`have assisted numerous clients with the processing and interpretation of land and
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`marine full azimuth 3D seismic data. Although this field of study is complex, the
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`main objective of our work is a better understanding of fractured reservoirs to
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`optimize drilling programs.
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`14. Throughout my career, I have been associated with numerous projects
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`that involved the processing, analysis, and imaging of seismic data. These projects
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`involve numerous datasets across numerous surveys. In Occidental Qatar, for
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`example, I worked on processing and interpreting two offshore 3D multi-
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`component datasets, and wrote programs to, among other things, compute
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`azimuthal velocity and amplitude versus offset (AVO), in order to facilitate the
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`mapping of subsurface fractures. I have worked on other projects involving
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`azimuthal velocity, AVO, and other seismic attributes for numerous clients,
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`including Apache, Devon Energy, El Paso Energy, Pioneer Resources, Jetta
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`Operating Co., EOG, Exco, Resolve Geosciences, Lake Ronel, and Pablo Energy.
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`15. From 2004–06, I served on the National Science Foundation Advisory
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`Board for the Geoscience Directorate.
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`16. Since August 2009, I have served as an adjunct professor in the
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`Geophysics Department at the Colorado School of Mines, where I have taught a
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`graduate-level course on seismic data processing. This course is offered to both
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`graduate students and seniors and involves hands-on computer exercises in seismic
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`data processing. In my capacity as professor, I have served on numerous Ph.D and
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`M.S. thesis committees and continue to do so today.
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`17. From January 2010 to December 2012, I served as a board member
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`and chair of SEG’s Advanced Modeling Corporation (SEAM). SEAM is a
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`partnership between industry and SEG to construct realistic subsurface models and
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`model seismic data in an effort to advance the geophysical science field.
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`Computationally, the creation of seismic data over such models comes under the
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`category of grand challenge problems, that is, computer algorithms requiring
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`extremely high performance computers to provide usable data in a reasonable
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`amount of time. SEAM was awarded an SEG Special Commendation at the 2014
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`SEG Annual Convention.
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`18. Over the years, I have authored and co-authored over twenty-five
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`publications, including a number in peer-reviewed journals including Geophysics,
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`the Journal of Geophysical Research, and Geophysical Prospecting. I have also
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`presented abstracts at a number of industry conferences, including at SEG Annual
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`Meetings. Many of these publications and abstracts have dealt with the issues
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`related to noises created by marine seismic sources. One relevant paper to this
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`case in which I was the lead investigator and co-author is “Experimental
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`Investigation of Interference from Other Seismic Crews,” which was published in
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`Volume 52 of Geophysics in November 1987 (while I was at Western
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`Geophysical). The paper conveyed the results of two studies performed with the
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`goal of determining the maximum amount of recorded energy from other seismic
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`crews that could be tolerated in marine seismic data. My co-authors and I
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`observed that if the firing intervals (the time between successive shots) of the other
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`crew differed from that of the survey crew in question, interference from the other
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`crew would be misaligned in CMP gathers and would be greatly attenuated by
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`conventional CMP stacking. Neither I nor others at the time thought to apply these
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`observations to the acquisition of seismic data using multiple simultaneous
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`8
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`sources. In the wake of the Vaage Patent, however, my observations later became
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`of foundational importance to the development of marine simultaneous source
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`techniques.
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`19. My papers have received several awards over the years. Papers I have
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`authored or co-authored received the Best Paper Award at the 1986 Pacific Coast
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`SEG meeting, the 1989 Annual SEG Meeting, and the 1990 Canadian SEG
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`meeting. I have also co-chaired numerous geophysics conferences, including the
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`June 1998 SEG/CPS/EAGE Beijing International Geophysical Conference and
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`Exposition.
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`20.
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`I am a co-inventor of one patent in the seismic data processing field,
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`U.S. Patent No. 4,943,950. This patent is entitled “Method for Migrating Seismic
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`Data.” The other co-inventor of this patent was Dr. Craig Beasley, who is also the
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`co-inventor of the Beasley ’049 Patent referenced by WesternGeco in this case.
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`21. My complete curriculum vitae is attached as Ex. 2010.
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`III. COMPENSATION AND RELATIONSHIP TO THE PARTIES
`22.
`I am being compensated for my time at my standard hourly rate of
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`$315 plus expenses for my time spent on this matter. My compensation is in no
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`way dependent on the outcome of this IPR.
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`23.
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`It is my understanding that PGS Geophysical AS (“PGS”) is listed as
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`the assignee of the Vaage Patent. As discussed above, I have previously been
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`9
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`employed by PGS. I have also been previously employed by a predecessor of the
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`Petitioner, WesternGeco. Despite my prior employment, I own no stock in
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`WesternGeco or PGS, and have no other financial interest with those companies.
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`IV. LEGAL STANDARDS
`24. Although I am not an attorney and do not offer any legal opinions in
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`this proceeding, I have been informed of certain legal principles that I have relied
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`on in reaching the opinions set forth in this declaration.
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`A.
`25.
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`Priority Date
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`I have been asked by counsel to assume that the “priority date” of the
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`Vaage Patent is July 17, 2002. I have used this priority date in my analysis of what
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`the POSA would have known and understood, of whether the Vaage Patent would
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`have been obvious to a POSA, and of how the POSA would interpret the claims of
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`the Vaage Patent.
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`B.
`26.
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`Broadest Reasonable Interpretation
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`I understand that for purposes of these IPRs the terms in the claims of
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`the Vaage Patent are to be given their broadest reasonable interpretation in light of
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`the specification of the Vaage Patent, as understood by a POSA as of the priority
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`date.
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`C. Anticipation
`27.
`I understand that a patent claim is invalid if it is anticipated by the
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`prior art. I have been informed by counsel for PGS that an anticipation analysis
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`involves a review of the scope and content of the asserted prior art references and
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`that, to anticipate a claim under the relevant legal standard, a prior art reference
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`must disclose each and every element of the claim, arranged or combined as in the
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`claim.
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`28. Alternatively, I have been informed that a reference may also
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`anticipate a claim if it inherently discloses any claim elements that it does not
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`expressly disclose. In order for a claim element to be inherently disclosed, I
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`understand that the unstated element must be necessarily present, not merely
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`probably or possibly present, in the prior art.
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`D. Obviousness
`29.
`I understand that a patent claim is invalid if the differences between
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`the subject matter and the prior art would have been obvious to a POSA at the time
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`of invention. I have been informed by counsel that an obviousness analysis
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`involves a review of the scope and content of the asserted prior art, the differences
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`between the prior art and the claims at issue, the level of ordinary skill in the
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`pertinent art, and “objective indicia of non-obviousness,” such as long-felt need,
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`industry praise for the invention, and skepticism of others in the field. In
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`particular, I have been advised that, for an invention to be regarded as obvious, the
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`POSA must have had a reason to modify the prior art or to combine one or more
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`prior art references in a manner that would lead to the claimed invention.
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`V. THE PERSON OF ORDINARY SKILL IN THE ART
`30.
`I understand that the POSA is a hypothetical person who may possess
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`a set of skills of more than one actual person in the relevant field. I have been
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`informed that factors that may be considered in determining the level of ordinary
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`skill in the art may include: (1) the educational level of the inventor; (2) type of
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`problems encountered in the art; (3) prior art solutions to those problems; (4)
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`rapidity with which innovations are made; (5) sophistication of the technology; and
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`(6) educational level of active workers in the field.
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`31.
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`I have been asked to define the qualifications of the person of ordinary
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`skill in the art to which claims 1–7 and 10–38 of the Vaage Patent are directed, and
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`have formed an opinion regarding the person of ordinary skill in the art, as is
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`relevant to the opinions discussed below. In my opinion, the POSA would have
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`had expertise in the field of land- and marine-based seismic surveying, including at
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`least a Masters degree (or equivalent) in geophysics or a related field. The POSA
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`should have an understanding of seismic data acquisition systems and post-
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`acquisition seismic data processing and seismic imaging techniques, including
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`common concepts such as shot gathers, common midpoint (CMP) gathers,
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`stacking, and dip filtering. This person would also have a working knowledge of
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`the various scientific and practical limitations that accompany seismic reflection
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`survey design and seismic data acquisition and processing, especially the
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`challenges that are presented by marine multi-source or simultaneous source
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`surveying. Finally, the POSA would have knowledge relating to the encoding and
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`decoding of seismic data, including methods of source signature encoding and
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`decoding available as of the priority date, the limitations of the various methods of
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`encoding and decoding seismic data, and the relationship between those methods
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`of encoding and available methods of decoding.
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`32.
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`I have reviewed the definition of the person of ordinary skill in the art
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`offered by WesternGeco in its Petitions, see, e.g., ’309 Petition at 15,2 and in the
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`Declaration of its expert, Dr. Ikelle, Ex. 1002 ¶ 59. The opinions I express in this
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`report would not change were I to apply WesternGeco’s definition.
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`33.
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`I have undertaken to consider the knowledge the POSA would have
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`had as of July 17, 2002. When I refer to the POSA in this Declaration, I am
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`referring to a person of ordinary skill in the art as of that date.
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`VI. SUMMARY OF OPINION
`34.
`It is my opinion that the claims as to which review was instituted in
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`these proceedings—claims 1–7 and 10–38—were each patentable as of the July 17,
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`2 I will refer to the Petitions as the ’309 Petition, the ’310 Petition, and the ’311
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`Petition throughout this Declaration. Each Petition is Paper 1 in its respective
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`proceeding.
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`PGS Exhibit 2001
`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`2002 priority date of the Vaage Patent. I hold this opinion because 1) the de Kok
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`reference does not anticipate any of the claims as to which anticipation by de Kok
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`is an instituted ground for review, and 2) the combination of the Beasley and
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`Edington references does not render obvious any of the claims as to which
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`obviousness over the combination of Beasley and Edington is an instituted ground
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`for review. I will explain my opinion, and the bases for it, in the following
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`sections of this Declaration.
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`VII. TECHNICAL BACKGROUND
`35.
`In this section, I provide background on several technical concepts
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`that are pertinent to the disclosures of the Vaage Patent. I first begin with an
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`overview of marine seismic surveying, including the concepts of seismic traces and
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`common midpoint (CMP) gathers. This overview describes concepts that would
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`have been understood by the person of ordinary skill in the art as of July 17, 2002.
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`I then provide a brief introduction to the advantages and challenges associated with
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`simultaneous shooting and describe some of the early land-based techniques for
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`source separation. I will explain the specific approaches of the Vaage, de Kok,
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`Beasley, and Edington patents in Sections VIII–IX.
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`A. Overview of Marine Seismic Surveying
`36. Marine seismic surveying uses acoustic waves to explore and map the
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`subsurface earth layers beneath the seafloor. Data gathered in marine seismic
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`surveys are used to create maps of the earth’s subsurface, which can be used to
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`locate geological formations that are likely to yield deposits of hydrocarbons (oil
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`and gas), among other purposes.
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`37. Seismic surveys utilize what are known as seismic “sources” and
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`“receivers.” A seismic source (labeled “source” in the figure below) creates an
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`acoustic wave that propagates into the survey medium. This source may be one of
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`several different kinds. In land surveying, common sources include explosives,
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`weight drops, and large, truck-mounted vibrators known as Vibroseis sources. In
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`the marine environment, the most common sources are airguns, which create
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`acoustic waves by releasing explosive bursts of compressed air.
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`38. As the figure above demonstrates, see Ex. 1008 at 2, the acoustic
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`waves created by the seismic source are reflected and refracted each time they
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`reach a boundary, or interface, between earth layers of different composition. At
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`each such interface a portion of the wave’s energy is reflected back toward the
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`surface and the remainder passes through until it meets another interface, where it
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`splits again into reflected and refracted waves. This process continues as long as it
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`takes for the acoustic wave to dissipate.
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`39. Receivers located at or near the surface (labeled “receivers” above)
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`measure the amplitude and timing of seismic waves that arrive at the surface after
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`reflecting off the subsurface layers. These receivers are typically deployed in large
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`numbers so as to measure the reflections arriving at many different locations.
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`40. The time at which a particular reflection or refraction arrives at the
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`receiver conveys information about the subsurface because sound travels through
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`different geologic materials at different speeds. Amplitude information is also
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`useful because the strength of the reflected waves may vary with the composition
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`of the subsurface layers. The timing and amplitude information allows
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`geophysicists to deduce the thickness and composition of the earth layers, which in
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`turn allows them to create maps of the subsurface layers.
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`41. The below figure is a simplified diagram of a marine seismic survey
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`configuration. The system consists of a source (the open rectangle behind the
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`vessel), streamers containing seismic receivers (black dots), and a survey vessel
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`used to tow the source and streamer through the survey area. The source is
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`typically an array of airguns of different volumes towed between 6 to 12 meters
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`below the surface. The seismic receivers are regularly spaced along the length of
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`the streamer. The streamers are also generally towed at a fixed depth between 5 to
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`15 meters below the surface. As of the priority date, it was common to tow 6 to 12
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`streamers, each with a length of 6 to 8 km.
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`42. During the survey, the survey vessel proceeds at a constant, controlled
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`speed, towing the source and receivers. The source is actuated (“fired”) at
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`predetermined timed intervals and the reflected waves are measured by the
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`receivers and recorded.
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`43. The data recorded by each receiver take the form of a seismic trace,
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`which is the basic unit of seismic data. The trace represents the amplitude of
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`signals recorded by a particular receiver over a set period of time. For a given shot
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`location, each receiver records the reflected seismic energy. A collection of traces
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`recorded for one shot point is called a shot record or gather. The time length of
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`recording will vary depending on geologic targets, but is typically between 8 and
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`12 seconds. In conventional surveys, the source is fired only once during each shot
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`record.
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`44. The precise firing times of the source are determined by the amount of
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`time the survey vessel takes to advance a pre-determined distance, often equal to a
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`multiple of the separation between receivers. For example, if the receivers are
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`spaced at 12.5 meters and the vessel moves 2.5 meters per second, the source may
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`be fired every 10, 15, or 20 seconds so that the vessel advances 2, 3, or 4 receiver
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`positions per shot.
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`45.
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`In a conventional survey, each trace corresponds to a single source
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`location and a single receiver location. Thus it takes a source–receiver pair to
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`create a seismic trace. The distance between the source and receiver in a given
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`trace is called offset. In data processing, traces may be sorted by (among other
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`things) offset, source location, receiver location, or the midpoint location between
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`source and receiver.
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`46. One common way to view traces generated by a seismic survey is in
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`the form of a shot gather (also called a shot record or common shot