PROTECTIVE ORDER MATERIAL Page 1 of 1 I, Walter Bratic
I, Walter Bratic, declare as follows: 1. Unless otherwise stated, I have personal knowledge of the statements herein, and if called to testify, I could and would testify competently to the truth of the statements herein. I have been asked to express my opinions regarding the commercial success of U.S. Patent Nos. 6,047,781, 6,068,069, and 6,085,851 (the “Transocean Dual-Activity Patents”), which are owned by Transocean Offshore Deepwater Drilling Inc. (“Transocean”). I am a Managing Director of OverMont Consulting, LLC (“OverMont”). I am a Certified Public Accountant licensed to practice in the state of Texas. I have over 25 years of experience analyzing economic, financial, valuation, and business matters involving patented technology. I have been retained in patent dispute matters and have analyzed and opined on issues related to commercial success of patented inventions. My qualifications are discussed in more detail in my resume. See Exhibit 2081. 2. I was retained in several Transocean patent infringement litigation matters in which certain Transocean patents, including the Transocean Dual-Activity Patents which are the subject of this declaration, were asserted against Maersk Contractors USA, Inc. (“Maersk”), Stena Drilling Limited (“Stena”), and Pacific Drilling S.A. (“Pacific”). My work on these patent litigation matters included analysis of the PROTECTIVE ORDER MATERIAL Page 1 of 1 001 commercial success attributable to Transocean’s dual-activity patents as required under Georgia-Pacific factor number 8.1 3. I have analyzed the following indicators of commercial success related to the Transocean Dual-Activity Patents: Day rate premium attributable to dual-activity technology; Dual-activity rig status compared to single activity rig status; and Industry preference for dual-activity rigs.
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