`
`———————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————————
`
`WESTERNGECO L.L.C.,
`Petitioner
`
`v.
`
`PGS GEOPHYSICAL AS,
`Patent Owner
`
`———————————
`
`Cases
`IPR2015-00309 (U.S. Patent No. 6,906,981)
`IPR2015-00310 (U.S. Patent No. 6,906,981)
`IPR2015-00311 (U.S. Patent No. 6,906,981)
`
`———————————
`DECLARATION OF SIMEON G. PAPACOSTAS
`
`
`
`Pursuant to 28 U.S.C. § 1746, I, Simeon G. Papacostas, the undersigned,
`
`hereby declare as follows:
`
`1.
`
`My name is Simeon G. Papacostas. I am over eighteen years of
`
`age, of sound mind, and in all ways qualified and competent to make this
`
`declaration. I have personal knowledge of the facts contained in this declaration
`
`and they are true and correct.
`
`2.
`
`I am a partner in the law firm of Kirkland & Ellis, L.L.P.,
`
`counsel for WesternGeco L.L.C. ("WesternGeco").
`
`WesternGeco Ex. 1020, pg. 1
`WesternGeco v PGS
`IPR2015-00310
`
`
`
`3.
`
`I am a member in good standing of the Bar for the State of New
`
`York.
`
`4.
`
`I am not currently suspended or disbarred from any court or
`
`administrative body.
`
`5.
`
`I have not been denied admission to any Bar, court, or
`
`administrative body.
`
`6.
`
`I have not been sanctioned or held in contempt by any court or
`
`administrative body.
`
`7.
`
`I have read and will comply with the Office Patent Trial
`
`Practice Guide and the Patent Trial and Appeal Board’s Rules of Practice.
`
`8.
`
`I agree to be subject to the USPTO Rules of Professional
`
`Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under
`
`37 C.F.R. § 11.19(a).
`
`9.
`
`I have been practicing patent law since my admission to the bar
`
`in 2009, over six years ago.
`
`10.
`
`I have been involved in numerous litigations involving patent
`
`infringement in district courts across the country and at the Court of Appeals for
`
`the Federal Circuit.
`
`WesternGeco Ex. 1020, pg. 2
`WesternGeco v PGS
`IPR2015-00310
`
`
`
`11.
`
`I have been representing WesternGeco with respect to seismic
`
`exploration technology and patents for over five years, and with respect to the
`
`above-captioned patent for over two years.
`
`12.
`
`13.
`
`I have extensive experience with U.S. Patent No. 6,906,981.
`
`I have represented WesternGeco in the following federal district
`
`court litigation where Petroleum Geo-Services, Inc. ("PGS") asserted the above-
`
`captioned patent: WesternGeco L.L.C. v. Petroleum Geo-Services, Inc. and PGS
`
`Geophysical AS, Civ. No. 4:13-cv-02725 (S.D. Tex.) ("the PGS Litigation").
`
`14.
`
`I have also represented WesternGeco with respect to U.S.
`
`Patent No. 5,924,049 ("Beasley") and U.S. Patent No. 6,545,944 ("de Kok"), on
`
`which inter partes review was instituted for the ‘981 patent, in the following
`
`district court litigation: WesternGeco L.L.C.v. Multi Klient Invest AS, Petroleum
`
`Geo-Services, Inc., and PGS Geophysical AS, Civ. No. 4:14-cv-03118 (S.D. Tex.)
`
`("the Multi Klient Litigation").
`
`15. More broadly, I have represented WesternGeco regarding
`
`seismic exploration technology in numerous district court, Federal Circuit, and
`
`Patent Office proceedings: WesternGeco L.L.C. v. ION Geophysical Corp., et al.,
`
`Civ. No. 4:09-cv-01872 (S.D. Tex.) ("the ION Litigation"); WesternGeco L.L.C. v.
`
`Fugro-Geoteam, Inc., Fugro-Geoteam AS, Fugro Norway Marine Services AS,
`
`Fugro, Inc., Fugro (USA), Inc., and Fugro Geoservices, Inc., Civ. No. 4:10-cv-
`
`WesternGeco Ex. 1020, pg. 3
`WesternGeco v PGS
`IPR2015-00310
`
`
`
`02120 (S.D. Tex.) ("the Fugro Litigation"); and WesternGeco L.L.C. v. Polarcus
`
`US Inc. and Polarcus Ltd., Civ. No. 4:13-cv-02385 (S.D. Tex.) ("the Polarcus
`
`Litigation").
`
`16.
`
`The PGS Litigation was filed in 2013 and the Multi Klient
`
`Litigation was filed in 2014.
`
`17.
`
`18.
`
`19.
`
`The PGS Litigation and the Multi Klient Litigation are ongoing.
`
`I am familiar with the patent at issue and its field of technology.
`
`I have been involved in all aspects of the PGS Litigation and
`
`the Multi Klient Litigation that have taken place so far.
`
`20.
`
`I hereby declare that all statements made herein of my own
`
`knowledge are true and that all statements made on information and belief are
`
`believed to be true; and further that these statements were made with the
`
`knowledge that willful false statements and the like so made are punishable by fine
`
`or imprisonment, or both, under Section 1001 of Title 18 of the United States Code
`
`and that such willful false statements may jeopardize the results of these
`
`proceedings.
`
`21.
`
`I declare under penalty of perjury that the foregoing is true and
`
`correct.
`
`
`
`WesternGeco Ex. 1020, pg. 4
`WesternGeco v PGS
`IPR2015-00310
`
`
`
`October 1, 2015
`Chicago, IL
`
`Simeon G. Papa^ostas
`
`5
`
`WesternGeco Ex. 1020, pg. 5
`WesternGeco v PGS
`IPR2015-00310
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