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 No. IPR2015-00313
` Patent 6,026,059
` _______________
` Oblon Docket No.: 439520US
`
` DEPOSITION OF WALTER S. LYNN, Ph.D.
` Washington, D.C.
` Friday, November 6, 2015
`
`Reported by: John L. Harmonson, RPR
`Job No: 99583
`
`TSG Reporting - Worldwide - 877-702-9580
`
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`WesternGeco Ex. 1030, pg. 1
`WesternGeco v PGS
`IPR2015-00313
`
`

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`Page 2
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`Page 3
`
` A P P E A R A N C E S
`
`On Behalf of the Petitioner:
` OBLON McCLELLAND MAIER & NEUSTADT
` 1940 Duke Street
` Alexandria, VA 22314
` BY: MICHAEL KIKLIS, ESQ.
` CHRISTOPHER RICCIUTI, ESQ.
` - and -
` KIRKLAND & ELLIS
` 601 Lexington Avenue
` New York, NY 10022
` BY: TIMOTHY GILMAN, ESQ.
` SAUNAK DESAI, ESQ.
`
`On Behalf of the Patent Owner:
` WILLIAMS & CONNOLLY
` 725 Twelfth Street
` Washington, DC 20005
` BY: DAVID KRINSKY, ESQ.
` CHRISTOPHER SUAREZ, ESQ.
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` November 6, 2015
` 8:57 a.m.
`
` Deposition of WALTER S. LYNN, Ph.D., held at
`the offices of Williams & Connolly, 725
`Twelfth Street, Washington, D.C., pursuant to
`Notice, before John L. Harmonson, a Registered
`Professional Reporter and Notary Public of the
`District of Columbia, who officiated in
`administering the oath to the witness.
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`Page 4
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` W. LYNN
`--------------------------------------------------
` P R O C E E D I N G S
` 8:57 a.m.
`--------------------------------------------------
` Whereupon,
` WALTER S. LYNN, Ph.D.,
` after having been first duly sworn or affirmed,
` was examined and did testify under oath as
` follows:
` EXAMINATION
` BY MR. GILMAN:
` Q. Welcome back, Dr. Lynn. It's good to
` see you again.
` A. Good morning.
` Q. So we just had another deposition two
` days ago, so I won't spend a lot of time going
` through the procedure. But I want to ask if you
` have any questions since we last met about the
` deposition or the questions and the answers of
` the process for today.
` A. No.
` Q. Is there any reason why today you
` would be unable to give full, fair and accurate
` answers to my questions?
`
`Page 5
`
` W. LYNN
` A. No reason.
` Q. Did you get to do anything fun in the
`interim day yesterday?
` A. A short walk.
` Q. Did you meet with your counsel again
`yesterday?
` A. I did.
` Q. Who did you meet with?
` A. Mr. Krinsky, Mr. Suarez.
` Q. Was anybody else present when you met?
` A. No.
` Q. Did you meet here in Williams &
`Connolly's offices?
` A. We did.
` Q. How long did you meet for?
` A. It started at roughly 9:30 and went to
`4:30, 5:00 o'clock.
` Q. And the purpose of that meeting was to
`get ready for today's deposition?
` A. Yes.
` Q. Did you review any documents during
`your meeting yesterday?
` A. Certainly.
` MR. GILMAN: I would like to start by
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`2 (Pages 2 to 5)
`TSG Reporting - Worldwide - 877-702-9580
`
`WesternGeco Ex. 1030, pg. 2
`WesternGeco v PGS
`IPR2015-00313
`
`

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`Page 6
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` W. LYNN
` giving you a copy of what's been previously
` marked as Exhibit 2037, a copy of your
` declaration regarding the '059 patent.
` (PGS Exhibit 2037, previously marked
` for identification, is attached hereto.)
` MR. KRINSKY: And I would like to
` observe for the record and for the benefit
` of the court reporter that the exhibit
` numbering today is discontinuous from the
` exhibit numbering on Wednesday and the
` caption is different. This is the 313
` proceeding.
` MR. GILMAN: I think we hopefully have
` it all straight but definitely during the
` break I will make sure all that is clear on
` the record.
` MR. KRINSKY: Since we didn't do
` introductions and we didn't have a
` videographer, at the beginning I just wanted
` to note that for the record.
`BY MR. GILMAN:
` Q. Is Exhibit 2037 a copy of your report
`in this matter concerning the '059 patent?
` A. It is.
`
`Page 8
`
` W. LYNN
` Q. The patent owner's response that PGS
`submitted in these proceedings?
` A. That's correct. I had not seen that
`before.
` Q. There was a time when you worked at
`PGS as well; is that correct?
` A. That's correct.
` Q. How long did you work for PGS?
` A. I began in 1993, and I left PGS in
`2002.
` Q. So about a decade of working for PGS?
` A. Correct.
` Q. Do you still have friends, PGS people,
`that you see?
` A. I had friends at PGS, but no one that
`I see on any routine basis. At conferences I
`will chat with them, but no regular business at
`all with them.
` Q. Who is still at PGS that you still run
`into?
` A. Well, we recently had -- we, the
`Society of Exploration Geophysicists -- recently
`had their annual conference in New Orleans. And
`at that conference, PGS, along with many other
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`Page 7
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` W. LYNN
` Q. If you turn to the last page of the
`exhibit, is that your signature on page 88?
` A. It is.
` Q. And did you review this document,
`Exhibit 2037, before you signed it?
` A. I did.
` Q. To make sure that it was accurate and
`complete?
` A. Absolutely.
` Q. And you signed it on or about October
`2, 2015?
` A. Correct.
` Q. In terms of your preparations
`yesterday, other than this declaration,
`Exhibit 2037, and the materials that you cite
`therein, did you look at any other documents to
`prepare for today?
` MR. KRINSKY: And you can answer that
` question yes or no.
` THE WITNESS: I don't think there are
` any other documents. I did review one
` additional document that would be the patent
` owner's response which uses my declaration.
`BY MR. GILMAN:
`
`Page 9
`
` W. LYNN
`companies, exhibited. I spent some time there at
`their booth.
` One person I visited with is a fellow
`named Magne Reiersgard, a Norwegian fellow.
`Another fellow was Steve Pitman. Magne works in
`the Houston office; he's very senior in the
`company. Steve Pitman works in the London
`office.
` Q. Other than those two gentlemen, are
`there other people from PGS that you see
`periodically?
` A. No. And when you say "periodically,"
`I want to emphasize that this is a once a year
`renewal of friendships, just catching up with one
`another.
` Q. Do you usually go to SEG each year?
` A. Yes. I went to my first SEG in 1975.
`I've been to every one since. I don't know if
`that's a record because they don't take
`attendance, but that's 41 in a row.
` Q. I've been to one, so you've got me
`beat.
` A. Okay.
` Q. Are there other conferences that you
`
`3 (Pages 6 to 9)
`TSG Reporting - Worldwide - 877-702-9580
`
`WesternGeco Ex. 1030, pg. 3
`WesternGeco v PGS
`IPR2015-00313
`
`

`
`Page 10
`
` W. LYNN
`go to in the seismic industry?
` A. A few. Denver -- in the Denver area
`there is a -- there is a local Geophysical
`Society called the Denver Geophysical Society.
`They have a monthly luncheon with a technical
`speaker. When I'm in Golden during the, say, mid
`August, mid December when I'm teaching at the
`Colorado School of Mines, I often go to those
`events. That's a networking opportunity.
` I am a consultant, and that's just how
`my wife and I make our living. And also at our
`point in our careers we have many friends.
` Also, that society, we call it the
`DGS, for the Denver Geophysical Society, they
`cohost an annual conference with the Rocky
`Mountain Association of Geologists known as RMAG.
`That is a one-day event called the 3-D symposium.
`That's generally held in February, March of each
`year, and for the last several years I've
`attended that one. Not every year but in terms
`of regular.
` And really no others at this point in
`my career. I don't feel the need to travel.
` Q. Do you ever go to EAGE?
`
`Page 12
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` W. LYNN
`But typically at an SEG the attendance is on the
`order of 5000 to 9000 people. The society as a
`whole has -- when I was president, it had
`30,000-plus members. It's a worldwide society.
` Q. Is it mostly exploration companies?
`Do the oil majors tend to go as well? In terms
`of the industry, what level of the industry tends
`to attend these conferences?
` A. Certainly oil company representatives.
`Portions of academia, students that are studying
`science relevant to the SEG. Contractors such as
`PGS and WesternGeco and others. It's a very good
`conference.
` Q. How did you end up getting involved in
`this case? How did you end up hearing about it
`or being retained for this case?
` MR. KRINSKY: I'll just caution you
` not to reveal the specifics of any
` conversations with counsel.
` THE WITNESS: I was contacted by
` Williams & Connolly.
`BY MR. GILMAN:
` Q. So it wasn't somebody at PGS who you
`knew who approached you? It was the lawyers who
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` W. LYNN
` A. I have. I haven't been to EAGE since
`likely 2002. I was president of SEG from 2001 to
`2002, and I'm sure I was at EAGE in that year. I
`have not been back to the EAGE since.
` Q. Would you say SEG is the biggest
`conference in the seismic industry?
` A. In exploration seismology. There are
`other branches of seismology, but for our
`profession it is definitely the biggest.
` Q. When you say "exploration seismology,"
`what do you mean by that? What's that
`limitation?
` A. The application of seismology for
`exploring the earth, in our case for
`hydrocarbons. It could be used for other things.
` Q. So SEG is the biggest conference for
`seismic exploration for hydrocarbons, for oil?
` A. Right. There are smaller parts of
`SEG, but that's the main part of SEG.
` Q. And I think you said earlier a lot of
`people tend to go to the SEG conferences, set up
`booths?
` A. Yes. I'm not in the thick of things
`anymore since I've left the executive committee.
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`Page 13
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` W. LYNN
`first reached out to you?
` A. I've never spoken to anyone at PGS
`about this case.
` Q. You mentioned before the consulting
`that you do with your wife. Is that Lynn, Inc.?
` A. That is Lynn, Inc., yes.
` Q. Is it just you and your wife or are
`there other people who are also part of Lynn,
`Inc.?
` A. It's just my wife and myself.
` Q. How long have you had Lynn, Inc. for
`doing consulting work?
` A. We formed the company in 1985.
` Q. And is your wife a geophysicist?
` A. Yes.
` Q. What's her background like?
` A. Ph.D., Stanford. Extremely smart.
`She is well known in the industry for her
`expertise, which is what we do in our company.
`We apply a technology called azimuthal seismic
`looking for azimuthal signatures in the seismic
`that can help in the unconventional reservoirs.
` Q. What do you mean by "unconventional
`reservoirs"?
`
`4 (Pages 10 to 13)
`TSG Reporting - Worldwide - 877-702-9580
`
`WesternGeco Ex. 1030, pg. 4
`WesternGeco v PGS
`IPR2015-00313
`
`

`
`Page 14
`
` W. LYNN
` A. What the term reflects are reservoirs
`that contain hydrocarbon. But when a well is
`drilled, the permeability within that reservoir
`is not sufficient to get flow from the pour
`spaces to the well, and those reservoirs have to
`be fracked. I'm sure you're familiar with
`hydrofracking from the newspapers and so forth.
` Q. I've heard the term and a little bit
`more than that.
` A. That's our expertise. By looking at
`the azimuthal seismic and the azimuthal
`anisotropy, we can understand what the
`differential pressures are in the reservoir and
`what the fractures may or may not be in the
`reservoir prior to drilling.
` Q. Is that the main application of the
`work that you do at Lynn, Inc., is advising on
`potential fracking operations?
` A. Yes. We work with engineers with
`various companies, have worked with engineers of
`various companies. We don't go out in the field
`and sit while they're drilling the wells, but we
`try to give guidance to the engineers working
`with the other geoscientists within a company.
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`Page 16
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` W. LYNN
`the design of a survey, in the processing of the
`data, and in the interpretation of the data.
` Q. When you're involved in the seismic
`surveys, either the planning or the shooting or
`the data processing, is it your clients, like
`Devon Energy, that are doing the seismic or is
`there an oil services company that's actually
`performing the seismic?
` A. Almost always the oil companies
`contract out the acquisition and the processing
`of the data.
` Q. Do you interact with the companies
`that are doing the acquisition and the
`processing?
` A. Sometimes with acquisition. More so
`in the processing and the interpretation.
`Because many times our involvement happens after
`the data have been acquired and Company X says
`oh, there's some useful information here and we
`need some help.
` Q. So do you work hand-in-hand with the
`data processing company or are you a QC on them?
`Or how does that relationship work?
` A. In the data processing, our
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`Page 15
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` W. LYNN
` Q. What types of companies do you
`generally work with?
` A. Generally smaller companies. But the
`original work we did at Lynn, Inc. where we kind
`of grew our field understanding of this was Devon
`Energy. And they're based in Oklahoma City.
` Q. Devon Energy, are they an oilfield
`services company?
` A. We call them a mid size oil and gas
`company.
` Q. So they actually own or lease the land
`for exploration and drilling?
` A. Yes.
` Q. The work that you do at Lynn, Inc.,
`are your clients generally the oil companies or
`do you work with oilfield companies?
` A. Almost exclusively with oil companies.
` Q. So the oil company would bring you in
`to consult on a potential fracking operation, for
`example?
` A. Usually we're engaged prior to that
`point. They may be considering shooting seismic
`for the purpose of getting that information.
`They sometimes might ask for our involvement in
`
`Page 17
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` W. LYNN
`involvement is not so much at every step along
`the way but more so when they get into the areas
`of the processing steps where we have to be very
`careful to retain the azimuthal information.
`Which is velocity and amplitudes.
` Q. So you would be hired by the oil
`company but do some work with the services
`company in, for example, some of these data
`processing steps?
` A. Absolutely, yes.
` Q. What services companies do you work
`with?
` A. We have worked with several. Right
`now we're working with three data processing
`companies for one client. One is called Arcis,
`based in Calgary. A second is called NEOS. A
`third in this case is Geokinetics.
` There are not many processing
`companies that know how to do azimuthal
`processing. I'm pretty familiar with those.
` Q. Do you ever work with PGS on data
`processing or azimuthal processing?
` A. We have not.
` Q. Are they a company that you would
`
`5 (Pages 14 to 17)
`TSG Reporting - Worldwide - 877-702-9580
`
`WesternGeco Ex. 1030, pg. 5
`WesternGeco v PGS
`IPR2015-00313
`
`

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` W. LYNN
`characterize as knowing how to do azimuthal
`processing?
` MR. KRINSKY: Object to the form of
` the question.
` THE WITNESS: I don't have sufficient
` information to answer that yes or no. So
` I'll answer it this way. Given the people
` that I'm aware of working there and their
` expertise, I would be surprised if they did
` not know how to do azimuthal processing.
`BY MR. GILMAN:
` Q. So there are data processing companies
`out there that you do know that are good with
`azimuthal processing?
` A. Uh-huh.
` Q. And I think you've mentioned a couple
`of the names; is that correct?
` A. I mentioned three so far.
` Q. You do not have personal knowledge if
`PGS is good at doing azimuthal processing? You
`just haven't seen that?
` A. That's correct.
` Q. Do you ever work with WesternGeco in
`terms of the seismic work that you do?
`
`Page 20
`
` W. LYNN
`If you know.
` A. My contract is with Williams &
`Connolly.
` Q. Have you been retained to consult in
`any other legal matters other than these two
`Patent Office proceedings about the '059 patent
`and the '981 patent?
` MR. KRINSKY: Object to the form of
` the question.
` I would ask the witness not to respond
` with any specifics regarding other work you
` may be doing for Williams & Connolly or
` other law firms. I don't think that's an
` appropriate line of questioning. You can
` answer just whether you have or not.
` THE WITNESS: Is your question
` currently am I working with other companies
` on any law or any patents -- Why don't you
` rephrase the question?
`BY MR. GILMAN:
` Q. Let's start with that.
` Are you currently working as a
`consultant on any other legal matters other than
`the '059 patent and the '981 patent, the two
`
`Page 19
`
` W. LYNN
` A. I would like to back up to the
`previous question for just a moment. You asked
`if I've ever seen that. I've never worked
`directly with PGS for their azimuthal data
`processing.
` Q. Have you worked directly with PGS on
`other matters as part of Lynn, Inc.?
` MR. KRINSKY: Counsel, I don't think
` he was done with his answer.
` So please feel free to finish
` answering that question.
` THE WITNESS: I think I was finished.
` And your following question was?
`BY MR. GILMAN:
` Q. Have you done any work with PGS as
`part of Lynn, Inc.?
` A. No.
` Q. Were you retained for your work in
`this matter by PGS or by Williams & Connolly?
` A. I think you asked that earlier, and I
`did reply that it was Williams & Connolly that
`contacted me on this.
` Q. I understand they contacted you. I
`didn't know in terms of who formally hired you.
`
`Page 21
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` W. LYNN
`Patent Office proceedings?
` A. No.
` Q. Have you in the past been retained to
`work on other legal matters?
` A. Yes.
` Q. I think we talked about a few of them
`on Wednesday.
` A. Yes.
` Q. And I don't have my notes here from
`Wednesday. But have you been retained to work on
`any other legal matters other than the two Patent
`Office proceedings in the last ten years?
` A. Yes.
` Q. What other legal proceedings have you
`been retained to work on?
` A. I was retained by -- I was retained, I
`don't know if I should say by whom.
` THE WITNESS: You can advise me,
` Counsel.
` It was about one and a half, two years
` ago I was retained as an expert consultant
` on some patent litigation. But I have not
` done anything on that for at least a year
` and a half.
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` W. LYNN
`BY MR. GILMAN:
` Q. What type of technology did that
`involve, that case?
` A. It involved acquisition technology.
` Q. Towed marine seismic?
` A. Yes.
` Q. Was that a Patent Office proceeding or
`was that litigation in a court?
` MR. KRINSKY: And I'll just instruct
` you. You should not reveal any details of
` that proceeding that are confidential. I
` don't know quite what you're referring to,
` so I don't know that I can advise you more
` specifically about that.
` THE WITNESS: So you asked me was it
` related to Patent Office or --
`BY MR. GILMAN:
` Q. Do you know if it was a Patent Office
`proceeding like we're talking about today or if
`it was litigation before a court?
` A. I'm not sure. So I think that's
`probably my best answer. It was very
`preliminary, and I was asked to just help
`understand the science.
`
`Page 24
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` W. LYNN
`main person. There were other people I spoke
`with, but I'm not -- I'm not sure.
` Q. And did that matter relate to the
`ability to steer marine streamers during a
`seismic survey?
` A. Yes.
` Q. You said you haven't done much work on
`that since a year and a half ago or so?
` A. Easily, yeah.
` Q. Well, other than this marine streamer
`matter and the two present matters, are there
`other matters that you've been retained as an
`expert in conjunction with?
` A. With? With what?
` Q. I ended with a preposition there. Are
`there any other matters that you have been
`retained as an expert in the last ten years?
` A. I spoke of one during the Wednesday
`proceedings where I was hired by a company at the
`time called IO, and they were being charged with
`faulty equipment. The company, which I couldn't
`remember the name at the time, the first name of
`Bjorn, B-j-o-r-n, Paulsson came to me during a
`breakfast or something.
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` W. LYNN
` Q. What company was it that retained you?
` MR. KRINSKY: And I don't -- If this
` is not a public expert engagement, I don't
` know that that's an appropriate question,
` Counsel. I leave it to Dr. Lynn to let you
` know if it is -- if he has been publicly
` disclosed or disclosed to the other side in
` that proceeding.
` THE WITNESS: I have no idea if my
` involvement was publicly disclosed or not.
`BY MR. GILMAN:
` Q. Was it Williams & Connolly who
`retained you in that matter?
` A. Yes.
` Q. And I take it it was not Mr. Krinsky
`that you worked with on that matter?
` A. I did not work with Mr. Krinsky on
`that matter.
` Q. Who at Williams & Connolly did you
`work with on that matter? If you remember.
` A. There were two people. One was David
`Berl.
` Q. Do you remember the second name?
` A. It could have been -- David was the
`
`Page 25
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` W. LYNN
` Q. Other than that ION matter with
`Mr. Paulson's company, the two patent proceedings
`that we've been talking about this week and this
`other matter with Williams & Connolly and
`steerable streamers, are there any other matters
`you've been retained in in the last ten years?
` A. No.
` Q. These two Patent Office matters, I
`believe you are being compensated at a rate of
`$315 an hour?
` A. Yes.
` Q. Do you know approximately how many
`hours you've worked on the two matters?
` A. Let's do some arithmetic. I think the
`billing to date is roughly $110,000, divided by
`15 would give an estimate of the number of hours.
` Q. So the billing to date for your work
`in this case or these two cases has been about
`$110,000?
` A. Roughly, yeah. Plus or minus.
` Q. We'll see how long today goes.
` A. I'm definitely not going to extend the
`proceedings for a long day.
` Q. I won't comment on whether or not it's
`
`7 (Pages 22 to 25)
`TSG Reporting - Worldwide - 877-702-9580
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`WesternGeco Ex. 1030, pg. 7
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`IPR2015-00313
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` W. LYNN
`worth $315 an hour to talk to me.
` In terms of the other matter that you
`mentioned with Williams & Connolly, do you know
`approximately how much you charged for your
`services in that case?
` A. The number I gave you was -- oh,
`excuse me, for the steerable streamer matter?
` Q. Correct.
` A. Far less. Maybe $30,000. That's an
`educated guess.
` Q. I don't know if I gave you a copy of
`it yet. I would like to show you what's been
`previously marked as Exhibit 1001, the Starr
`patent.
` (WesternGeco Exhibit 1001, previously
` marked for identification, is attached
` hereto.)
` MR. KRINSKY: I neglected to
` compliment counsel on the color photocopying
` today.
` MR. GILMAN: I try to learn from my
` mistakes.
`BY MR. GILMAN:
` Q. Exhibit 1001, the Starr '059 patent,
`
`Page 28
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` W. LYNN
` A. The '059 patent uses acquisition
`geometries that are applicable to what we call
`ocean bottom seismic acquisition where receivers
`or cables are laid on the water bottom.
` Q. How does ocean bottom acquisition
`work?
` A. In ocean bottom seismic at this point,
`as of the priority date, the cables were laid on
`the water bottom. So instead of a boat pulling
`streamers behind the vessel, the cables are laid
`on the water bottom. And the seismic source
`vessel is independent of the cables. It's not
`towing them. So they're decoupled, so they're
`free to go in any direction relative to where the
`cables are.
` And in Figure 1 and 2 of the Starr
`patent, he exemplifies some representative
`geometries of acquisition, acquisition
`geometries.
` Q. So starting with Figure 1, what part
`of Figure 1 would be the cables that are laid on
`the water bottom?
` A. They would be the -- Let me just make
`sure. In Figure 1 there are two vertical lines
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` W. LYNN
`is what is at issue in the Patent Office
`proceeding we're talking about today.
` A. Correct.
` Q. What is your understanding as to what
`the invention is of the Starr '059 patent?
` MR. KRINSKY: Object to the form of
` the question.
` THE WITNESS: Maybe re-pose the
` question so I can give a specific answer
` would be helpful.
`BY MR. GILMAN:
` Q. Sure.
` What is the goal of the '059 patent?
` MR. KRINSKY: Same objection.
` THE WITNESS: The overall goal of the
` '059 patent is to obtain information from
` seismic data that's applicable to
` hydrocarbon exploration. More specifically,
` pre-stack analysis of data for hydrocarbon
` identification.
`BY MR. GILMAN:
` Q. For the '059 patent, it's not a patent
`on the method of acquiring the seismic data; is
`that fair?
`
`Page 29
`
` W. LYNN
`that are solid lines labeled RL1 and RL2. Those
`are -- RL standing for receiver lines.
` Q. So those receivers would be actually
`laid on the bottom of the ocean?
` A. Correct.
` Q. And are the cables that would have the
`sensors, the hydrophones inside of them?
` A. In ocean bottom seismic as of the
`priority date, these cables would have two
`sensors in them, they would have a hydrophone and
`a geophone.
` Q. For the ocean bottom cable seismic,
`you wouldn't be towing any sensors?
` A. No.
` Q. So on Wednesday we talked about some
`examples of towing arrays of streamer cables.
`That's a different approach than the ocean bottom
`cable approach of Figure 1 of Starr?
` A. It's different in the sense that the
`cables are laid on the water bottom; they're not
`moving. The seismic vessel or the source vessel
`will go in a geometry as depicted in Figure 1.
`The SL1, for example, would be a source line.
` Q. So the source line is where you would
`
`8 (Pages 26 to 29)
`TSG Reporting - Worldwide - 877-702-9580
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`WesternGeco Ex. 1030, pg. 8
`WesternGeco v PGS
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` W. LYNN
`tow the source at the surface of the water?
` A. Just below the surface of the water.
` Q. So you would have a boat actually
`towing the source and the receiver cables would
`be laid on the floor of the ocean?
` A. Correct.
` Q. And SL1, you said, is an indication of
`the direction the source boat is going?
` A. Correct. It's showing that the source
`line is going orthogonal to the receiver lines.
`So if the receiver lines are north-south, the
`source vessel is going east-west.
` Q. Would that be the normal case in ocean
`bottom exploration, that your source lines would
`be orthogonal to your receiver lines?
` A. As best I know, that would be a
`conventional configuration.
` Q. Have you seen other configurations for
`ocean bottom surveys?
` MR. KRINSKY: Object to the form of
` the question. Foundation.
` THE WITNESS: I don't recall any
` others, and so I can answer no, I have not
` seen any others.
`
`Page 32
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` W. LYNN
`would be one line. The next line would be
`parallel to that source line.
` In one of the papers that I cite Alex
`Calvert is talking about the use of now instead
`of common offset bins but we use the term offset
`vector tiles. And Calvert's paper talks about
`how OVTs, i.e., common offset bins, could be
`formed with any type of geometry provided that
`there's some regular pattern to the -- for the
`receiver lines are parallel, the source lines are
`parallel. That gets into reasons that are beyond
`the scope of the Starr patent.
` Q. So did you just say that offset vector
`tiling is the same as common offset binning?
` A. That's what we would refer to it as
`today.
` Q. The two terms would be somewhat
`interchangeable?
` A. I had not ever seen common offset bins
`in words before reading the Starr pattern. And
`so a person of skill in the art I think would
`have that understanding.
` Q. When did you first read the Starr
`patent?
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` W. LYNN
`BY MR. GILMAN:
` Q. All of the ocean bottom surveys that
`you're familiar with would have orthogonal cell
`lines and receiver lines?
` A. Yes.
` Q. Is there anything special about that
`geometry in terms of what's going on in the Starr
`patent?
` A. Yes. In the Starr patent it takes
`advantage of this orthogonality to build these
`common offset bins. However, it is not a
`prerequisite to develop these common offset bins
`to have the orthogonality between the source and
`receiver lines.
` Q. You could do common offset bins with
`any type of seismic acquisition?
` A. There is an implicit assumption of
`uniformity of direction for the receiver lines
`a