`
`In The Matter Of:
`
`ROY‐G‐BIV Corporation
`vs.
`ABB, Ltd., et al.
`
`
`___________________________________________________
`
`Marc McClung
`March 14, 2014
`
`___________________________________________________
`
`
`
`Marc McClung March 14, 2014
`
`1
`
` IN THE UNITED STATES DISTRICT COURT
` FOR THE EASTERN DISTRICT OF TEXAS
` TYLER DIVISION
` - - - -
`
`ROY-G-BIV CORPORATION, )
` )
` Plaintiff, )
` )
` vs. ) No. 6:11-cv-000622-LED
` )
`ABB LTD., ABB, INC., )
`MEADWESTVACO TEXAS, LP and )
`MEADWESTVACO CORPORATION, )
` )
` Defendants. )
`___________________________)
`
` - - - -
` DEPOSITION OF MARC McCLUNG
` Held at Verbatim Reporting Service
` 141 Stony Circle, Suite 240, Santa Rosa, California
` Friday, March 14, 2014, 10:00 a.m.
` - - - -
`
`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`2
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`APPEARANCES
`
`For the Plaintiff:
` Boies, Schiller & Flexner LLP
` Attorneys at Law
` 5301 Wisconsin Avenue, NW
` Washington, DC 20015
` BY: RICHARD S. MEYER, ESQ.
`
`For the Defendants:
` Squire Sanders
` Attorneys at Law
` 1200 19th Street NW
` Suite 300
` Washington, DC 20036
` BY: JEREMY W. DUTRA, ESQ.
`
` ABB, Inc.
` Legal Department - 4U6
` 29801 Euclid Avenue
` Wickliffe, Ohio 44092
` BY: ROBERT P. NUPP
` Senior Patent Attorney
`
`Also present:
`
` David Brown
` Eric Harnew, Videographer
`
`Reported by:
` Jennifer L. Furia, RPR, CSR
` License No. 8394
`
`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
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`Marc McClung March 14, 2014
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`3
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` INDEX OF EXAMINATION
` Page
`Examination by Mr. Dutra 7
`Examination by Mr. Meyer 143
`Further examination by Mr. Dutra 214
`
` INDEX OF EXHIBITS
`McClung
`Exhibit No. Description Page
`
` 1 Compumotor Motion Toolbox User Guide, 37
` Bates stamped RGBINSP00017944 -
` RGBINSP00018056
`
` 2 Compumotor 6000 Series Software 50
` Reference Guide, Bates stamped
` RGBINSP00001703 - RGBINSP00001970
`
` 3 A Parker Compumotor Digiplan Memo to 83
` Bob Cook, Kevin Holloway, Joanne Botka,
` Marc McClung, John Stroup, Dave Brown -
` ROY-G-BIV, Jay Clark, ROY-G-BIV, CC Roy
` Glassett, DATE April 22, 1994, RE
` ROY-G-BIV Meeting Minutes, Bates
` stamped PARKER 0010 - PARKER 0016
`
` 4 Motion Control Component WOSA API/SPI 105
` Specification, Bates stamped
` RGB00055144 - RGB00055171
`
` 5 WOSA/XMC MCAPI and MCSPI Design 124
` Specification, Bates stamped
` RGB00055896 - RGB00055949
`
` 6 ROY-G-BIV Spec 2.0 Meeting Minutes, 125
` September 8, 1994 3:30 AM, Bates
` stamped PARKER 0045 - PARKER 0046
`
`(312) 386-2000
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`Merrill Corporation - Chicago
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`www.merrillcorp.com/law
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`Marc McClung March 14, 2014
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`4
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` INDEX OF EXHIBITS (Continued):
`
`McClung
`Exhibit No. Description Page
`
` 7 Email from Marc McClung, to Dave Brown, 130
` dated 9/19/94, RE: WOSA/XMC, Draft 2,
` Section 3.3, Bates stamped RGB00051658 -
` RGB00051659
`
` 8 Email from Marc McClung, to Dave Brown, 131
` dated 11/10/94, RE: WOSA/XMC, Draft 2,
` ITimer, Bates stamped RGB00051664
`
` 9 Email from Marc McClung, to Dave Brown, 131
` dated 11/11/94, RE: WOSA/XMC, Draft 2,
` Interrupts, Bates stamped RGB00051665
`
` 10 Email from Marc McClung, to Dave Brown, 132
` dated 11/11/94, RE: WOSA/XMC, Draft 2,
` ICounter, Bates stamped RGB00051666
`
` 11 RGBLOG.TXT, Bates stamped PARKER 0034 - 132
` PARKER 0038
` 12 Motion Control Component WOSA API/SPI 161
` Specification, Bates stamped
` RGB00120632 - RGB00120659
` 13 Reciprocal Non-Disclosure & 166
` Confidentiality Agreement, Bates
` stamped RGB00058740 - RGB00058742
` 14 Reciprocal Non-Disclosure & 184
` Confidentiality Agreement, Bates
` stamped RGB00057860 - RGB00057862
` 15 RGBLOB.TXT, Bates stamped PARKER 186
` 0019 - PARKER 0044
`
` 16 Parker Compumotor Digiplan Memo to Bob 218
` Cook, Kevin Holloway, Marc McClung, John
` Stroup, Bates stamped PARKER 0052
`
`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
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`Marc McClung March 14, 2014
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`5
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` --o0o--
` THE VIDEOGRAPHER: We're going on the record.
`The time is 10:00 a.m. The date is March the 14th,
`2014. We're located at the Office of Verbatim
`Reporting Service at 141 Stony Circle, second floor
`conference room, Santa Rosa, California. We are taking
`the deposition of Marc McClung in the U.S. District
`Court for the Eastern District of Texas, Tyler
`Division. ROY-G-BIV Corporation versus ABB Limited, et
`al. Case number 6:11-CV00622-LED.
` Videotape is being produced on behalf of
`Squire Sanders Law Office, attorneys for the defendant.
` My name is Eric Harnew. I work for
`Tradewinds West Video, located at 66 Bennett Avenue,
`San Anselmo, California. Telephone area (415)
`456-7630.
` At this time I'd like to ask those present to
`introduce themselves for the record. Please state your
`name, the firm you work for, location of the firm, and
`whom you're representing in this matter. And I'll
`leave the camera on the witness and start with camera
`left.
` MR. DUTRA: Jeremy Dutra with the law firm
`Squire Sanders on behalf of the Defendant's ABB, Inc.
` MR. NUPP: Robert Nupp on behalf of ABB,
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`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`6
`
`Inc.
` MR. MEYER: Richard Meyer with Boies,
`Schiller & Flexner in Washington, D.C. representing the
`Plaintiff ROY-G-BIV Corporation. And with me here
`today is a representative of ROY-G-BIV, Mr. David
`Brown.
` THE VIDEOGRAPHER: And today our court
`reporter is from Verbatim Reporting, Jennifer Furia.
` Would the court reporter please administer
`the oath.
`
` MARC McCLUNG,
`called as a witness by the Defendant, herein, being
`first duly sworn by the Certified Shorthand Reporter,
`was thereupon examined and interrogated as is
`hereinafter set forth.
` THE WITNESS: Uh, yes.
` THE VIDEOGRAPHER: Mr. McClung, are you aware
`the deposition is being videotaped?
` THE WITNESS: Uh, yes.
` THE VIDEOGRAPHER: Thank you.
` We're following the Federal Rules of Civil
`Produce. If there are any stipulations you'd like to
`put on the record, this might be the appropriate time.
`If not, proceed.
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`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`7
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` MR. MEYER: Normal, the way we've been doing
`it, according to the Federal Rules of Civil
`Procedure.
` MR. DUTRA: Federal Rules and local rules, I
`suppose, local rules of practice.
` MR. MEYER: Yes.
` EXAMINATION
`BY MR. DUTRA:
` Q. Good morning, Mr. McClung.
` A. Good morning.
` Q. I introduced myself. Jeremy Dutra with
`Squire Sanders. Can you just provide your name for the
`record, please.
` A. Marc McClung.
` Q. Okay. And your address, please.
` A. My home address is 1508 Cabernet Circle,
`Santa Rosa, California.
` Q. Now, you're appearing here today pursuant to
`a subpoena that my law firm, Squire Sanders, uh,
`issued, uh, to you, correct?
` A. That's correct.
` Q. Okay. Have you ever been deposed before?
` A. Never have.
` Q. Okay. I'll just give you a brief overview.
`Um, you are under oath. I'm asking you questions.
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`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`8
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`I'll ask you for answers. I -- I will try not to
`interrupt any of your answers. The court reporter
`appreciates that, when we're not talking over one
`another.
` You may hear objections from Mr. Meyer today.
`It's just a natural process, you know, he's preserving
`a record for himself. Um, after he gets done with his
`objection, uh, if he has one, you can still answer the
`question.
` Um, if there's not -- if there is a question
`that I've asked that you don't understand, let me know
`and I'll -- I will try to clarify it and see if we can
`remove any ambiguity, all right?
` A. Okay. Thank you.
` Q. And the other thing I'll note too is, if at
`any time you want to take a break, just let me know,
`okay? The one caveat I'll have is, if I have a
`question on the floor, you know, I'll want a response
`to that. But, uh, um, just let me know if you need to,
`uh, you know, stretch your legs or something.
` A. Okay, sure.
` Q. All right. Let's go with a little bit of
`your background here. Um, start with your education.
`You have a college degree?
` A. I do.
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`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`9
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` Q. Okay. And, uh, where did you get that degree
`from?
` A. University of Louisville, Louisville
`Kentucky.
` Q. Okay. And what was the degree in?
` A. Electrical engineering.
` Q. Okay. Did you have any postgraduate degrees?
` A. I, uh -- I did take a number of master's
`courses -- courses, was enrolled in the master's
`program, also at University of Louisville.
` Q. Okay.
` A. And took additional, you know, master
`coursework at Rochester Institute of Technology.
` Q. Okay. Are you currently employed?
` A. Yes.
` Q. Okay. With whom are you employed?
` A. I'm employed with Dragnet Solutions.
` Q. Okay. And what does Dragnet Solutions do?
` A. We build, uh, uh, identity verification
`systems and document authentication systems for
`financial institutions. Primarily banks.
` Q. Okay. And what is your position with the
`company?
` A. Uh, at that company I'm the director of
`engineering.
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`(312) 386-2000
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`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`10
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` Q. You oversee, I'm assuming, then a staff of
`engineer -- in-house engineers?
` A. That's correct.
` Q. Okay. And how long have you been with
`Dragnet?
` A. Been there since -- been there, I believe,
`for about, uh -- I believe I started there about 2005.
`So it's been about, uh, about nine years.
` Q. Okay. And prior to, uh, your joining
`Dragnet, with whom were you employed?
` A. I worked for, uh, Parker Hannifin
`Corporation.
` Q. Is that, uh -- and what was your position? I
`guess, when did you begin with Parker?
` A. I started at Parker, in particular their, um
`-- it was called Compumotor at the time or when we --
`but it's since changed names. I believe it was -- it's
`like their mechanical division in Rohnert Park. And so
`I started there in 1987.
` Q. Okay. Okay. And what -- what position did
`you hold when you first joined?
` A. Uh, when I joined I -- I don't recall the
`exact title. I -- I joined as -- as an engineer. Uh,
`you know, I don't -- I can't recall if I started, you
`know, out as a -- I -- I can't exactly recall, you
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`(312) 386-2000
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`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`11
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`know, the exact title. I know for a while I was called
`a senior engineer, a staff engineer. I was an
`engineer, basically.
` Q. During your entire tenure at, uh, at
`Compumotor Parker were you an engineer?
` A. During the entire -- the entire time?
` Q. Yes.
` A. Yes.
` Q. Okay. Maybe different titles, but at the end
`of the day your responsibilities were with engineering?
` A. Uh, that's correct.
` Q. Okay. And I know you mentioned Compumotor
`Parker. If I use Compumotor or Parker can we use those
`terms interchangeably today to refer to --
` A. Uh, yeah. That -- that makes sense in the
`context of this case, sure.
` Q. Okay. Okay. Perfect. I appreciate that.
` What type of -- what type of work did you do
`at Compumotor as an engineer, when you -- when you
`first joined. And we can start there and move on.
` A. Okay. Yeah, when I joined in '87 I -- I
`worked in a systems products group. And, uh, I, uh,
`worked on PC-based control systems, you know, for --
`for factory automation. So, primarily it was kind of,
`uh, uh -- it was kind of an internal project.
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`(312) 386-2000
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`Merrill Corporation - Chicago
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`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`12
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` So, uh, uh, we had a mission to, you know,
`create a PC-based control system for, uh, Parker
`Hannifin's machine, you know, back -- back east. Their
`core business being, you know, the production of, you
`know, hoses and fittings and that sort of thing. And
`they wanted to automate, uh, these -- um, these
`cam-driven machines. So we were tasked with, you
`know -- you know, automating, you know, those machines.
` You know, basically removing the mechanical
`cams and replacing those with mechanical slide tables
`and motors and controllers and automate, um, you -- you
`know, tho -- those machines. So that was about --
`basically it was like a three-year project doing
`that.
` Q. Okay. Would you characterize this type of
`work as motion-control type work?
` MR. MEYER: Objection, leading.
` THE WITNESS: Oh. Should I go ahead and
`answer?
`BY MR. DUTRA:
` Q. You can --
` A. Okay.
` Q. -- answer, yep.
` A. Okay. Yes, it is, definitely it's a
`motion-control application. I mean, it's --
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`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`13
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` Q. Okay. And after this, uh, three-year -- I
`guess you referred to it as an internal project, what
`other type of work did you do at Parker?
` A. Well, after working in the system products
`group, uh, I, uh -- that -- that group was disbanded
`and then I moved into the product group. And, uh,
`there I, uh, was kind of a -- I basically wrote uh, uh,
`um, applications, PC software applications to support
`the, you -- you know, the products that, you know,
`that that group built.
` Q. And what were the products that that group
`built?
` A. Uh, at that time they, uh, uh, uh, they were
`building a, uh -- we were working on the 6000 Series
`product line, which was -- which was a family of
`bus-based Stepper and Servo controllers.
` THE REPORTER: Servo?
` THE WITNESS: Servo, S-e-r-v-o.
` THE REPORTER: Thank you.
`BY MR. DUTRA:
` Q. And what type of, uh, PC -- I think you said
`PC-based applications --
` A. Hm-m.
` Q. -- were you writing at that time?
` A. Okay. At that time it was, uh -- it was
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`
`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`14
`
`primarily -- it started out as -- I was writing DOS
`applications initially in the systems products group.
`And then when I transitioned into the product group, I
`was still -- I was still working on the DOS-based
`applications.
` I worked on a product called a G-code
`interpreter. It wasn't something that I wrote, it's
`something I inherited. It's something that we had
`contracted out to a company, uh, to build for us for a
`product called -- it was uh, uh the PC23 bus-based
`indexer.
` And so I was -- so when I went into that --
`that -- the product group, that was -- that was one of
`the first things I -- I worked on basically. Helping,
`uh, in the -- uh, basically debugging, ferreting out
`all the bugs, so we -- you know, the contractor, I
`believe, quit working on it for -- in fact, I can't
`recall what reason. But I got it and I had to make it
`work. So that was my first introduction to that kind
`of software.
` And then at that time Windows was coming out,
`so I remember, uh, being fascinated by that. And I --
`I remember I got -- got a copy of the Windows 2 S --
`there was like a little SDK and -- and so I built some
`Windows applications for this PC23 Indexer. And
`
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`
`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`15
`
`everybody was like really excited about it and, uh --
` And that's kind of like -- and then this new
`project came along. We were -- we were going to build
`this family of indexers, it's -- indexers and servo
`controllers. And so we decide, you know -- you know,
`let's write Windows software, you know, for -- for this
`family. And so, uh -- and that's what we did. And it
`turned out it was a good decision.
` Q. And when you said for this family, you're
`referring to the 6000 Series Controllers?
` A. 6000. Exactly. Exactly.
` Q. Okay. You used the -- the phrase G-code.
` A. Uh-huh.
` Q. I'm not familiar --
` A. Okay.
` Q. -- with the -- with the -- with the phrase.
` A. Okay.
` Q. Could you, I guess, illuminate me a little on
`that?
` A. Oh, okay. G-code is a, uh, like it's a
`dedicated -- it's a specialized programming language
`for numerical control. You know, it's primarily used
`in controllers that are -- that are associated with
`usually cutting metal or materials. I'm trying to
`think of a good example.
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`
`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`16
`
` At that time, you know, the big NC
`controllers, I believe, were GE, FAN -- FANUC and, uh,
`and others.
` But it is a -- it's a -- so I can compare it,
`I mean it's -- it's kind of a -- it's a -- it's a --
`uh, uh, uh, a, uh, motion-control language that's kind
`of, uh, geared toward, you know, a, uh, that particular
`application, you know, of -- of, you know, metal --
`primarily metal cutting.
` Q. Okay.
` A. Um, I -- you know, compared to, you know,
`what we do with the 6000 family, was the 6000, the
`command set is more of a -- you know, more of a -- like
`a -- I would characterize it as like a general-purpose
`motion control language. It's not just limited to, you
`know, uh, uh, you know, machine tool operations.
` Q. Okay. When -- you talked about working on
`debugging the DOS-based PC23, and then you did some
`Windows apps. And then I think you said you moved
`on to the 6000 Series. When did that occur? When --
`when did you start developing the indexers for the 6000
`family?
` A. It probably -- it probably occurred, I
`think -- so like I said, I mentioned that I was in
`the -- in the -- in the system products group for about
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`
`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`17
`
`three years, and there was about a year I think I was
`probably working on the, you know, with the PC23. And
`it was about that time, you -- you know, that this --
`this -- the idea of the 6000 family was born. So I
`would -- I would estimate, you know, about '91 or '92,
`something like that.
` Q. Okay. Okay.
` Now, you referred to the 6000 Series or 6000
`family. I take it from that there were a number of
`different actual controllers within that family?
` A. Uh, yes. It started out, uh, uh, you know,
`with the -- I believe it -- it started with the, uh,
`the AT6400 which -- the bus-based, uh, indexer.
` And, uh, I can't recall exactly what came
`next, but -- but like I say, the family, what the --
`you know, the family was -- usually it was broken out
`by the number of axes, you know, so you'd have a -- so
`the AT6400 was a 4-axes indexer. It could control four
`motors.
` And I think, then right after that there was
`a big push to -- to -- to create a servo controller.
`And I -- I believe that was the -- the next thing that
`we did -- I seem to recall that -- that we were really
`busy on that. That that was a pretty important
`product. And that would -- that like rounded out the
`
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`
`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`18
`
`bus-based family.
` Q. If you don't mind me asking, you say servo
`controller. Can you just provide sort of a definition
`or explain that so, you know, jurors who aren't
`involved in this area --
` A. Okay.
` Q. -- have an understanding of what you're
`talking about?
` A. Um, yeah. So a servo controller controls
`a -- a motor using feed -- feedback, so there's this
`notion of a feedback loop. And it's kind of a tough
`thing to -- to explain.
` It would be -- there -- there is a, you know,
`control log in this controller, you know, that
`stabilizes a, uh, position loop. So if you command a
`position and, uh, uh, you know, tell the -- the motor
`to move to a particular position. And then the
`feedback, there would be like a feedbut -- a feedback
`device on the motor, something called an encoder, that
`would tell the controller where it's at, you know, so
`--
` Um, I'm trying to put it in layman's terms.
`If you, uh, uh, if -- if you, uh, uh, you know, if the
`controller sees that, uh, uh, you know, maybe, uh, um,
`you know, that -- that, uh, you know, you're moving, a
`
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`
`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`19
`
`little too far, or not far enough, then it will try to
`compensate and try to -- to match the commanded
`set-point position.
` Q. Okay.
` A. And so -- so a servo controller is a -- a
`form -- is a closed-loop motion control system.
` Q. Okay. I appreciate that. That's, uh -- I
`put you on the spot here.
` A. Yeah, I know. I'm trying to recall. I
`haven't worked like in this field for, you know, almost
`ten years, so I'm trying --
` Q. I understand.
` A. But it -- yeah. That's kind of a crude
`explanation of the --
` Q. Now, so did I hear you right that once the
`6000 family was being developed that you worked on
`developing programs for that -- those controllers?
` A. Well, I mainly was -- my role was as a -- I
`was kind of a lone -- I was a lone software developer,
`PC software developer for that group.
` Q. Okay.
` A. Everybody in my group was a -- either a
`firmware engineer or a hardware engineer, so I was kind
`of an oddity. I think they just didn't know what to do
`with me, you know, when I -- uh, uh, but I got put in
`
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`
`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`20
`
`that group and that -- and so I was, uh, um, uh -- and
`that's when I worked on creating applications that
`support these products. That allows the user to, uh,
`uh, you know, to configure, to tune, to diagnose
`problems, to communicate, to provide help, you know.
` So it was really, you know, software that was
`just tailored, you know, for this -- for this 6000
`family. Helping the user get the most out of it and
`get them up -- up to speed as quickly as possible, you
`know. And so that's -- yeah, in a nutshell is what --
`what I worked on.
` In particular the -- the software that I
`wrote for the 6000 family was something called Motion
`Architect. And that -- that, uh, uh, piece of software
`was really a collection of ap -- applications. There
`was a -- there was a program editor that allowed a user
`to edit a, uh, uh, 6000 program, you know, in the --
`within the native 6000 instruction set or language.
` There was something called a terminal -- a
`terminal emulator that allowed a user to interact with
`the product, you know, be able to sit at a terminal and
`send commands to the indexer controller and get back
`responses.
` Uh, there was a -- something called a, uh, uh
`-- it was like -- I forget exactly what we called it.
`
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`
`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`21
`
`Config -- I want to say -- I want to call it a
`configurater. But it was a configuration tool that
`allowed a user to easily, uh, uh, you know, uh, setup
`the -- the controller, uh, you -- you know, things
`like, um, uh, you know, setting up, you know, scaling
`or, you know, setting up your IO or -- or whatever.
` And, uh, it was -- and another item was a --
`there was a panel, panel application that allowed a
`user, uh, to create a kind of a uh, uh, a panel that --
`uh, uh, uh, it was kind of a GUI -- uh, uh, a GUI
`panel, graphical user interface panel. Uh, you could
`configure buttons and assign, you know, uh, 6000 codes
`to these push buttons.
` But at that time it was like -- that was like
`a big -- that was like a big deal, hitting a button and
`then having the codes go out -- go out to the, uh, to
`the controller indexer.
` Q. And -- and this was occurring in the, what
`time frame?
` A. Uh, that occurred, uh, during -- that time
`frame was probably -- it was probably like '91 through
`'94. Yeah, I think in terms of like three-year
`increments. It was like everything I worked on was
`like -- everything was -- every project was like three
`years. I was kind of just doing the mental math.
`
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`
`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.com/law
`
`
`
`Marc McClung March 14, 2014
`
`22
`
` Q. Makes it easy, I guess, when you're thinking
`back, right?
` Um, okay. Now, you talked about program
`editor. We used the term program. What -- what do you
`mean by that?
` A. Uh, the -- when I -- when I talk about
`programs, these controllers and indexers, uh, that we
`built had, uh, uh -- you could create programs for
`them. So basically, uh, uh, you could, uh, um, you
`know, uh -- a program would be like a sequence of
`instructions, you -- you know, that -- that could be
`stored in the controller, that could be, you know,
`run -- you know, you could run them at a -- at a later
`time.
` So you could define a program to, for
`example, command a motion profile. And then you could
`store that in the controller. And, uh, and then if you
`want to run that program at a later date you would --
`you would issue a run command, uh, to do that.
` Q. And when you say motion profile --
` A. Hm-m.
` Q. -- again --
` A. Hm-m.
` Q. -- um, I mean these --
` A. Hm-m.
`
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`
`(312) 386-2000
`
`Merrill Corporation - Chicago
`
`www.merrillcorp.c
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