L. Ikelle
`UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` _____________________________
` WESTERNGECO L.L.C.,
` Petitioner
` v.
` PGS GEOPHYSICAL AS,
` Patent Owner
` _____________________________
` Case IPR2015-00309, 00310, 00311
` Patent U.S. 6,906,981
` _____________________________
`
` DEPOSITION OF LUC IKELLE
` Alexandria, Virginia
` September 3, 2015
`
`Reported by: Mary Ann Payonk
`Job No. 96927
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`TSG Reporting - Worldwide
`(877) 702-9580
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`WesternGeco v. PGS (IPR2015-00309, 310, 311)
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`Page 3
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` L. Ikelle
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` September 3, 2015
` 8:37 a.m.
`
` Deposition of LUC IKELLE, held at the
`offices of Oblon, McClelland, Maier & Neustadt,
`LLP, 1940 Duke Street, Alexandria, Virginia,
`pursuant to Notice before Mary Ann Payonk,
`Nationally Certified Realtime Reporter and
`Notary Public of the District of Columbia,
`Commonwealth of Virginia, States of Maryland
`and New York.
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`Page 4
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` L. Ikelle
`Appearances (Cont'd.)
`ALSO PRESENT:
` Kevin Hart, Petroleum Geo-Services, Inc.
` (By phone)
` Whitney Hermandorfer, Law Clerk
` Williams & Connolly
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` L. Ikelle
`APPEARANCES:
`ON BEHALF OF PETITIONER:
` DAVID KRINSKY, ESQUIRE
` SANJIV LAUD, ESQUIRE
` WILLIAMS & CONNOLLY
` 725 Twelfth Street, N.W.
` Washington, D.C. 20005
`
`ON BEHALF OF PATENT OWNER:
` MICHAEL KIKLIS, ESQUIRE
` CHRISTOPHER RICCIUTI, ESQUIRE
` KATHERINE CAPPAERT, ESQUIRE
` OBLON, McCLELLAND, MAIER & NEUSTADT
` 1940 Duke Street
` Alexandria, VA 22314
`
` SAUNAK DESAI, ESQUIRE
` KIRKLAND & ELLIS
` 601 Lexington Avenue
` New York, NY 10022
`
`Page 5
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` L. Ikelle
`LUC T. IKELLE,
` called as a witness, having been duly
` sworn, was examined and testified as
` follows:
` EXAMINATION
`BY MR. KRINSKY:
` Q. Welcome, Dr. Ikelle.
` A. Thank you.
` Q. Have you been deposed before?
` A. Once, roughly in 2005. 2004, 2005.
`I don't remember exactly but that's a few
`years, yes.
` Q. Was that another case in which you
`were serving as an expert witness?
` A. I was actually helping a lawyer, but
`last minute he asked me to testify, to depose,
`yes. Helping him in understanding the
`technical part of the case.
` Q. Was that a patent case?
` A. No.
` Q. What was the nature of that case,
`just at a general level? What kind of case was
`it? I don't need the details.
` A. Was a dispute about best practices.
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` L. Ikelle
` Q. So you know generally how depositions
`work. I will be asking you questions and
`you're obligated to answer them truthfully.
`You understand that?
` A. Yes.
` Q. Is there any reason why you can't
`testify fully and truthfully today?
` A. Not to my knowledge.
` Q. You're not under the influence of any
`medication or alcohol that would interfere?
` A. I don't drink alcohol so we're safe
`on that.
` Q. Okay. And you're safe on medication
`as well? Nothing that would interfere with
`your ability to testify?
` A. As far -- I don't, correct.
` Q. Okay. I note you have a stack in
`front of you. Do you already have in front of
`you the De Kok patent, which is Exhibit 1003?
`If not, I'll be happy to give you a copy.
` A. No, I didn't have the De Kok here.
`Thank you.
` Q. You're welcome. Just to clarify for
`the record as well, I will be using exhibit
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`Page 8
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` L. Ikelle
` A. Yes.
` Q. And you mentioned polarization of
`sources. Can you explain what you meant by
`that and what you're referring to in the
`figure?
` A. I'm referring to S1 and S2.
` Q. And S1 is -- S1 corresponds to source
`1; correct?
` A. To the polarization of source 1.
` Q. When you say "polarization of source
`1," what do you mean by that?
` A. Are you asking me to define the word
`"polarization"?
` Q. As relevant to the seismic survey
`depicted in figure 2.
` A. Polarization here means like 1, minus
`1 and 0. Polarization here means that you're
`going to -- the signal will take three values,
`minus 1, 1, and 0.
` Q. And the graph S1 refers -- depicts
`the polarization as a function of time of the
`signal emitted by source 1; correct?
` A. I did not get the question, please.
`Repeat it again.
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` L. Ikelle
`numbers without specifying an IPR. I believe
`they are, with limited exceptions that I'll
`call out, identical across the -- the three IPR
`proceedings that relate to the '981 patent.
`That's IPR2015-039, 310, and 311. And that's
`what we're here today to talk about. We will
`start again tomorrow with the remaining IPR.
` So this is Exhibit 1003, the De Kok
`patent. Have you seen this before, Doctor?
` A. Yes, I did.
` Q. This is one of the references on
`which you rely in this case; correct?
` A. Yes.
` Q. Could you please turn in the De Kok
`patent to sheet 2 of 6, which is figure 2?
` A. Yes.
` Q. Could you just describe for me what
`is depicted in figure 2, please? Explain what
`the figure means.
` A. It's showing a boat, a seismic type
`of boat, two sources, and an array of receivers
`207, and two polarizations of sources.
` Q. And the sources here are 203 and 205;
`is that right?
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`Page 9
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` L. Ikelle
` Q. The top line labeled S1?
` A. Yes.
` Q. That depicts the polarization of
`source 1 as a function of time?
` A. No, that depict the claim, the form
`of polarization that will be associated with
`source 1.
` Q. Okay. And so I -- I'm not sure
`whether we're agreeing or disagreeing because I
`didn't fully understand your answer. Does
`that -- does this top line depict as a function
`of time the polarization of the signal that
`source 1 is emitting?
` A. No, it give you the -- the
`indications of how the polarization will be for
`that source. There's no time there. There's
`axis of time, but there is no numbers.
` Q. Okay. I see. The axis of time. But
`at -- in the survey contemplated by figure 2,
`source 1 and source 2 are fired simultaneously
`and repeatedly; is that right?
` A. If you want to discuss that, probably
`it's effective to go back to figure 1.
` Q. Okay. So does -- do figure 1 and
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`

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`Page 10
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` L. Ikelle
`figure 2 depict the same survey?
` A. This is not a survey.
` Q. Or the same example. The same
`embodiment of De Kok's invention?
` MR. KIKLIS: Objection, form.
` A. What he's showing here, you can call
`that a source that he's going to use. That's
`what's depicted, the wave he's going to
`generate -- what he's describing here or
`showing in this picture, not describing --
`because the picture only shows, not describe --
`what the picture is showing is the system that
`he's going to use to generate waves.
`BY MR. KRINSKY:
` Q. And in the system -- when you say
`"the system that's used to generate waves,"
`you're referring to the combination of sources
`1 and 2?
` A. Yes.
` Q. And sources 1 and 2 in the example of
`figure 2 are being towed by a boat; right?
` A. Yes.
` Q. And the same boat is towing the
`seismic streamer labeled 207; correct?
`
`Page 12
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` L. Ikelle
`2, uh-huh, yes.
` Q. It says: "Figure 2 shows the
`sequences of two sources firing simultaneously
`with polarity coding."
` Do you see that?
` A. Yes, that's correct.
` Q. And then a little while -- a few
`sentences later, it says that figure 2 shows a
`source vessel 201 towing sources 203 and 205.
` A. Yes.
` Q. That's the boat and the sources we
`were just talking about; right?
` A. Yes.
` Q. And then it says that the source
`vessel may also tow a streamer containing
`sensors for receiving source signals, for
`example, streamer 207; correct?
` A. That's correct.
` Q. So 207 refers to a streamer?
` A. All of them are caveat with examples,
`therefore, it's -- he has in mind something
`more general than that, but I accept the
`streamer would be one scenario.
` Q. No, I understand it. I'm trying to
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` L. Ikelle
` A. I'm not sure that it define it like
`streamer. Probably define like an array of
`sensor.
` Q. Let me turn you to column 4 of the
`patent, which talks about figure 2. That may
`help you out.
` A. Okay. Thank you. Column 4.
` Q. So figure 2 -- I'm looking at line 28
`of column 4. Are you with me?
` A. Line which one again?
` Q. 28.
` A. 28.
` Q. It's a paragraph that begins with
`"figure 2."
` A. Oh, figure 2, yes.
` Q. Okay. And as this paragraph
`indicates, figure 2 shows the sequences of two
`sources firing simultaneously with polarity
`coding; correct. That's what it says?
` A. Figure 2. You're reading the brief
`descriptions?
` Q. No, sir, I'm looking at column 4 on
`the right-hand column.
` A. Oh, the caption is there. So figure
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` L. Ikelle
`understand his examples so that I can try to
`understand --
` A. Sure.
` Q. -- your opinions about his invention.
`I recognize that this isn't the only example of
`his invention.
` MR. KIKLIS: Objection, form,
` foundation.
`BY MR. KRINSKY:
` Q. So in the graph of figure 2 -- or in
`the example of figure 2, the signals emitted by
`source 1 and source 2 are encoded using
`polarity. Is that right?
` A. One of the component of the encoding
`of the sources here is polarization, one of the
`component. The time delay is not a component.
` Q. Okay. Is there a time delay
`associated with the encoding in figure 2 in
`your opinion?
` A. No. Let me just rephrase you. What
`he's trying to show here, I mentioned at the
`beginning, is that what it is showing here is
`the code polarization only.
` Q. Right.
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` L. Ikelle
` A. But this picture isn't describe the
`whole story.
` Q. But the description at column 4, line
`28 says that the two sources are firing
`simultaneously.
` Do you see that?
` A. Column 4. What are we talking about
`here? We are --
` Q. Again, line 28, column 4.
` A. Oh, 28 again? Okay.
` (Discussion held off the record.)
` A. Okay. So we are talking about 28,
`page 6; is that correct?
`BY MR. KRINSKY:
` Q. And I apologize, I'm used to column
`numbers because I'm a patent lawyer.
` A. Okay.
` Q. Would it be easier for you if I use
`the page number at the bottom?
` A. That's -- I have to adopt your
`method. I just have to learn quickly.
` Q. Sure. So in the right-hand column at
`the bottom labeled page 9, the top of the
`column.
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` L. Ikelle
`sources. It -- each source simultaneously
`emits a polarity encoded signal. Is that
`understanding correct or is that understanding
`incorrect in your opinion?
` A. Is incomplete.
` Q. Okay.
` A. Because scientifically, you make
`diagrams to be clear. This is not an example.
`This is diagrams.
` Q. Okay.
` A. And diagram objective is to make it
`clear and also draw the point that are
`significantly new -- difficult to capture.
`Time delay, you don't need to really draw that
`as such. It's not necessary. You've made the
`picture unnecessarily complicated.
` Q. So you referred to time delay.
` A. Yes, sir.
` Q. And can you explain what time delay
`means in this context?
` A. Let me start by saying one thing
`clear. We have the firing times because we
`have more than two sources. We have more than
`one source. And so I'm going to fire source 1,
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` L. Ikelle
` A. Page 9?
` Q. At the top of the column, there's a
`4.
` A. 9?
` Q. So --
` A. Oh, it's page below that. Okay. I
`found the page. So here, you're going to call
`these pages, and this one, you call these
`columns.
` Q. That's correct, sir.
` A. Okay, thank you. So what, page, 9,
`line 28?
` Q. Right. In the right-hand column,
`which is labeled column 4.
` A. Okay.
` Q. And it says that figure 2 shows the
`sequences of two sources firing simultaneously
`with polarity coding.
` Do you see that?
` A. Yes.
` Q. Okay. And my understanding of this
`figure is that unlike some of the other
`examples that we will look at shortly, this
`example does not use time delay as between the
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` L. Ikelle
`fire source 2. If they're not fired the same
`time, differences between these two firing
`times are the time delay.
` Q. So that the time delay is the period
`of time between when source 1 fires and source
`2 fires. Or if you have more sources, it could
`be between two other sources. But in this
`example with two sources, it would be the time
`between source 1 and source 2's firing?
` A. I prefer that you stick with my
`language, which is that I fire source 1 and I
`fire source 2. The time difference between the
`two is the time delay.
` Q. I think that's what I just said, but
`I will endeavor to use your language.
` Column 4 says that figure 2 shows the
`sequences of two sources firing simultaneously.
`What you're telling me is that notwithstanding
`what column 4 says, those sources are not
`firing simultaneously; they're firing with a
`time delay.
` MR. KIKLIS: Objection, misstates.
` A. So we are reading 28, yeah?
`BY MR. KRINSKY:
`
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` Q. Yeah.
` A. Yeah. My understanding is that there
`are two -- we call that encoding processes
`going on here. And try to explain them one
`step at a time. And so you have polarities,
`you have time delays.
` Q. Okay. And so your understanding is
`that the statement in column 4 that the two
`sources firing simultaneously is inaccurate?
` A. No, is not the final -- is not the
`final picture of the story.
` Q. Okay. Well, are the sources firing
`simultaneously if there is a nonzero time
`delay?
` A. That's a possibility, yes.
` Q. How would they be firing
`simultaneously?
` A. What?
` Q. How are they firing simultaneously if
`there is some time between when one source
`fires and when the other source fires?
` A. That is why we use the term "near
`simultaneously" in this phase, especially when
`you include time delay encoding.
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` L. Ikelle
` Q. I'll try to make this clearer. The
`time axis --
` A. Yes.
` Q. -- shows a series of successive near
`simultaneous firings of sources 1 and 2;
`correct?
` A. No. That figure shows polarity of
`the sources.
` Q. Right.
` A. Doesn't show any shooting.
` Q. Okay. But the polarity that it shows
`is for a sequence of multiple near simultaneous
`activations; correct?
` A. Yes. A polarity here is associated
`with each sources.
` Q. Okay. And the -- in -- first, source
`1 and source 2 fire so that they both have a
`positive polarity; correct?
` A. Repeat that again, please.
` Q. First, source 1 and source 2 fire so
`that they both have positive polarity; correct?
` A. You are talking about the first --
`the first instance. In other words, there is
`something here that you're missing, counsel, is
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` L. Ikelle
` Q. I see. So your understanding is that
`when he says simultaneously in column 4, he
`means near simultaneously?
` A. Yes, actually, in this paper, in this
`particular patent, he -- he did not bother by
`put in near simultaneously, except maybe
`there's one place where I -- I miss -- I
`forget, but most of the time, he tend to use
`simultaneously as a -- uh-huh.
` Q. Okay. And each -- I know there are
`no numerical units of time --
` A. Yes.
` Q. -- in figure 2.
` A. Yes.
` Q. But you see there's a pattern of
`vertical lines in both the source 1 and the
`source 2 graphs.
` A. Yes.
` Q. And at each of those vertical lines,
`source 1 and source 2 fires near
`simultaneously; correct?
` A. You're asking two question here. You
`talk about vertical lines and then you move to
`simultaneously. I'm lost.
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` L. Ikelle
`that polarity here doesn't means the source.
`This is a time, specific time that we're
`talking about.
` Q. Maybe -- would this be clearer if I
`referred to figure 5A? Is that depicting the
`time delays that you're thinking about?
` A. No, actually what I was trying to
`help you here --
` Q. Yeah.
` A. -- is that when you see some of these
`boxes --
` Q. Yeah.
` A. -- don't read them like source. They
`are not sources. The sources have a duration,
`and sometime I start with T zero, this is
`polarity, so forth. Okay, well, sorry about
`that. I should not be doing this, but let's
`try --
` Q. No, this is helpful. I'm trying to
`understand your opinions, Doctor. So this is
`helpful.
` A. Yeah, I know.
` Q. If we call -- just can we agree for
`clarity's sake, going back to -- are you now on
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` L. Ikelle
`figure 5A?
` A. Yes, uh-huh, 5A.
` Q. Why don't we discuss figure 5A, then
`we can perhaps come back to figure 2?
` A. Uh-huh.
` Q. On figure 5A, can you just explain --
`why don't you explain in your words rather than
`my trying to put words into your mouth, what
`figure 5A is depicting?
` A. I'm going to start by defining
`seismic survey quickly for this. The method of
`shooting. TD1 is one source that generate wave
`and get -- and TD2 is another source that
`generate wave. And therefore, here, we are
`really not talking about multiple shooting. We
`are talking about single shooting. And 1, 2, 3
`are sequences or, if you want to use De Kok
`language, you call that shots.
` Q. Okay. And so if we look at source
`TD1, the line that's depicted 501, what does
`501 depict in this context?
` A. Is a shot.
` Q. And there's a vertical line going up
`at time tr equals 0 and a vertical line going
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`there being a line that goes up followed by a
`line that goes down as it relates to De Kok's
`invention?
` A. Indicate two things. Indicate the
`polarity. Indicate a time delay.
` Q. And the polarity is -- why is the
`polarity downward in all of these graphs after
`the polarity upward?
` A. He just decided to use that, to
`discretion.
` Q. Does the downward signal indicate --
` A. Different polarities.
` Q. Let me finish my question.
` A. Sorry.
` Q. Does the downward signal indicate a
`ghost?
` A. That's one possibility, yes. Your
`ghost is a seismic event.
` Q. And ghosts -- ghosts have the
`opposite polarity of the signal before it's
`reflected.
` A. Not -- no, sir. That is a very
`specific word you're saying there.
` Q. Okay.
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`down, what looks like just after that, 501.
`Could you please explain the significance of
`that?
` A. I did not get that. Do you mean the
`vertical line?
` Q. Uh-huh.
` A. These are schematic diagrams, and
`therefore, they're not representing reality.
`They just give you an idea what happened. The
`vertical line here is not described. But I can
`help you by saying this indicate time and
`amplitude, roughly.
` Q. And -- okay. You say it indicates
`time and amplitude?
` A. No, there are two vertical lines. If
`you are looking at the pulses, there's
`amplitude.
` Q. The way I read 501 is that there is a
`line going up at tr equals 0.
` A. Yes.
` Q. And there's a line down at some time
`shortly after that?
` A. Oh, yes, that's amplitude.
` Q. Right. What's the significance of
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` A. It's one particular case that can
`contain, but no, in general, no.
` Q. Okay. Can you explain the particular
`case, then?
` MR. KIKLIS: Objection, form.
` A. So there are three type of ghosts.
`There is a ghost from the source side and a
`ghost from the receiver side. And there is a
`third ghost where you have ghost from source
`side and ghost from the receiver side.
`BY MR. KRINSKY:
` Q. And the third ghost is when you have
`a reflection at both the source and the
`receiver side?
` A. Yes.
` Q. Is the ghost that's relevant here the
`source side ghost or the receiver side ghost,
`or the third possibility?
` A. I did not see that -- that
`description necessary for my analyses so I did
`not assign that ghost a particular meaning.
` Q. Okay. But the second line, the
`right-hand line in 501 refers to a ghost that
`is of negative polarity?
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` A. It refer to a seismic event of
`negative polarity.
` Q. Okay. And the vertical line is a
`seismic event of positive polarity -- the
`upward line. Excuse me.
` A. Actually, I have to take back my
`answer. I'm speculating here. You have to
`define what positive, negative in this picture
`before you assign. I just made the convention
`that they usually use, but no, I did not do --
`my answer is not correct. I don't know what is
`the positive and what is the negative, so I
`cannot assign the sign of the polarization.
` Q. Okay. So if by convention we say
`that up is positive and down is negative, the
`upward line is an event of positive polarity
`that is followed by an event of negative
`polarity?
` A. I agree with you if you -- based on
`that convention.
` Q. And in the example that De Kok is
`describing here, 501 and 511 represent the two
`events that are simultaneous; right?
` A. As I mention early -- sorry, were you
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` Q. And similarly, 507, they're both down
`at the reference time. 507 and 517.
` A. Yes.
` Q. And in figure 5B, De Kok discloses a
`way of separating source signals arising from
`TD1 and TD2 by summing these signals in a
`particular way; correct?
` A. Yes, but you went too fast, I guess,
`in the sense that he is not using this data.
`He's going to combine them at some point. He's
`going to do a multi-shooting, a multiple
`shooting. As I mentioned early, figure 5, the
`top one is a single shooting. The bottom is
`single shooting. So therefore, you are not in
`a multi-shooting or simultaneous mode yet.
` Q. So --
` A. Then you start going to the decoding.
` Q. In other words, 501 represents the
`energy from a single source.
` A. Exact.
` Q. And 511 represents the energy from a
`different source, the second source?
` A. Yes.
` Q. And De Kok teaches putting that
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`finished?
` Q. Yes.
` A. As I mentioned early, this is not
`simultaneous shooting that picture. This
`picture is not simultaneous shooting. So
`analyzing it as simultaneous shooting, we're
`going in wrong directions.
` Q. I'm trying to understand what De Kok
`teaches as relevant to your invention here.
`De Kok -- sorry, that was -- strike that. That
`wasn't what I meant to say.
` I'm trying to understand what De Kok
`teaches as relevant to your opinions here. 501
`and 511 both have an upward signal at the same
`reference time, tr equals 0; correct?
` A. That's correct.
` Q. And in contrast, 503 and 513 have --
`503 has an upward signal and 513 has a downward
`signal at that -- at reference time tr equals
`0. Right?
` A. Yes.
` Q. Similarly, 505 and 515 -- 505 is
`down, 515 is up at the reference time.
` A. Yes.
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`source energy 501 and that source energy 511
`into the water simultaneously?
` (Discussion held off the record.)
`BY MR. KRINSKY:
` Q. Rather than my repeat the question
`that got interrupted, why don't I ask a
`predicate question. We will try to take this
`step by step. You referred to single shooting
`and contrasted it with multi-shooting.
` A. Yes.
` Q. Can you explain what you mean by each
`of those concepts?
` A. There is nothing special in my
`definition. I said multiple shooting, that
`means I'm going to shoot from multiple
`locations. Single shooting, I'm going to shoot
`from one location at a time. Or if you want me
`to help you a bit more, single shooting is the
`current convention, and multi-shooting,
`multiple shooting is what we're talking about
`here.
` Q. So De Kok contemplates the single
`shot 501 and the single shot 511 being
`initiated with no relative time delay between
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`the two of them; correct?
` A. That's correct.
` Q. And that's why they're both labeled
`with a 1?
` A. Yes.
` Q. And similarly, 503 and 513 are
`initiated with no relative time delay and
`that's why they're both labeled with a 2?
` A. There's a time delay there I'm
`reading, no?
` Q. I apologize. The tr dashed line, tr
`equals 0 is the same in 513 and 503. The
`reference time in 503 and 513 is the same time;
`correct?
` A. We're in physics here. We are always
`going to define a reference. Life goes on
`forever. We start at this -- today we call
`that T0. That's the convention. I say this
`geographic -- GPS, this geographic location is
`reference to somebody -- something. Always
`have that. You will decide about where we
`start. So that's T0. I don't know why you add
`that T there. This is just my definitions.
`It's just a definition. It's free to decide
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` A. No, it's not a distraction, it's a
`convention in physics. Sorry, I'll let you
`finish.
` Q. What De Kok contemplates is that the
`source activation in 513 comes before the
`source activation in 503; correct?
` A. Yes.
` Q. And there's some -- the relative --
`excuse me, the time delay between those
`activations is such that the negative polarity
`signal in 513 corresponds with the positive
`polarity signal in 503.
` A. I agree with that.
` Q. And similarly, the negative polarity
`signal -- in 505 and 515, there's a time delay
`in the other direction, TD1 precedes TD2;
`correct?
` A. Yes.
` Q. Such that the negative polarity
`signal and the positive -- excuse me, the
`negative polarity signal in 505 and the
`positive polarity signal in 515 correspond;
`correct?
` A. Well, counselor, I did not completely
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`what T0 mean.
` Q. But in 511 and 501, you agreed with
`me that the -- there was no time delay between
`those source initiations?
` A. I already say yes.
` Q. Right. And in 503 and 513, there is
`a time delay but the reference time depicted
`here in figure 5A is the same, so that the
`upward spike in 503 is at the same time as the
`downward spike in 513; right?
` A. Okay.
` Q. Is that your understanding of this
`figure?
` A. I mean, as a scientist I would never
`talk about tr in this process, because I just
`defined my -- I just defined a reference point.
`I never touched it again. That would be the
`reference for all my figures and everything.
`So that's a convention in physics. That has
`nothing to do with this patent, I mean. I'm a
`little bit lost there what you -- where we're
`going with that tr.
` Q. Okay. If tr is a distraction, let me
`see if I can rephrase.
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`agree with you. You are looking at this
`picture with a mindset of polarity. If you
`disconnect the time here, you are missing the
`key information. Both are -- this picture
`include polarity and time delay.
` Q. And the -- right, but the time delay
`in 505 and 515, or the time delay between the
`source activation depicted in 505 and the
`source activation depicted in 515 is chosen so
`that the negative polarity signal in 505 occurs
`at the same time as the positive polarity
`signal in 515. Yes?
` A. Yes.
` Q. I know you're already keeping track
`of a lot but when you simply nod, the court
`reporter can't report it.
` A. I said yes.
` Q. I understand.
` A. Uh-huh.
` Q. And in 507 and 517, there is again no
`time delay?
` A. Yes.
` Q. And if 501 and 511 are fired
`simultaneously -- strike that.
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` What De Kok teaches is, among other
`things, is that one can activate this sequence
`of -- I hesitate to use the word sequence
`because I know it's a term that we will run
`into again, but there's a series of
`simultaneous or near simultaneous activations
`of sources TD1 and TD2 contemplated here;
`correct?
` A. So if we stick with De Kok, what
`De Kok call this is shots.
` Q. Okay.
` A. And basically, what he's showing here
`is that your time delay can vary from one shot
`to another, from one shot to another. In other
`words, you go back to language of sequence and
`will be variation from one sequence to another.
`That's what he teach here, teaches here.
`That's what De Kok teach here. Teaches here.
`Sorry about that.
` Q. Okay. And De Kok -- looking at 5A
`together with 5B and 5C, De Kok contemplates
`using -- repeatedly firing both sources TD1 and
`TD2; correct?
` A. I did not get that, please.
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`can possibly decide about his encoding and
`decoding based on polarity and time delay
`simultaneously, so that -- in other words,
`De Kok is trying to do this. He's going to say
`I'm going to use my polarity, I'm going to have
`time delay to decode multiple shotting
`result -- response of multiple shooting. So
`here, the illustration where he say that, if I
`consider four shots, this is what I can get.
` Q. Okay. So you