Gilman, Timothy K.
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Timothy Gilman <TGilman@kirkland.com>
`Tuesday, December 08, 2009 6:03 PM
`james.brasher@pgs.com
`eugene.thigpen@pgs.com
`WesternGeco v. ION, Case No. 4:09-cv-01827-KPE (S.D. Tex.)
`
`
`James,
`
`As I indicated during our conversation this afternoon, we are representing WesternGeco in connection with the above-
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`captioned patent litigation. For your convenience, attached below are the parties' four pleadings in this case.
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`Based on our investigation and research to date, it appears that information relevant to the litigation may be in the
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`possession, custody or control of PGS and/or that current PGS employees may have personal knowledge relevant to the
`litigation. For example, Oyvind Hillesund, a former WesternGeco employee who is believed to currently work for PGS in
`Oslo, is a co-inventor on some of the patents-in-suit. As another example, we understand that PGS was involved in the
`design, testing and/or launch of the ION products and systems accused of infringement in this action in 2007, and would
`likely have information relevant to those products and systems. PGS may have used these systems and products outside
`the United States, which would be relevant to WesternGeco's claim against ION under 35 U.S.C. s. 271(f). PGS may also
`have information relevant to ION's antitrust counterclaims in this case, such as information regarding the identity and
`market shares of companies involved in marine seismic surveys.
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`I would appreciate the opportunity to discuss this matter with you in greater detail, and to explore the potential for
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`discovery of relevant material that PGS may possess. For example, we would we interested whether PGS would be
`willing to make Mr. Hillesund available to discuss his work relating to the applicable patents-in-suit, as well as possibly
`sitting for a deposition in this case. Please let me know when would be convenient for you to continue this discussion.
`
` -
`
` tim
`
`D.I. 1 -- Complaint.pdf D.I. 6 -- ION Answer and Counterclaim.pdf D.I. 14 -- WG Answer
`and Counterclaim to ION Counterclaim.pdf D.I. 19 -- ION Answer to WG Counterclaim.pdf
`
`Timothy K. Gilman
`Kirkland & Ellis LLP
`212-446-4689
`212-446-4900
`601 Lexington Avenue
`New York, NY 10022-4675
`timothy.gilman@kirkland.com
`
`Attachments:
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`D.I. 1 -- Complaint.pdf (4411824 Bytes)
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`D.I. 6 -- ION Answer and Counterclaim.pdf (3120883 Bytes)
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`D.I. 14 -- WG Answer and Counterclaim to ION Counterclaim.pdf (3558380 Bytes)
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`D.I. 19 -- ION Answer to WG Counterclaim.pdf (231538 Bytes)
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`b282f738-ec7c-4eb2-9bb6-b036409f9383.gif (1637 Bytes)
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`34eba385-f8f0-4ce1-8931-045a921023bc.gif (1808 Bytes)
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`958c0455-1580-449d-bc29-0aed8cd5b835.gif (1983 Bytes)
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`c5705a51-6794-4638-aa17-0b57615305bc.gif (1846 Bytes)
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`1
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`WesternGeco Ex. 2015, pg. 1
`IPR2015-00565
`ION v WesternGeco
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`