DAVID McNAMARA
`TOYOTA MOTOR CORP. v.
`
`LEROY G. HAGENBUCH
`April 17, 2014
`Page 3
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`Page 1
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AN'D APPEAL BOARD
`
`TOYOTA MOTOR CORP.
`Petitioner
`
`v .
`LEROY G. HAGEN'BUCH
`Patent Owner
`
`/
`
`Case IPR203-13-OD433
`
`Patent 8 , 014 . 9 1'?
`
`The deposition of DAVID MCNAMARA was taken
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`the 11th day of April, 2014. comencing at
`on Thursday,
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`9:00 a.m. _. at the Law Offices of Oblon, Spivak,
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`15 MeClelland. Maier s Neustadt. LLP, 1940 Duke Street.
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`16 Alexandria. Virginia. before Brian M. McDonald. Notary
`1'? Public.
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`REPORTED BY: Brian M. McDonald
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`INDEX
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`April 17 .. 2014
`Deposition of DAVID McNAMARA
`
`6 Examination By:
`7 Mr. Hill
`8 Mr. Matteon
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`Page
`4, 200
`191
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`Page 2
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`Page 4
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`1 APPEARANCES :
`2
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`FOR THE PETITIONER TOYOTA MOTOR CORPORATION:
`ROBERT C. MATTSON. ES UIRE
`Q
`TSKY' ESQUIRE
`
`THOMAS C ' YEBE
`”1°“ 91’1“"
`1940 Duke Street
`Alexandria. Virginia 22314
`Telephone :
`(703) 413-3000
`Facaimile =
`"'03) “3‘22””
`Email : matteon®oblon.com
`
`FOR THE PATENT OWNER LEROY G- HRGEN'BUCH:
`JONATHAN HILL, REQUIRE
`Freeborn & Peters, LLP
`311 South Wacker Drive
`Suite 3000
`Chicago, Illinois 50606
`Telephone:
`(312} 3 50 - 5000
`Facsimile:
`{312) 360-6520
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`Email :
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`jhill@freehorn . com
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`PROCEEDINGS.
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`DAVlD MCNAMARA
`‘
`.
`.
`.
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`a wnness lIereIn. haying been lIrst duly sworn. was
`examined and teslified upon his oath as follows:
`EXAMINATION BY MR. HILL:
`Q. Good morning. Mr. McNamara.
`A Good morning
`1 will be
`Q. My name is Jonallian Hill.
`taking your deposition today. Have you been deposed
`belore'.’
`A. Yes I have.
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`Q. You know [he basics: I'll be asking you a
`series of questions; and you will provide answers to
`the best ol‘your ability.
`[l‘you nced lo lake a
`break at any time, pleasejust let me know: this
`isn't a lesl of physical endurance.
`[‘II also ask
`that your answers be nudihlejust for the sake of
`the court reporter lo creale a record.
`I would like
`to show you what's been produced as Toyota Exhibit
`1008.
`
`A. Thank 3'0".
`Q. And do you recognize this document?
`A. Yes, I do.
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`Q. Okay. This is a declaration that has your
`
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`Barkley Court Reparters
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`(11) Pages I - 4
`OWNER Ex. 2054, p.
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`
`
`

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`DAVID MeNAMARA
`TOYOTA MOTOR CORP. v.
`
`LEROY G. HAGENBUCH
`April 17, 2014
`Page 7
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`Page 5
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`signature?
`A. Yes.
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`Q. Sure. did you consider any other
`references?
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`Q. Okay. And this declaration has been
`submitted in connection with |PR2013m004831 is that
`correct?
`
`I believe so, yes.
`A.
`Q. This relates to certain claims of'U.S.
`Patent No. 80|491 7'?
`A. Yes.
`Q. Okay. Sir, are you being compensated for
`your time in this matter?
`A. Yes, I am.
`Q. Okay. And how are you being t:oliipet't:»;aled'.J
`A.
`lam being compensated by check monthly --
`or when l invoice, excuse me.
`Q. Do you charge an hourly rate?
`A. Yes, I do.
`Q. And what is that rate'.’
`A. The rate is two hundred dollars per hour.
`Q. And [ believe you said your compensation
`does not depend on the outcome of these proceedings:
`is that correct?
`A. Yes.
`
`Q. Mr. McNamara. your declaration concludes
`that certain claims of' the 9] 7' Patent are obvious
`
`over Aoyanagi in view oi‘Oishi.
`A. Aoyanagi in light of Oislti and Aoyanagi in
`light of Vollmer.
`Q. And these three references. Aoyanagi.
`Oishi and Vollrncr are the bases for your conclusions
`on obviotlsncss?
`A. Yes.
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`A. Oh. references. yes.
`Q. Okay.
`A.
`I considered the references that are
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`listed in my report and they're listed, materials
`considered, paragraph [3, I list Aoyanagi and I list
`Oishi, Hamilton.
`1 list Trevor Jones, Fully
`I
`Integrated Truck Information and Control Systems.
`list Omni'l‘RACS, two-way satellite mobile systems and
`then Mr. Hagenbuch's S.A.E. paper. Truck Mobile
`Equipment Performance Monitoring Management
`Information System.
`Q. And that's the universe ot‘documents you
`looked at for purposes of preparing yottr
`declaration?
`A. My recollection today. yes.
`Q. You didn't consider any other patents as
`possible grounds of'invalidity?
`A.
`Invalidity?
`Q. C'otrect. obviousness.
`A. Okay, thank you. The scope of this report
`was those materials.
`
`Q. Okay. So you considered references listed
`here in paragraph l3 of' your declaration?
`
`A. Yes.
`Q. And your declaration states that you've
`devoted your entire career to the field of
`automotive electronics; is that right?
`A.
`I think I characterized my career a little
`bit broader. But that's, you know, of course,
`correct. automotive electronics, but I would also
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`Page 5
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`Page 8
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`probably broaden it to transportation,
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`Q. How did Aoyanagi come to your attention?
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`transportation systems in general.
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`A. Through looking at prior art.
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`Q. Okay.
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`Q. How did Oishi come to your attention?
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`A. Trucks, fleets, trains, very broad
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`A. Same process. of looking at the prior art.
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`transportation. a lot of the information is shared
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`Q. Same answer for Vollmer?
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`amongst all those different professions and areas.
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`A. Vollmer looking at the prior art, yes.
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`Q. Okay. Now, is it fair to say that the
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`Q. How did you go about your search through
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`term automotive electronics refers to any electrical
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`the prior art‘.’
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`component ofa road vehicle?
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`A.
`I looked at what was available through
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`A. Automotive electronics to any component
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`discussions with attorneys and the Oblon attorneys
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`of...
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`and my own understanding of prior art out there.
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`Q. Electrical t.‘t:)n|‘tponent‘:1
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`Q. Did you conduct any searches on the PTO
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`A.
`...electrieal component. We tend to use
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`web site?
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`broadly eteetri -- sorry to parse the words — but
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`A. No.
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`we tend to think in terms of electrical.
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`Q. Did you consider any other references as
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`electronics. sensors, microcomputers,
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`possibie grounds for concluding that certain Claims
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`communications. so when we use the term electronics.
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`ofthc 9| 7 patent were obvious?
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`A. Can you repeat the question.
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`And then as I mentioned. I would be viewing the
`
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`Barkley Coart Reporters
`
`OWNER Ex. 2054, pt? Pages 5
`
`8
`
`

`

`DAVID MeNAMARA
`TOYOTA MOTOR CORP. v.
`
`LEROY G. HAGENBUCH
`April it, 2014
`Page 11
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`Page 9
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`application of sensors, computers and the
`communications to a broad array of transportation
`issues of which automotive cars is a subset.
`Q.
`lsee. Now, would the field ofautomotive
`electronics includc engine control units?
`A. Yes.
`Q. Okay. And engine control units. as |
`understand. perform a number of functions. one of
`which would be to control air fuel ratio: is that
`correct?
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`electronics. correct?
`A. Yes.
`0. Okay. And the claim ol“)! '3’ patents are
`not directed to tlte field ot‘engine ~— excuse me. to
`the field oftlansmission electronics. correct?
`A. What do you mean about the term directed?
`I‘m not famiiiar with that terminology.
`Q. Okay. Do the claims of the 9! 'i' Patent
`relate in any way to the field oftransmission
`electronics?
`
`A. Well, I think that my understanding. I'm
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`A. Amongst others. yes. Air fuel ratio and
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`having a little problem with the word directed.
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`other functions associated with controlling the
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`would say the ciaims, you know, talk about engine
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`engine, yes.
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`RPM, they talk about sensors that are measuring
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`Q. And would control ofignition timing be
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`what's happening with the engine and the
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`one ofthose other functions?
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`transmission and they are in the area of diagnostics
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`A. Yes.
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`and diagnostics is a broad subject that covers a lot
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`Q. What‘s the goal of'ignition timing? Is it
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`of the components on a vehicle.
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`fair to say that the goal ot‘ignition timing is to
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`0. Okay. Well. that‘s fair enough. And I
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`optimize powerand fuel economy?
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`think we‘ll agree that the lield ot‘automolive
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`A. There are actually three dimensions for
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`electronics would include event data recorders.
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`engine controls and many variables ofcontrol which
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`right?
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`ignition is one, but in my career we would look at
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`A. What do you mean by event data recorders?
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`it from the viewpoint of performance; we would look
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`The common, just being clear. What do you mean by
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`at the idea of fuel economy and emissions. Those
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`were the three big goals of an engine control system
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`event...
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`Q. Devices that store data relating to
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`to optimize those three big goals, [ would call it.
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`vehicle parameters.
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`Q. Okay. And another function of engine
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`A.
`[would view event data recorders. that's
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`control unit would be the control idle speed: is
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`terminology...
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`that correct?
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`(Speakers overlapping)
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`A. Yes, idle speed along with ignition and
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`Q. Fair enough. we want a clear record of
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`other parameters. yes.
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`your understanding.
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`Q. Would timing control be among those
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`A. Yes, that is, using your word directed is
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`considerations?
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`capturing chronological events around a crash, of
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`A. Yes.
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`which I would say is a sub-set ofdiagnostics
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`Q. Okay. cooling system control.
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`systems as a whole.
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`A. Cooling system control.
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`Q. Okay.
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`Q. Engine cooling system?
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`A. Specialized case.
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`A. Engine cooling, thank you. Trying to give
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`Q. Okay. And would the field ofautomotive
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`the most accurate answer I can here. We tended to
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`electronics also include chassis electronics such as
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`measure the engine coolant. the engine coolant would
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`antinloek braking systems?
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`be input to an engine control system, especially as
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`A. Yes.
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`we can imagine, Washington on a cold day, you know,
`1‘?
`Q. Would it include traction control systems?
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`so it's, I tend to view it as one ofthe sensor
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`A. Yes.
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`inputs, yes.
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`Q. Electronic brake distribution, variable
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`Q. Okay. Now. would you say that the claims
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`brake pressure?
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`of the 9 l 7 patent are directed to the lield ol‘
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`I guess I would
`A. Variable brake pressure.
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`engine control unit design?
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`call it electronic brake boost. I‘m just trying to
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`A. No.
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`relate it to what I understand. I'd probably call
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`Q. Okay. And the field ot‘automotive
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`it something a little bit different.
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`electronics also would include transmission
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`
`Barkley Court Reporters
`
`3 P
`OWNER Ex. 2054, 5’3 ”g“
`
`9 - [2
`
`

`

`DAVID MeNAMARA
`TOYOTA MOTOR CORP. v.
`
`LEROY G. HAGENBUCH
`April 17, 2014
`Page 15
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`Page 13
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`Q Okay. And are the claims ofthe 9H'
`Patent related in any way to the field ofchassis
`electronics?
`A. Could you hand me the 917 Patent, please?
`Q. Sure.
`A. Yes.
`Q.
`l‘m handing you what has been labeled
`Toyota Exhibit IOOI.
`A.
`[would say, yes, with the qualification
`that it does include a steering wheel sensor of
`which chassis control systems would use a steering
`wheel sensor as an input to the chassis system. but
`I do not see, as I remember, a specification talking
`about trying to control the chassis and usually in
`chassis control systems you're trying to control
`steering in the attitude of the vehicle; that's what
`we used to do at Ford with load leveling.
`I did not
`sec or remember load leveling, so [ know they talk
`about a sensor, is my answer.
`Q. Okay. And the field ol' automotive
`electronics would include sai'cty electronics such as
`air bag deployment systems. correct?
`A. Yes.
`Q. That would also include, for example,
`collision avoidance systems?
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`infotainment, yes.
`Q. But the claims oftlte 9]? Patent. they're
`not directed in any way to the field ofinfotainment
`systems. correct?
`A. Stiii having a little difficulty with
`directed.
`I would say talk about or mention.
`Q. Related?
`I would say there's the
`A. Related. yes.
`mention ofa display, a very extensive display and
`of course of displays are part of an infotainment
`system so it does talk about a display.
`Q. That's a specification.
`A. Yes. Oh. sorry, you said claim. right?
`Q. Correct?
`A.
`I‘m sorry. Okay, I agree, it does not say
`infotainment.
`Q. Yeah. Thank you. The declaration. that's
`paragraph three. describes your work as including.
`about halfway down the page, the development and
`integration of various motor vehicle technologies.
`Are you with me‘?
`A. Where are you? Paragraph three?
`Q. Paiagraph threc. about halfway down il‘tC
`page. For example. i have been involved in the
`development and integration ofvarious motor vehicle
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`Page 14
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`Page 16
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`A. Yes.
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`Q. Do you see anything in the 9] T patent that
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`relates to those types ol‘ sal‘cty electronics?
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`MR. MATTSON: Objection to form.
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`A. Reiatcs to?
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`Q. Yes.
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`A.
`I would say that they mention, the only
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`sensor I see mentioned — can you repeat the
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`question.
`I forgot the sensors you were referring
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`to.
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`[ referred to air bag deployment systems
`Q.
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`and collision avoidance systems.
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`A.
`[see a mention of an Accelerometer but
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`the field of automotive electronic air bag systems
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`are much more sophisticated. Just the air bag
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`sensor is the control auger and the actuator and
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`those elements are missing.
`1‘?
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`Q. Okay. And the field ot‘automotivc
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`(Whereupon. a recess
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`electronics would also include what's termed
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`was taken)
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`infotainment systems. col'rcct‘.’
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`(By Mr. Hill) Mr. McNamara. could you
`Q.
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`A. Yes.
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`describe for me what embedded vehicle controllers
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`Q. You have a fair amount ofexpericncc in
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`arc'.’
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`that field. rigltl'.J
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`A. The question is what they are or...
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`A. Yes, that is largely my career, a large
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`part of my career, later part of my career was
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`Q. Yes. what they are.
`
`
`technologies.
`A. Yes.
`Q. Can you tell me what you mean by
`integration? is that simply the building of
`electrical solo-systems.J
`A. No. no. Sorry. I'm just thinking of my
`answer. Integration in the context of my
`development, you know. an engineer in, over my
`career has been combining systems to provide greater
`function in a way that you give performance of both
`systems with the highest quality, meaning cost
`targets. You know, you have a series of goals when
`you combine, so a simple term would be combining but
`in a way in which you do not compromise other
`performance quality and costs, goals.
`Q.
`1 sec.
`MR. HILL: Can we go ot‘t‘the record for a
`moment.
`
`Barkley Court Reporters
`
`(4) Pages 13 - 16
`OWNER Ex. 2054, p. 4
`
`

`

`DAVID McNAMARA
`TOYOTA MOTOR CORP. v.
`
`LEROY G. HAGENBUCH
`April 17, 2014
`Page 19
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`Page 1?
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`A. Okay. Embedded controllers is a term that
`means taking a controller, usually a microprocessor
`which is a CPU in memory' and instead ofit being on
`your desk as form ofa PC or an office automation,
`it's usually used in the sense of now embedding,
`putting it into a machine to control the performance
`of that machine or to control that machine in a
`general sense.
`Q. Okay.
`It sounds like you were perhaps
`distinguishing the mechanism from general purposes
`procc55ors?
`A. Well. no ] was saying. I was saying
`usually the term is that embedded controllers, that
`you‘re taking CPU and memory and putting it into a
`machine to control the machine. you're embedding it.
`I‘m defining the adjective in the sense. what it
`means to embed.
`Q. Okay. And you worked on these types of
`controllers?
`A. Yes.
`0. Okay. Were the controllers you worked on
`all electrical or have you worked on the mechanical
`controllers?
`A. Okay. Sol have worked on both, to answer
`the question. And botlt mechanical in the sense of
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`O. Okay. Do you recall what kind ot‘adaptive
`control that was? Was it. for example. tnodel
`reference adaptive control.
`A. Model reference.
`I would say that most of
`the systems on the cars are not model reference but
`rather reacting to the behavior of sensors on the
`car and responding to more strategies, more adaptive
`strategies.
`I guess I would say that that's more
`the class of adaptive control and engine controls.
`And I worked on the pressure sensors, to be clear.
`1 provided input for making those kind of adaptive
`decisions.
`I worked on the sensors.
`Q. May I infer from solne of your previous
`answers that these control systems you've worked on
`are feedback controllers as opposed to open loop
`control?
`A.
`I've probably worked on both kinds. yes.
`Q. Okay. And have you worked with both
`analogue and digital control systems?
`A. Mostly digital because [ came in a world
`where we were replacing analogue with digital so I
`could say both because I was replacing analogue
`systems with digital electronics.
`Q. You had mentioned working on pressure
`sensor controls.
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`Page 18
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`Page 20
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`A. Yes.
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`usually you don't say controllers. you'll say
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`Q. Okay. Can you tell me a little bit about
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`mechanisms, we would say mechanical systems, a
`2
`what exactly your role was working on pressure
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`handle on a door operating the locks, and then they
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`sensor controls?
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`become electrical which is now controlled by a
`4
`A.
`I guess technically my answer is not
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`switch and wiring and then even can go to electronic
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`pressure sensor control. You know, I didn't work on
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`being part of a module that is actually controlling
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`controlling pressure.
`I worked on measuring
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`the locks and now on a vehicle network. That
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`pressure.
`I just...
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`progression from mechanical to integrated system
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`Q. Okay. measuring pressure?
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`where it is communicating with other systems on the
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`A. Measuring pressure.
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`car.
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`Q. And pressure l‘rom what'.’
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`Q. Okay. Have you done any non~linear
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`A. Two important operating pressures in the
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`control work?
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`car manifold pressure and barometric pressure.
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`A. What do you mean by non-linear control?
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`Q. Why are those important?
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`0. Well. for example. adaptive control is
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`A. Basically to control the air-fuel ratio on
`15
`often thought ol‘els non~linear.
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`the car you do what is called -- bad terminology.
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`A. Okay. I see.
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`You do a speed density calculation. And part of the
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`Q. Bang-bang relays.
`1‘?
`speed density caiculation to determine the amount of
`18
`I've worked
`A. Yeah. thank you, thank you.
`18
`air coming into the throttle body or the car, you
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`on adaptive systems and most of the things in your
`19
`need to know How so you need to know the pressure
`20
`control have non-linear behaviors.
`20
`of the manifold and you need to know the barometric
`21
`Q. The world is basically non—linear
`21
`pressure. And ofcourse you would be controlling
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`A. Yeah. it's a car. it‘s not a -- so in
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`fuel injectors so you will know the mast coming in
`23
`other words. they're non-linear in nature but I have
`23
`and you can do this calculation in the computer as
`24
`worked on adaptive control systems in the area of
`24
`to figure out your air fuel ratio which is very
`25
`engine controls.
`2 5
`
`
`Barkley Court Reporters
`
`5 l"
`* 17-20
`OWNER Ex. 2054513). 5";Ls
`
`

`

`DAVID MeNAMARA
`TOYOTA MOTOR CORP. v.
`
`LEROY G. HAGENBUCH
`April 17. 2014
`Page 23
`
`Page 21
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`important for catalyst and the behavior ofthe
`catalyst and so this -- so as you can see. pressure
`becomes a very critical input to those calculations.
`Q. Did you work on the controller aspect of
`maintaining the proper air to fuel ratio?
`A. Controller meaning?
`Q. Well. you said that you were working on
`the sensor to take the pressure reading. correct?
`A. Right.
`Q. And so that reading presumably fed to a
`control system?
`A. Right.
`Q. Okay. Did you actually work on the
`control systetn?
`A. Yes, I did.
`Q. Okay. Can you tell me what your role was?
`A. Mainly in the control system was working
`with the engineers over the accuracy of the pressure
`sensor. What the pressure sensor accuracy should
`be. So I was involved in the modeling, you know,
`what the controller was doing. And I was arguing in
`a constructive way for looser tolerances on the
`pressure sensor.
`Q. Okay. But yen weren't involved, for
`example. in terms ofselceting what kind of feedback
`
`are input to an engine control system. Then much
`1
`ntore into I guess the next would be air bag
`2
`Accelerometers, I was responsible for an air bag
`3
`diagnostic module. So we were looking at the
`4
`behavior of the accelerometers, and l was more tlte
`5
`system engineer. you might say.
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`Q. What does that mean?
`7
`A. That means I was supervisor, had
`8
`responsibility for all aspects of the system, and
`9
`into navigation, what is called GPS positioning of
`10
`different types. different radio technologies. GPS.
`11
`12 We were very excited about the satellites coming up
`13
`in the 80's and looking at communications and you
`14
`might say communications. looking at the
`15
`possibilities there. And then more into collision
`16
`warning systems.
`I launched, as my CV says. on the
`1'?
`Jaguar 2000 XKE. adaptive cruise control.
`18
`radar-based system. And we were using it to
`19
`determine the headway between vehicles and also we
`20
`were very excited in that technology because we were
`21
`looking at a millimeter wave technology that allowed
`22
`us to do coiiision warning if we wanted to.
`23
`Q. About what time frame was that?
`24
`A.
`[started working on that system in '95.
`25
`Then about that time, in that time frame, as shown
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`gain you would have in the control system?
`A. Feedback gain. No. other than, you know1
`helping them understand how the sensor should behave
`and what the feedback gain should be.
`I don't think
`we thought of it in terms of feedback gains because,
`you know. the engine controls had multiple control
`ioops and some of them are open. quite frankly. you
`know, so it was a very complex system. so that's a
`difficult question to answer. Whether that process
`was something I really gave input to I guess is the
`best answer.
`Q. Okay. You mentioned working on a pressure
`sensor in this particular context. Can you tell me
`what, if any other, kind ofsensors you have worked
`on?
`In my whole career?
`A.
`Q. We can start. And ii‘this calls for an
`obscenely long narrative. then we'll curtail the
`discussion.
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`by my CV. I also worked on low cost sensors;
`ultrasonics.
`Q. You said low cost?
`A. Low cost. lower cost positioning --
`excuse me. low cost collision warning sensors. Like
`ultrasonic sensors. The kind of technology you
`would find in a camera for ranging, that kind of
`ultrasonics, and we adapted it and integrated into
`the bumper of Windstars. And we were the lirst in
`the United States to provide the customers with high
`reliability, that technology. And then, let's see.
`what other sensors. And others. I'm sure but those
`are - so pretty much every sensing technology that
`can go on a car I have had some experience with.
`Q. Let me just go through a few in
`particular; this may jog your recollection.
`A. Okay, sure.
`Q. You did mention acceleration sensors. You
`worked on those?
`
`A. Yes.
`20
`I‘ll let you cut it off. How about a
`A.
`20
`Q. Okay. And you mentioned the temperature
`21
`chronological order.
`It will help me remember.
`2 1
`sensors. I believe.
`22
`please. So first pressure sensors of all kinds and
`22
`A. Yes.
`23
`technologies because we were trying to select the
`2 3
`Q. More specifically. those temperature
`24
`technology. Temperature sensors. crank shaft
`24
`sensors were located in what part of the vehicle?
`25
`position sensors, pretty much all the sensors that
`25
`
`
`Barkley Court Reporters
`
`6 l"
`* 21-24
`OWNER Ex. 2054513). 6"“
`
`

`

`DAVID McNAMARA
`TOYOTA MOTOR CORP. v.
`
`LEROY G. HAGENBUCH
`April 17, 2014
`Page 2?
`
`Page 25
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`temperatures are a problem. If you're in Minnesota
`and y'ou have low temperature, all ofa sudden the
`oil is now going to absorb moisture so actually both
`extremes are an issue.
`Q. Okay.
`A. Yeah, yeah.
`Q. And ] apologize ifyou'v'c already stated
`this. but have you worked on oil pressure sensors?
`A. Yes.
`Q. For lubrication, that sort of oil?
`A. Yes.
`Q. Okay. How about tire pressure sensors?
`A. Yes. Now. worked on the sensor means
`means knowing how the sensor works and using the
`output for one of the products I was -- yes, that's
`the sense of being, when you say worked on, you
`know.
`Q. Okay.
`A. Yeah, I used that sensor in an application
`sense.
`Q. Have you had any experience with throttle
`positions sensors?
`A. Yes.
`Q. And what lype ot‘ sensors were those?
`That‘s probably a had question. How did you
`
`measur v- did the sensors that you worked with
`measure throttle position?
`A. Basically, we had a mechanical linkage to
`the throttle and it went to, I guess for lack ofa
`better term, more accessible term, a potentiometer.
`You know. it went to a resistive coatingm a disk
`with a resistive coating with a wiper. And so we
`would measure the change of resistance as position
`of the throttic.
`
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`A. Well, we used tliermistors about
`everywhere. They used them in engine coolant, air
`temperature and climate control.
`Q. Okay.
`A. We used those very affordable sensors any
`time you want to measure temperature. and I also
`launched an outside ambient air temperature and put
`that sensor in a bumper and that's when you look at
`your dash and you see your outside temperature. So
`I mentioned four types of temperature sensors
`throughout the car.
`Q. Okay. And have you worked with
`lemperalures —~ excuse me. strike thal. Sensors for
`measuring the temperature of oil?
`A. Forgot that one. [actually have a patent
`that — should not have forgotten that. It's an oil
`level sensor of which we adapted a thermistor in the
`oil level sensor and measured the engine oil
`temperature as a key input to make a determination
`of when you can change your oil. Sol have a lot of
`experience in oil temperature.
`I mean,l have
`experience in the packaging of the sensor to go in
`a car.
`I guess that‘s where I was really focused.
`Q. Can you jusl brie Ily tell me why it is
`imponant to measure engine oil temperature?
`
`In a general vehicle environment?
`A.
`Q. Yes.
`A. Okay. It's one of many indications of
`potential problems. okay, in the failure modes in
`the car. of the vehicle. A lot of things can cause
`the oil temperature to increase, and you usually
`have a fault trigger or some understanding that, you
`know, you need to look at other things, other
`sensors on the vehicle and see if this rate of
`
`Page 25
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`Page 28
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`Q. That was mounted on a pivot point?
`10
`change or this temperature is important. So it can
`10
`A.
`It was -- good question.
`It depends on
`11
`be one of the inputs to your diagnosis...
`11
`the execution.
`I can remember them and throttle
`12
`Q. Okay.
`12
`bodies being, you know, off to the side of the
`13
`A.
`...ofa problem.
`13
`throttle. Usually we did not want to have a big
`14
`Q. Okay.
`14
`linkage between the sensor and the, you know. and
`15
`A.
`It can also. it's also an important fluid
`15
`the throttle because it's a source of error. So you
`16
`in the vehicle that needs to be changed. and we used
`16
`try to mount the sensor by the measure end, the
`17
`it to determine the life of the vehicle. [fyou're
`1‘?
`thing you're measuring which is a problem in
`18
`in an environment where you're running at a high RPM
`18
`environment conditions ofengines.
`19
`and even driver abuse, you can elevate the oil
`19
`Q. Have you worked on any sensors that could
`20
`temperature significantly and find yourself needing
`2 0
`be used in measuring the ground speed of a vehicle?
`21
`to change the oil quicker than if you're doing
`2 1
`A. The actual speed of the vehicle over the
`22
`expressway driving or moderate driving.
`22
`ground?
`23
`Q. Higher temperatures lend lo cause oil
`23
`Q. Yes. linear speed.
`24
`degradation?
`24
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`A. 0h,ycs. Yeah, yeah. Actually, low
`25
`A. Not the distance traveled?
`
`
`Barkley Court Reporters
`
`(7’) Pages 25 - 28
`OWNER Ex. 2054, p. 'i'
`
`

`

`DAVID McNAMARA
`TOYOTA MOTOR CORP. v.
`
`LEROY G. HAGENBUCH
`April 17, 2014
`Page 31
`
`Page 29
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`Q. Right.
`A. Not what's happening at tlte wheels. yeah.
`Yes, mainly' hall] effect type technologies for
`measuring wheel speed, and then also. you know, more
`recently in my career GPS, Global Positioning
`Satellite positioning systems.
`Q. What is hall effect as that phrase is
`used‘?
`
`A. Hall effect?
`0. Yes. can you tell me what that is'?
`A. Hall effect. Magnetic field to flow in a
`device.
`Q. Okay. And have you worked on any brake
`sensors?
`A. Yes.
`Q. Okay. What kind of brake systems have you
`worked on'?‘
`
`A. Mainly, in the area of on and oil
`switches. determining whether you're in park or. you
`know. car's moving, very important. Yeah.
`0. Okay.
`A. And then also pressure sensors in general,
`yes.
`In the brake Cylinder?
`Q.
`A. No, mainly manifold pressure but the sante
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`would indicate that the brake pedal is being pressed
`or a brake light is on'?‘
`A. Well. that‘s the sensor usually. the
`sensor that we're getting the output from. 0h,
`excuse me. Oh. you're talking, yea h, between park
`and brake, yes. So we would use both, either one
`would be available. I'd have to think but different
`cars have different infotations. You know, I'm not
`
`quite sure where that sensor is, btlt we're using
`the brake pedal or a separate sensor; we're probably
`using the brake pedal sensor.
`Q. Okay.
`lgot a little confused.
`A.
`I'm a little bit, going back in my memory
`bank too. trying to reinemher.
`Q. The brake may or may not be on when the
`car is in park. right?
`A. Let me think about this a little bit.
`
`I
`
`think the answer is depending on the car and whether
`it has a network or not. We could be using
`information from the chassis control module that has
`a brake sensor and determining the infotainment
`system would be getting a message of the state of
`the car, hitting a brake or is a parking brake on
`and then other cars have independent sensors.
`Q. Okay.
`
`
`
`
`Page 30
`
`Page 32
`
`A. But it‘s been a while since I've worked on
`1
`principle. Variable brake boost, I've worked on for
`1
`those specific systems.
`2
`adaptive cruise control, more of an actuator. But
`2
`Q. Fair enough. Have you done any work with
`3
`you have to measure the pressure of the actuation as
`3
`sensors that would indicate whether ot' not a seat
`4
`feedback to the actuator. yes.
`4
`bell is fastened?
`5
`Q. Okay.
`] thought y'ou said you have done
`5
`A. Yes.
`6
`work on a sensor for measuring brake on—ofl‘status.
`6
`in what eontext'.’
`Q. Okay.
`7
`Did ] hear you correctly‘?
`7
`A. Mainly that would be part of restraint
`8
`A. Yes.
`B
`systems.
`I did not have assignments directly in
`9
`Q. How did that sensor function?
`9
`restraint systems but I was involved in the planning
`10
`A. Well. mainly there's a break sensor on the
`10
`of those systems. So [was part of the evaluation
`11
`cars, and we would use the output to determine if
`11
`of systems. passive restraint that would use. you
`12
`the car was in park. and so you could turn on your
`12
`know. those sensors and -- yeah.
`13
`navigation system. You use the output of that
`13
`Q. Okay. Why was it important at least in
`14
`sensor.
`14
`your experience to know the status ofa seat belt'.’
`15
`Q. The sensor...
`15
`A. Well, in passive restraint systems, I‘m
`16
`A.
`It gives an output to the navigation
`16
`thinking of the system that in the 30's would. you
`17
`system so brake state is a very important part of
`1‘?
`know. which was mandated, would tell you that your
`18
`infotainment, knowing when to turn the infotainment
`18
`seat belt would come into position, so we were
`19
`on and off. Certain infotainment systems need to be
`19
`determining, that‘s when we first started working on
`20
`off when the car is moving. Rather. it can be on
`20
`seat belt Switches for those of kind of systems.
`21
`when you‘re in park.
`21
`Later in my career we started. I was working with
`22
`Q. So the sensor that you worked on indicates
`22
`seat belts where — I don't know how to put this
`23
`whether the car is in park mode?
`2 3
`nicely -- we were annoying our customers at Ford
`24
`A. Yeah. yeah.
`24
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`0. Okay. Have yet: worked on any sensors that
`25
`that they needed to put their seat belt on. And [
`
`
`Barkley Court Reporters
`
`{8) Pages 29 - 32
`OWNER Ex. 2054, p. 8
`
`

`

`DAVID MeNAMARA
`TOYOTA MOTOR CORP. v.
`
`LEROY G. HAGENBUCH
`April 17, 2014
`Page 35
`
`Page 33
`
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`was involved in the discussions over whether we
`should do that or not.
`Q. What time period was that?
`A. Probably around 2000. It was an idea
`