In The Matter Of:
`
`TOYOTA MOTOR CORPORATION
`v.
`AMERICAN VEHICULAR SCIENCES
`
` ___________________________________________________
`
`STANLEY YOUNG, Ph.D. - Vol. 1
`May 8, 2014
`
` ___________________________________________________
`
`
`IPR2013-00415 - Ex. 1025
`Toyota Motor Corp., Petitioner
`1
`
`
`
`TOYOTA MOTOR CORPORATION
`v.
`AMERICAN VEHICULAR SCIENCES
`
` ___________________________________________________
`
`STANLEY YOUNG, Ph.D. - Vol. 1
`May 8, 2014
`
` ___________________________________________________
`
`
`IPR2013-00415 - Ex. 1025
`Toyota Motor Corp., Petitioner
`1
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`
`
`STANLEY YOUNG, Ph.D. - 5/8/2014
`
`Page 1
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` STANLEY YOUNG, Ph.D. - 5/8/2014
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TOYOTA MOTOR CORPORATION, )
` )
` Petitioner, )
` ) Case No. IPR2013-00415
` -vs- ) Patent No. 7,650,210
` ) Issue Date: 1/19/2010
`AMERICAN VEHICULAR SCIENCES, )
` )
` Patent Owner. )
`
` Deposition of STANLEY YOUNG, Ph.D., taken
`
`before MARGARET A. BACHNER, CSR, RMR, CRR, and Notary
`
`Public, pursuant to the applicable Rules pertaining
`
`to the taking of depositions for the purpose of
`
`discovery, at Suite 3400, 500 West Madison Street,
`
`Chicago, Illinois, on the 8th day of May, A.D. 2014,
`
`at 8:59 a.m.
`
`1-800-325-3376
`
`Merrill Corporation - New York
`www.merrillcorp.com/law
`
`2
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`
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`STANLEY YOUNG, Ph.D. - 5/8/2014
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`Page 2
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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` There were present at the taking of this
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`deposition the following counsel:
`
` KENYON & KENYON LLP
` BY: MR. ABHISHEK BAPNA
` MR. K. PATRICK HERMAN
` One Broadway
` New York, New York 10004-1007
` 212-425-7200
` abapna@kenyon.com
` pherman@kenyon.com
`
` on behalf of the Petitioner;
`
` McANDREWS HELD & MALLOY, LTD.
` BY: MS. STEPHANIE F. SAMZ
` MR. SCOTT P. McBRIDE
` 500 West Madison Street, 34th Floor
` Chicago, Illinois 60661
` 312-775-8000
` ssamz@mcandrews-ip.cpm
` smcbride@mcandrews-ip.cpm
`
` on behalf of the Patent Owner.
`
`ALSO PRESENT:
`
` MR. TIMOTHY TUPIAK, Audio Monitor
` Merrill Corporation.
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`STANLEY YOUNG, Ph.D. - 5/8/2014
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`Page 3
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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` I N D E X
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`WITNESS EXAMINATION
`
`STANLEY YOUNG, Ph.D.
`
` By Mr. Bapna 4, 160
`
` By Ms. Samz 158
`
` E X H I B I T S
`
`DEPOSITION EXHIBIT FOR IDENTIFICATION
`
` No Exhibits Marked.
`
`TOYOTA DEPOSITION EXHIBIT FIRST REFERRED TO
`
` Exhibit 1001 - IPR2013-00415, United States 61
`
` Patent Number 7,650,210 B2,
`
` Breed
`
` Exhibit 1006 - IPR2013-00415, United States 101
`
` Patent Number 4,675,675,
`
` Corwin, et al.
`
`AVS DEPOSITION EXHIBIT FIRST REFERRED TO
`
` Exhibit 2007 - IPR2013-00415, Declaration 77
`
` of Stanley Young
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`STANLEY YOUNG, Ph.D. - 5/8/2014
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`Page 4
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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` MR. BAPNA: Ms. Bachner, could you please swear
`
`in the witness?
`
` (The witness was duly sworn.)
`
` MR. BAPNA: On behalf of the petitioner, Toyota
`
`Motor Corporation, my name is Abhishek Bapna, and my
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`USPTO registration number is 64049.
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` MR. HERMAN: I'm Patrick Herman from Kenyon &
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`Kenyon, also here on behalf of Toyota.
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` MS. SAMZ: On behalf of patent owner, AVS, I'm
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`Stephanie Samz from McAndrews Held & Malloy. Scott
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`McBride is not presently in the room, but should be
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`joining us.
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` STANLEY YOUNG, Ph.D.,
`
`called as a witness herein, having been first duly
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`sworn, was examined and testified as follows:
`
` EXAMINATION
`
`BY MR. BAPNA:
`
` Q. Dr. Young, could you please state your
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`full name?
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` A. My name is Stanley Young.
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` Q. Could you please state your home address?
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`09:00:58
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` A. Home address 3012 Honey Tree Lane, Austin,
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`09:01:00
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`Texas.
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` Q. Do you have a business address?
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`09:01:05
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`STANLEY YOUNG, Ph.D. - 5/8/2014
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`Page 5
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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` A. Business address for Spectral is -- hmm.
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`I don't ever send anything there. I would have to
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`get that from someplace else, actually.
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`09:01:08
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` Q. Do you understand that you're under oath?
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`09:01:26
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` A. Yes.
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`09:01:28
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` Q. Are you on any medication today that could
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`09:01:29
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`impair your ability to testify?
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` A. No.
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` Q. Is there any reason whatsoever why you
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`couldn't give truthful and competent testify today?
`
` A. Not that I know of.
`
` Q. Okay. Before we begin, I'd just like to
`
`go over some ground rules that will hopefully make
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`the deposition run smoother.
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` First, could you please let me finish my
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`question before you answer. Ms. Bachner cannot
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`accurately transcribe questions and answers if we're
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`both speaking over each other.
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` Do you understand?
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` A. Yes, I do.
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` Q. Okay. Could you please provide verbal
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`responses to my questions? Again, Ms. Bachner cannot
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`09:02:07
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`transcribe the testimony accurately if there's
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`non-verbal responses or gestures, such as a nod or
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`09:02:10
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`09:02:13
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`STANLEY YOUNG, Ph.D. - 5/8/2014
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`Page 6
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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`shaking of the head.
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` Do you understand?
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` A. Yes, I do.
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`09:02:16
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`09:02:18
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`09:02:19
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` Q. Okay. If you don't understand a question,
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`09:02:20
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`could you please ask me to clarify or to repeat the
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`question?
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` Do you understand that?
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` A. Yes.
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` Q. And we'll try to take a break every hour
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`or so. But if you need one sooner, please let me
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`know, and I'll do my best to accommodate you.
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` Is that agreeable?
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` A. Yes.
`
` Q. Okay. Dr. Young, have you been deposed
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`before?
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` A. I have not.
`
` Q. In how many cases have you served as an
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`expert?
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` A. An expert. Two.
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` Q. Two cases. Were those patent cases?
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` A. No, they were not.
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` Q. What kind of cases were they?
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` A. They were related to avionics, and I
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`believe I can say that they were related to accident
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`STANLEY YOUNG, Ph.D. - 5/8/2014
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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`investigations.
`
` Q. Okay. Now, I don't want you to divulge
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`Page 7
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`anything confidential or anything that's subject to a
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`protective order, but did those cases involve you to
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`provide opinions on technology in airplanes?
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` A. They were focused on helping explain how
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`avionics worked.
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` Q. And did you have to evaluate the
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`technology of airplanes in that case?
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` A. I was focused on helping explain how the
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`avionics systems worked.
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` Q. Did those avionics systems relate at all
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`to diagnostic systems on airplanes?
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` A. Some of them did.
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` Q. And could you give me some more detail
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`about those systems, those diagnostic systems, what
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`kind of systems they were, how they operate?
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` A. Let's see. The diagnostics were primarily
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`09:04:35
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`focused on sensors or taking in the sensor readings
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`or interpreting the sensor readings and then saying
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`how those matched up with other boxes or other
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`channels on the aircraft or on the avionics system.
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` Q. Now, did those sensors relate to
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`determining whether a fault had occurred in a
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`STANLEY YOUNG, Ph.D. - 5/8/2014
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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`component on the airplane?
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` A. In some instances, yes.
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`Page 8
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` Q. What kinds of components did those sensors
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`monitor?
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` A. The ones that I focused on primarily were
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`related to the propulsion system and the flight
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`control surfaces, and I believe some of them also
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`related to the landing gear, if I recall correctly.
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` Q. Okay. Are any -- are either of those two
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`cases still pending?
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` A. Hmm. I'm no longer working on them.
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` Q. Were those cases before a Court?
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` A. Not that I know of. I was part of -- I
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`think, as far as I know, I was part of preliminary
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`investigations.
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` Q. By whom were you hired in those two cases?
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`09:06:50
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` A. Let's see. It was the law firm.
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` Q. And who did that law firm represent in
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`those cases?
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` A. What -- could you expand on that?
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` Q. Sure. So, who were the parties in the
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`investigation?
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` A. Let's see. I think in the investigation
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`one of the groups was the aircraft manufacturer, and
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`STANLEY YOUNG, Ph.D. - 5/8/2014
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`Page 9
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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`the other group I believe was associated with the
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`pilot.
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` Q. What kind of airplanes did those cases
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`involve?
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` A. They were focused on a -- what's the
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`model? A Pilatus -- a large, single-engine, turbo
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`prop.
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` Q. Did those cases involve a Boeing airplane?
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` A. No.
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` Q. In either of those two cases did anyone
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`discredit or criticize your opinions?
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` A. Not that I heard, no.
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` Q. Did you testify at a hearing or a trial in
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`those cases?
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` A. No.
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` Q. Did you provide an expert report in those
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`cases?
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` A. No. I was assisting, helping people
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`understand how the avionics systems were working.
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` Q. You said you were helping people
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`understand how the avionics systems were working.
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` Who were those people that you were
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`helping?
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` A. The attorneys.
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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` Q. Do you know the resolution of those
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`investigations?
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` A. No.
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`09:09:21
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` Q. Are you relying on anything you learned in
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`those investigations in providing your opinions in
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`this case?
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` A. No.
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` Q. Dr. Young, have you ever applied for a
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`patent?
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` A. I think my name has been associated with
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`some applications.
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`09:09:39
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` Q. Some applications. Do you know about how
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`09:10:08
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`many that would be?
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` A. Probably between two and six.
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` Q. When would those applications have been
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`filed?
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` A. The applications would have been filed
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`either -- well, between 1985 and probably 2006.
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` Q. Were those applications for U.S. patents?
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`09:10:55
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` A. As far as I know, yes.
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` Q. Were there any co-inventors on those
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`patents?
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` A. Yes. I was not a single name.
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` Q. How many other inventors were there on
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`09:10:59
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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`those patents?
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`09:11:15
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` A. I think it would have ranged from three to
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`09:11:16
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`six.
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` Q. Do you know if any of those applications
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`were granted as U.S. patents?
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` A. I do not, no.
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` Q. Who did you interact with during the
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`application process?
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` A. I think they were -- fairly certain they
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`were in-house attorneys.
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`09:11:34
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` Q. In-house attorneys for a company that you
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`were employed at?
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` A. Correct.
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` Q. Which -- which company would that be?
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` A. It would either have been at Southwest
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`Research or at AVISYS.
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` Q. What was the general subject matter of the
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`technology in those patent applications?
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` A. The ones at AVISYS would have been for
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`techniques to move information around a -- to and
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`from an avionics box.
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` Q. What's an avionics box?
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` A. An avionics box is -- well, an avionics
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`system normally has many components. And a primary
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`component is often referred to as "the box" in which
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`most of the system components are placed.
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` Q. What do you mean by "system components"?
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` A. System components such as connectors,
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`circuit boards, mounting brackets, power supplies.
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`That's probably -- in general. I'm sure there are
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`other boxes that have other components, but those are
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`the main ones that I think of.
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` Q. What's the primary purpose of an avionics
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`box?
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` A. Whatever the -- a piece of avionics is
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`supposed to do.
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` Q. Could you give me some examples of that?
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` A. Yes.
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` Q. Please do.
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` A. One type of box is a radio.
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` Another type of box is a -- a radar.
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` Another type of box is a control system,
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`such as an auto pilot.
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` Those are some -- some examples.
`
` Q. I'd like to talk about your education.
`
`Could you please describe your education after high
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`school?
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` A. Yes.
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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` Q. Go ahead.
`
` A. After high school my Bachelor's work was
`
`in electrical engineering at Rice University.
`
` After the Bachelor's work there was
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`some -- a Master's program, also in electrical
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`engineering, at Rice University.
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` And after the Master's work there was the
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`Doctoral work at -- in electrical engineering at the
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`University of Texas at Austin.
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` Q. Your Master's degree, was that a Master's
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`09:16:23
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`of Science degree or a Master's of Engineering
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`degree?
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` A. Master's of Electrical Engineering.
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` Q. What kinds of electrical engineering
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`courses did you take as an undergraduate?
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` A. As an undergraduate electrical engineering
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`courses. Circuits, systems, communications,
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`controls. Those are the ones I remember right
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`offhand that are specifically related or that are
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`focused on electrical engineering.
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` Q. What kinds of electrical engineering
`
`courses did you take as a Master's student?
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` A. As a Master's student communications,
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`controls, signal processing, computer networks.
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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`Those are the ones that I can remember right offhand.
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`09:18:03
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` Q. Did any of the courses you took as an
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`09:18:08
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`undergraduate student or a graduate student relate to
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`vehicle diagnostic systems?
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`09:18:14
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` A. What type of vehicle diagnostic -- what --
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`can you expand on that?
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` Q. Any type of vehicle diagnostics, whatever
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`you deem that term to mean.
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` A. Hmm. In terms of the course being focused
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`on that or --
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` Q. Any teaching of vehicle diagnostics in any
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`of your courses.
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` A. So, any type of fault-related study?
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` Q. Right.
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` A. Would that qualify --
`
` Q. Sure, yes.
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` A. -- in that type of thing?
`
` Q. Yes.
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` A. My dissertation was focused on supervisors
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`for -- you would think I would remember the exact
`
`title, as much time as I spent on it. But
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`supervisors for systems that can exhibit faults.
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` Q. That was your Ph.D. research. How about
`
`your undergraduate and graduate level courses?
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` A. The ones at Rice for the Bachelor's and
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`Master's, facets of those, in particular the network
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`courses, had aspects of fault identification and
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`tolerance.
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` Q. Would that be fault identification and
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`tolerance in vehicles?
`
` A. In any kind of network.
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` Q. So, it wasn't vehicle-specific, correct?
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` A. It would depend if the vehicle had a
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`network on it.
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` Q. Did you specifically discuss vehicles in
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`those courses?
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` A. We never looked at the application of the
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`networks.
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` Q. After you received your Master's degree
`
`you worked for five years at Southwest Research
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`Institute, is that correct?
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` A. '84, '85, '86, '87, '88. Five to -- well,
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`09:21:07
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`let's see. '85, '86, '87, '88 -- five years.
`
` Q. After having worked for five years, why
`
`did you then decide to pursue a Ph.D.?
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`09:21:18
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`09:21:24
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`09:21:27
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` A. Primarily because there were some areas of
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`study that I wanted to continue with that I could not
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`do at Southwest Research -- well, I could not
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`continue working and do them at Southwest Research.
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`09:21:55
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` Q. Could you please tell me more about those
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`09:22:00
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`specific areas that you were interested in?
`
` A. Yes.
`
` Q. Go ahead.
`
` A. The specific areas were focused on two
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`aspects. One was -- is signal processing. The other
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`is related to system level design, architecture and
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`control.
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`09:22:26
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`09:22:34
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` Q. Design, architecture and control of what?
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`09:22:39
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` A. Systems.
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` Q. What kind of systems?
`
` A. The -- I guess the best way to describe
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`09:22:44
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`09:22:44
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`that is any system that is amenable to a mathematical
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`description.
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`09:23:04
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` Q. Could you give me more details about your
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`09:23:16
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`Ph.D. dissertation?
`
` A. Yes.
`
` Q. What -- what was the research exactly?
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`09:23:20
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`09:23:22
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`09:23:23
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` A. The research focused on a particular type
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`09:23:25
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`of system that can be described with a discrete event
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`09:23:30
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`systems model and how to control those systems if
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`those systems have components or components that can
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`fail.
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` Q. Components that can fail in what kind of
`
`technology, what kind of product?
`
` A. The particular approach focuses on any
`
`kind of system that can be described with a discrete
`
`event systems model. That doesn't specify a
`
`particular technology.
`
` Q. What were some of the specific
`
`technologies you intended that research to apply to?
`
` A. The primary focus is on any system that
`
`can be controlled or has computer-controlled
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`components.
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` Q. Did you have any specific products in mind
`
`09:25:02
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`during your research?
`
` A. Not really. We were focused on anything
`
`with computer components.
`
` Q. Did you develop an algorithm as part of
`
`your research?
`
` A. Yes.
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`09:25:06
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`09:25:10
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`09:25:14
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`09:25:20
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`09:25:22
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`09:25:23
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` Q. And can you give me more details about the
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`09:25:27
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`algorithm?
`
` A. Some details.
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` Q. What was it intended to accomplish?
`
` A. The first algorithm -- well, I guess
`
`depending, the algorithm that's wide -- that's
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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`published is focused on identifying -- or limits on
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`how to identify failures.
`
` Q. What kind of failures would those be?
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`09:25:52
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`09:26:01
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`09:26:06
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` A. Some failure in the system that is -- that
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`09:26:12
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`is captured in the discrete event systems model.
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` Q. And would there be sensors involved in
`
`such a system?
`
` A. There could be.
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` Q. What would be some of the inputs of this
`
`algorithm?
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`09:26:20
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`09:26:33
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` A. The primary input is focused on a node or
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`09:26:34
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`link in the discrete event systems model.
`
` Q. So, I'm sorry. What exactly was the
`
`input, then?
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`09:26:55
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`09:26:58
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`09:27:01
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` A. It would be a detection of a failure of a
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`09:27:01
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`node or a link in the system that is captured in the
`
`discrete event systems model.
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`09:27:04
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`09:27:14
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` Q. So, the input would be whether a system or
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`09:27:16
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`a component has failed or not, is that correct?
`
` A. If that's what the node or the link is
`
`describing.
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`09:27:19
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`09:27:21
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`09:27:26
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` Q. And then what would the algorithm do with
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`09:27:26
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`this information?
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` A. The algorithm is focused on how long it
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`would take to determine that a failure has occurred.
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`09:27:41
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` Q. So, the algorithm would output how long it
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`09:27:49
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`would take to determine whether a failure has
`
`occurred?
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`09:27:53
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`09:27:55
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` A. The algorithm -- could you ask that again,
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`09:27:56
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`please?
`
` Q. Right. So, what would the algorithm
`
`provide as an output?
`
` A. The algorithm takes the model, discrete
`
`event systems model, and then provides the length of
`
`time in which one is guaranteed to be able to
`
`determine if something has failed.
`
` Q. And how did this algorithm determine the
`
`time?
`
` A. It uses the structure of the discrete
`
`event systems model, and that is how it determines
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`09:28:01
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`how long -- and by "long," that's an abstract concept
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`09:28:59
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`in terms of whatever time means for that particular
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`model.
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` Q. What was novel about your research?
`
` A. That particular algorithm, it was the
`
`first time that anyone had provided a bound on
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`estimating how long it would take to determine if
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`something had failed.
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` Q. Was the algorithm a pattern recognition
`
`algorithm?
`
` A. No, not that I would -- I would not
`
`describe it as a pattern wreck anything algorithm.
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`09:29:40
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`09:29:55
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`09:29:58
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` Q. Did your Ph.D. research form the basis of
`
`09:30:01
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`any of your opinions in this case?
`
`09:30:04
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` A. I'm trying to think if there's any related
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`09:30:06
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`components.
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`09:30:36
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` Not that I can think of right offhand. It
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`09:30:53
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`might have, given that I spent many years in school,
`
`but nothing in particular jumps out.
`
` Q. I'd like to go back to discussing the
`
`investigations you previously testified about that
`
`you'd served as an expert in.
`
` A. Okay.
`
` Q. Both of those cases you said involved
`
`diagnostics, correct, diagnostic systems?
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`09:30:55
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`09:30:59
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`09:31:05
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`09:31:08
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`09:31:12
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` A. They involved avionics systems, and often
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`avionics systems have diagnostics in them, yes.
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` Q. Was there anything particularly
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`opined on and evaluated?
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` MS. SAMZ: Objection. Mischaracterization.
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` THE WITNESS: Can you ask again, please?
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`STANLEY YOUNG, Ph.D. - 5/8/2014
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`Page 21
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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`BY MR. BAPNA:
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` Q. Was there anything proprietary about those
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`diagnostic systems that you evaluated?
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` A. The avionics systems that I looked at were
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`made by companies.
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` Q. Were they standard diagnostic systems that
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`you had seen before and were familiar with?
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` A. The avionics systems that I looked at were
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`often found on aircraft.
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` Q. Now, you mentioned one of the diagnostic
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`systems in those investigations related to monitoring
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`landing gear, is that correct?
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` A. The avionics systems are related to -- or
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`some, some of the avionics were related to the
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`landing gear.
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` Q. Could you walk me through how a diagnostic
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`system would determine a fault in the landing gear?
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` A. For an avionics system that controls the
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`landing gear I would need to investigate that in more
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`detail.
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` Q. Did you not investigate that in your
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`investigations?
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` A. Not specifically.
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` Q. Would -- would those diagnostic systems
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`STANLEY YOUNG, Ph.D. - 5/8/2014
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`Page 22
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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`relating to the landing gear have sensors?
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` A. The avionics systems would have -- could
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`have sensors in them.
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` Q. When you say "could have," that means they
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`wouldn't necessarily have to have sensors?
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` A. The avionics systems could or could not,
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`or might not have sensors.
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` Q. I'm talking about diagnostic systems for
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`determining faults in landing gear. Would those
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`diagnostic systems be able to operate without
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`sensors?
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` A. The avionic systems, it would depend,
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`actually. Right, it would depend.
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` Q. What would it depend on?
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` A. The avionics could be open loop.
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` Q. Could you explain that? What does that
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`mean?
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` A. An avionics system that is open loop does
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`not depend on anything coming back from whatever it's
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`doing.
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` Q. So, how would such a diagnostic system
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`determine a fault in the landing gear without
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`sensors?
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` A. The avionics systems, if they are open
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`STANLEY YOUNG, Ph.D. - 5/8/2014
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` STANLEY YOUNG, Ph.D. - 5/8/2014
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`loop, would not have sensors. The avionics systems,
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`if they are closed loop, would have some type of
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`feedback.
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` Q. So, in an open loop system, what would be
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`measuring the state of the landing gear? What
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`components would be measuring the state of the
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`landing gear?
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` MS. SAMZ: Objection. Mischaracterization.
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` THE WITNESS: Could you say that again, please?
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`BY MR. BAPNA:
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` Q. Sure. In an open loop diagnostic system
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`that has no sensors, what component would be
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`measuring the state of the system that's being
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`monitored?
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` A. In an open loop avionics system there
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`would be no sensor coming back.
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` Q. Right. You've already said that. If
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`there's no sensor, how can you determine that there's
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`something wrong with the landing gear?
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` MS. SAMZ: Objection. Mischaracterization.
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`BY THE WITNESS:
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` A. For an avionics system that -- wait. Ask
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`again, please.
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`BY MR. BAPNA:
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