Page 1
`
` ** MICHAEL NRANIAN **
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TOYOTA MOTOR CORP.,
` Petitioner,
` vs. Case IPR2013-00483
`LEROY G. HAGENBUCH, Patent U.S. 8,014,917
` Patent Owner.
`_______________________/
`
` ORAL DEPOSITION OF MICHAEL NRANIAN
` Chicago, Illinois
` TUESDAY, JULY 8, 2014
`
`REPORTED BY:
`DEBORAH HABIAN, CSR, RMR, CRR, CBC
`JOB NO. 82045
`
`TSG Reporting - Worldwide 877-702-9580
`
`1
`2
`3
`
`4 5
`
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`TOYOTA Ex. 1017, page 1
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
` ** MICHAEL NRANIAN **
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TOYOTA MOTOR CORP.,
` Petitioner,
` vs. Case IPR2013-00483
`LEROY G. HAGENBUCH, Patent U.S. 8,014,917
` Patent Owner.
`_______________________/
`
` ORAL DEPOSITION OF MICHAEL NRANIAN
` Chicago, Illinois
` TUESDAY, JULY 8, 2014
`
`REPORTED BY:
`DEBORAH HABIAN, CSR, RMR, CRR, CBC
`JOB NO. 82045
`
`TSG Reporting - Worldwide 877-702-9580
`
`1
`2
`3
`
`4 5
`
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`TOYOTA Ex. 1017, page 1
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
` ** MICHAEL NRANIAN **
`
`Page 2
`
` TUESDAY, JULY 8, 2014
` 9:06 A.M. CST
`
` Oral deposition of MICHAEL NRANIAN,
`held at the offices of Freeborn & Peters, LLP,
`311 South Wacker Drive, Suite 3000, Chicago,
`Illinois, pursuant to notice before
`Deborah Habian, CSR, RMR, CRR, CBC.
`
`TSG Reporting - Worldwide 877-702-9580
`
`1
`
`2 3 4 5 6
`
`7
`
`8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`TOYOTA Ex. 1017, page 2
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 3
`
` ** MICHAEL NRANIAN **
` A P P E A R A N C E S
`
`ON BEHALF OF THE PETITIONER:
` OBLON SPIVAK McCLELLAND MAIER & NEUSTADT
` BY: ROBERT MATTSON, ESQ.
` 1940 Duke Street
` Alexandria, Virginia 22314
`
`ON BEHALF OF THE PATENT OWNER:
` FREEBORN & PETERS
` BY: JONATHAN HILL, ESQ.
` 311 South Wacker Drive
` Chicago, Illinois 60606
`
`TSG Reporting - Worldwide 877-702-9580
`
`1
`2
`
`3 4
`
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`TOYOTA Ex. 1017, page 3
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 4
`
` ** MICHAEL NRANIAN **
` I N D E X
`WITNESS: PAGE
` MICHAEL NRANIAN
` Exam by Mr. Mattson ........... 5
`
` PREVIOUSLY MARKED EXHIBITS
`NUMBER DESCRIPTION PAGE
`Exhibit 1001 U.S. Patent 8,014,917 6
`
`Exhibit 1003 Aoyanagi reference 14
`
`Exhibit 1005 Oishi reference 14
`
`Exhibit 1007 Vollmer reference 14
`
`Exhibit 2057 M. Naranian Declaration 5
`
`TSG Reporting - Worldwide 877-702-9580
`
`1
`2
`3
`4
`5
`
`6 7
`
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`TOYOTA Ex. 1017, page 4
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 5
`
` ** MICHAEL NRANIAN **
` (Witness sworn at 9:06 a.m. CST)
`
` MICHAEL NRANIAN,
`called as a witness herein by the Petitioner,
`having been first duly sworn, was examined and
`testified as follows:
` DIRECT EXAMINATION
`BY MR. MATTSON:
` Q. Good morning, Mr. Nranian.
` A. Hi.
` Q. You're here today to -- for your
`deposition relating to your declaration filed
`in IPR2013-0483?
` A. Okay.
` Q. Is that why you're here today?
` A. Yes.
` Q. Okay. And you do know why you're here
`today, right?
` A. Yes.
` Q. Okay. I'm going to hand you a copy of
`your declaration that's been introduced as
`Exhibit 2057 already. That is your declaration,
`right?
` A. Yes.
`
`TSG Reporting - Worldwide 877-702-9580
`
`1
`2
`
`3 4
`
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`TOYOTA Ex. 1017, page 5
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 6
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
` Q. And you've provided opinions relating
`to U.S. Patent 8,014,917 to Hagenbuch?
` A. Hagenbuch, yes, sir.
` Q. I'm going to hand you what's already
`been introduced as Exhibit 1001, which is a copy
`of the -- that patent. Is it okay if we refer
`to it as "the '917 patent"?
` A. Absolutely.
` Q. Can you tell me in your own words what
`you think the invention is in that patent?
` MR. HILL: Objection, calls for a legal
`conclusion.
` THE WITNESS: Well, as I said in my
`declaration describing it, "The '917 patent
`describes a comprehensive system for securely
`storing and/or transmitting information
`permitting accident reconstruction, evaluation
`of driver behavior, analysis of component and
`system diagnostic information and critical
`vehicle system and component parameters for
`potentially termination of component and system
`design and/or manufacturing defects and
`enhancements to emergency responses to a
`collision.
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 6
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 7
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
` There's generally two types of sensors
`in the '917; production-related and vital signs.
`Production-related sensors generally monitors a
`vehicle's performance. Production performance
`of the vehicle is generally evaluated and the
`amount of work done by the vehicle and the unit
`of time; for example, miles per hour, tons per
`hour and the like.
` And examples of production parameters
`include engine RPM, throttle position, distance
`traveled, ground speed and brake status.
` The vital signs refer to the health of
`the vehicle and indicate whether a component or
`subassembly is operating in a critical state;
`i.e. a state that if maintained will cause the
`component or subassembly to fail.
` Examples of vital signs include engine
`oil temperature, engine oil pressure and tire
`pressure. Vital signs also monitor whether the
`vehicle is involved in a collision."
` I can go on, but, you know, they're --
`BY MR. MATTSON:
` Q. Okay. Can you just tell me what
`paragraphs of your declaration you're reading
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 7
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 8
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
`from?
` A. Sure. I'm reading from paragraphs 18
`through 21.
` Q. And are those your own words --
` A. Yeah.
` Q. -- or did someone else write that for
`you?
` A. No, no, these are my own words.
` Q. Okay.
` A. From reviewing the patent.
` Q. Let's go back to paragraph 18. Does
`the '917 patent say anything about evaluation of
`driver behavior?
` A. That's what you can do with what it
`captures and what it records. When it records
`vital sign behavior, that's what you can do with
`it. See, that's why when you asked if these are
`my own words --
` Q. Um-hum.
` A. -- these are my own words. Even though
`this may not be mentioned in here, even though
`some of these phrases may not be mentioned in
`there, when I read this patent, that's what I
`get out of it.
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 8
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 9
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
` Q. Okay. Evaluation of driver behavior is
`not mentioned in the '917 patent, correct?
` A. Let's take a look. Now that you asked
`that specific question, we're going to look over
`the patent and look and see if that's in there
`then, because I don't want to be wrong on the
`record.
` Q. Okay.
` A. (Reviewing document.)
` Well, one of things it says, if you
`look at Column 2, Line 51, "With these two
`aspects of the invention, the operator of the
`vehicle is encouraged to operate the vehicle
`efficiency [sic] while at the same time being
`mindful that overstressing the vehicle to make
`up for a period of inefficiency will be quoted
`and noted by the operator's supervisors."
` Q. And in your opinion that constitutes
`evaluating driver behavior?
` A. No. I'm just saying that you asked me
`the question where in there is it related to
`driver behavior. That's one of the things that
`I'm going through now is you asked that question
`to figure out where exactly in the patent there
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 9
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 10
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
`might have aspects where it might relate to
`driver behavior. That's one. There may be
`others. So do you want me to continue?
` Q. No. I don't think you're going to find
`it in there. Let's step back and turn to
`paragraph 42 of your declaration, "Level of
`ordinary skill and the relevant art."
` A. Oh, yeah.
` Q. Did anyone inform you how to go about
`determining the relevant art for a patent?
` A. I guess I don't understand your
`question.
` Q. Did anyone inform you what the legal,
`proper legal analysis was for determining the
`relevant art in the U.S. patent?
` A. I still really don't understand what
`you're saying. What do you mean by -- I guess
`that's too vague for me to give you a definition
`"did anybody tell me."
` No, nobody actually told me, but maybe
`there's more details to that general, broad
`question that you just asked that I can answer
`better to get an understanding of what you mean.
` Q. Do you understand the proper legal
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 10
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 11
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
`analysis for determining the relevant art for a
`U.S. patent?
` A. I believe that I do, but offhand, I
`can't remember what that is. I am also a patent
`attorney, by the way.
` Q. Okay. Well --
` A. Okay. So --
` Q. -- can you tell me what it is?
` A. Not offhand, no.
` Q. Okay. Even though you're a patent
`attorney?
` A. That's right. Please, inform me. What
`is it that you're getting at?
` Q. Well, I'm more interested in how you
`came to determine what the relevant art is. Can
`you tell me how you determined it?
` A. That's too general of a question. What
`I did was is I looked at what Toyota presented
`in terms of the patents that they presented, and
`I did a specific analysis of those patents as
`compared to the Hagenbuch patent.
` So why don't you go ahead and let me
`understand exactly what it is you're getting at
`by that question.
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 11
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 12
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
` Q. Well, you have a whole section of your
`declaration with the heading "Level of Ordinary
`Skill in the Relevant Art," right?
` A. I have a whole heading where I'm
`addressing what a person of ordinary skill would
`be in the relevant art. Now we're getting to
`more details of what it is that you were getting
`at. When you just said "relevant art," it was
`one thing; now you're talking about a person of
`ordinary skill in the relevant art; is that what
`we're talking about?
` Q. I'm asking you how you determined the
`relevant art if you don't understand the legal
`analysis for making that determination in the
`U.S. patents.
` A. What I did was, for this specific
`patent, I looked at the references that were
`produced by Toyota, and I analyzed those
`references against the Hagenbuch patent. And
`then I looked at them and I said, Okay, with
`what's going on here with what's going on with
`the Hagenbuch patent, with what I see being
`produced by Toyota for these three other pieces
`that are allegedly prior art to the Hagenbuch
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 12
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 13
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
`patent, I said, You know what, this is what a
`person of ordinary skill should be, this is what
`a person should possess when looking at the
`relevant art and one who is experienced of
`ordinary skill in the relevant art and making
`the evaluation of what I get from reading those
`four disclosures --
` Q. So you --
` A. -- that person should possess.
` Q. Just so I understand, you used those
`four disclosures to determine what the relevant
`art is?
` A. You know, what I did was exactly what I
`said. I looked at those four disclosures. I
`did an analysis of those four disclosures
`compared to three produced by Toyota and
`produced under Hagenbuch.
` And then I said, You know what, when
`you talk about what's in these four disclosures,
`what kind of skill set should someone of
`ordinary skill in the art possess. And that's
`what I wrote here in paragraph 42. I hope that
`answers your question.
` Q. Well, it doesn't really, but I don't
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 13
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 14
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
`think you understand what the relevant art is
`and maybe that's why.
` A. And that's your opinion.
` Q. And when you talk about the -- you
`mentioned the documents produced by Toyota. Are
`you talking about the Oishi, Vollmer and
`Aoyanagi references?
` A. Yes.
` Q. I'm going to hand you a copy of those
`references now just to get that out of the way.
`Here's a copy of Aoyanagi. It's Exhibit 1003,
`and I'm going to hand you a copy of Oishi.
`That's Exhibit 1005. And I'm going to hand you
`a copy of Vollmer. That's Exhibit 1007.
` Did I hand a copy of Vollmer? One of
`them may have stuck to the back. Zzz
` A. Here's something.
` MR. HILL: Is that 1007?
` THE WITNESS: Got them.
` MR. HILL: Okay.
`BY MR. MATTSON:
` Q. I just want to get some terminology
`straight here, because you mentioned one of
`ordinary skill in the art?
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 14
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 15
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
` A. Um-hum.
` Q. Okay. If we talk about a -- is it fair
`to also call that person a skilled artisan or a
`person having ordinary skill in the art?
` A. I'm okay with that.
` Q. Okay. And do you understand that when
`we use that language, we're referring to the
`person of ordinary skill in the art at the
`earliest effective filing date of the '917
`patent?
` A. Yes, sir.
` Q. Okay. And that is February 15, 1994,
`right?
` A. Yes, sir.
` Q. Okay. And is it okay if we refer to
`that date as either the effective filing date of
`the '917 patent or the time of the invention?
` A. I'm happy with filing date.
` Q. Okay. I think your declaration
`actually uses at the time of the invention also,
`so would that be okay if we use that
`terminology?
` A. Yeah, unless I can find something where
`he had conception before that date, I'm okay
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 15
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 16
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
`with that date.
` Q. Are you aware of any evidence that --
` A. Not right now, but that doesn't mean
`something might not be produced.
` Q. Let me finish my question.
` Are you aware of any evidence that
`shows that the inventor conceived of the
`invention prior to the effective filing date?
` A. Not right now.
` Q. Okay. And if I use the acronym ACN, do
`you understand that to mean automatic collision
`notification?
` A. All right.
` Q. EDR, event data recorder?
` A. Okay.
` Q. Do you believe that your work
`experience and education gives you an
`understanding of the level of ordinary skill in
`the art at the time of the '917 patent's filing
`date?
` A. Yes.
` Q. Okay. Let's talk about your experience
`a little bit. Can you turn to paragraph 14 of
`your declaration.
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 16
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 17
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
` A. (Witness so doing.)
` Q. Within that paragraph you use the
`phrase "collision parameter and crash pulse
`storage." "Collision parameter and crash pulse
`storage." I think it's in the fourth line of
`paragraph 14.
` Can you tell me what you meant by that
`phrase?
` A. "During the course of my career in
`automotive research development and testing, I
`have designed, tested and developed numerous
`vehicle electrical and sensing systems,
`conducted numerous crash and collision tests and
`have developed and designed collision parameter
`and crash pulse storage and critical parameter
`retrieval systems for vehicle collision safety
`systems, air bag systems, seat belt systems,
`sensing systems for use in automobiles."
` Q. All right. And I asked you what the
`phrase "collision parameter and crash pulse
`storage" means. I don't understand what it
`means. Can -- rather than read back the
`paragraph to me, can you tell me what it means?
` A. Sure. When you get into an accident,
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 17
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 18
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
`you record certain parameters. When you run a
`crash test, you're going to look at that crash
`test, and you're going to look at -- this is
`we're talking about testing and development work
`in the automotive industry, which is, by the
`way, in reference to your first question about
`somebody of ordinary skill in the arts should
`have possessed in order to do and analyze what's
`going on with these patents.
` I've done numerous crash and sled
`tests. I've looked at numerous types of sensing
`systems and the performance of those sensing
`systems and the performance of safety systems in
`general, and I've looked at the data related to
`those types of systems. That's what I'm talking
`about.
` Q. Is it fair to say that a collision
`parameter, then, is a parameter that you would
`store in the event of a crash?
` A. Not necessarily.
` Q. What's a collision parameter?
` A. A collision parameter could be
`anything. A collision parameter could be
`somebody looking at a crash test and looking at
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 18
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 19
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
`film analysis of dummy movement and dummy
`kinematics and figuring out how the dummies are
`moving in that crash test.
` You're not necessarily capturing that
`information in events data recorded. Collision
`parameter could be a whole slew of different
`types of data and different types of information
`that you're getting from running these types of
`tests.
` Q. Including data that's not discussed in
`the '917 patent?
` A. Yeah.
` Q. And can you tell me what a crash pulse
`is?
` A. Sure. And it depends on what you're
`looking at. Are you looking at it in the
`longitudinal direction, are you looking at in
`the lateral and the vertical direction. Depends
`on what type of crash that you're talking about.
` So what we're talking about here is
`that let's say you're talking about just a
`forward frontal impact with no offset.
`Generally what you're looking at there is the --
`the pulse that you're going to see in Gs, okay,
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 19
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 20
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
`during the event. Now the thing is is that when
`you're doing that, though, don't forget, you're
`only getting it in one direction. So when you
`look at a crash pulse, you have to define
`exactly what it is that you mean that you're
`talking about.
` Q. Why is that?
` A. Because there's all kinds of forces
`acting on this vehicle when you get into a
`crash. These forces aren't necessarily all
`coming from just one direction.
` Q. Why do you care about the other
`directions? Why would you care about more than
`one direction?
` A. To look at the effects of what's
`happening.
` Q. Is that necessary to understand the
`effects of what's happening?
` A. It depends on how well you want to
`understand it.
` Q. Suppose you want to understand it well
`enough to reconstruct an accident?
` A. Then it depends on what type of
`accident it is.
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 20
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 21
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
` Q. What types of accidents would require
`understanding the forces in multiple directions
`in order to reconstruct the accident?
` A. Rollovers -- I mean, that's a very
`general sweeping statement. Rollovers. For
`example, accidents where you have rotation
`involved. Accidents where you have offset types
`of collisions involved. Angular impacts.
`Accidents where they're not just, let's say, at
`a 90-degree front end into a barrier type of an
`event. Accidents where you have steering inputs
`involved. Accidents where you have, you know,
`any type of anything that's just specifically
`not in the longitudinal direction of force.
` Q. Did you have any experience working
`with crash pulse storage systems prior to the
`filing date of the '917 patent?
` A. Yes.
` Q. And is what you just explained to me
`how one of ordinary skill in the art would have
`understood a crash pulse at the time of the
`invention?
` A. What specifically in what I just
`explained to you are you referring to? You got
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 21
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 22
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
`to be more specific. General sweeping comments,
`I can't answer those. So go ahead and give me
`some specific examples of what it is that you're
`talking about, and I'll be able be to answer
`your question.
` Q. Well, I understand that you need to
`sense forces in more than one direction to
`reconstruct certain types of accidents.
` A. What's your question?
` Q. My question is whether one of ordinary
`skill in the art would have understood that in
`order to reconstruct some accidents, you need to
`be able to sense the forces in more than one
`direction?
` A. Yes.
` Q. Did you ever work with a crash pulse
`storage system that was actually employed on a
`production vehicle?
` A. Is that your question? Are you done?
` Q. (Nodding.)
` A. Yes.
` Q. Prior to the filing date of the '917
`patent?
` A. Yes.
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 22
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 23
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
` Q. Which vehicles?
` A. I worked at General Motors. I worked
`on SDMs.
` Q. So your -- the crash pulse storage
`systems, or some of the crash pulse storage
`systems you worked with were actually employed
`on production vehicles prior to the filing date
`of the '917 patent?
` A. I wouldn't say "employed." They went
`into production after that date.
` Q. So prior to the filing date of the '917
`patent, none of the crash pulse storage systems
`that you had worked with had actually gone on to
`a production vehicle?
` A. I worked on the '96 ST truck. That's
`after the filing date of '917 patent. Hopefully
`that answers your question.
` Q. Well, I'm trying to figure out how you
`have a sense of what one of ordinary skill in
`the art would have known prior to the filing
`date of '917 patent.
` A. Did you read the CV?
` Q. Yeah. It's a lot of gobbledegook in
`there.
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 23
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 24
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
` A. Did you read the CV about all the
`experience in crash testing, crash-sensing,
`safety systems. You call that gobbledegook?
` Q. Crash pulse storage, though -- well,
`there's two different things; one is analyzing a
`collision, right? That's one field I think you
`have a lot of experience in, right, analyzing
`collisions; is that right?
` A. I was the black box expert for Ford
`Motor Company from 1999 to 2007.
` Q. 1999?
` A. To 2007.
` Q. Okay.
` A. The reason why I was there was because
`I've been working on these types of systems
`since 1987. Hopefully that answers your
`question.
` Do you have anything else you want to
`add to that?
` Q. Did you -- so you've not worked -- just
`to be clear, you've not worked on any collision
`safety system that went into production before
`the filing date of the patent?
` A. I didn't say that.
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 24
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
` Q. Have you?
` A. Yeah.
` Q. Which vehicles?
` A. Well, when I was at Ford in 1987, I
`worked on the Mustang, the Mark, the Taurus, the
`FN9, the Continental. I've worked on F-series
`truck. That's all in the gobbledegook in the
`CV.
` I worked at General Motors. I worked
`on the system for passenger deactivation for
`deactivation of the passenger air bag, for rear
`infant seat detection, for child seats; also how
`that related to sensing diagnostic modules. I
`worked specifically on the Jimmy and the ST
`truck platforms and the Chevy S-10.
` Then I went back to Ford in -- when was
`that -- 1995. I worked on side impact systems,
`rollover systems, inflatable curtain systems.
` Then in 1999, I became part of Ford
`design analysis group, which basically -- and my
`responsibilities there were working on crash
`data recorders, any information contained
`therein and the analysis of field events and
`accident reconstruction related to those field
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 25
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 26
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
`events. That's just a general overview. Do you
`want more?
` Q. Did any of the crash pulse storage
`systems that you worked with go into production
`before the filing date of the patent?
` A. When you say "crash pulse storage,"
`what are you talking about?
` Q. I'm talking about the phrase "crash
`pulse storage" in your declaration at
`paragraph 14.
` A. Okay. What specifically are you
`talking about for crash pulse storage? Are you
`talking about recording the crash pulse that you
`see in a collision?
` Q. Well, let me ask you what you're
`talking about.
` A. In the field event? Is that what
`you're talking about?
` Q. Well, is that what you're talking about
`in paragraph 14?
` A. No. I told you what I was talking
`about in paragraph 14 before in the answer to
`your previous question when we talked before
`paragraph 14, remember? So what are you talking
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 26
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 27
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
`about? Are you talking about specifically
`related to an automobile that you look at in the
`field in terms of getting accident
`reconstruction from it, or are you talking about
`specifically crash pulses in relation to crash
`testing that's done in the development of the
`safety systems? Please, clarify exactly what it
`is that you mean.
` Q. Automobiles in the field.
` A. Automobiles in the field. Okay. What
`is your question now?
` Q. Have you worked on any crash pulse
`storage systems that were used in automobiles in
`the field prior to the filing date of the
`invention -- or prior to the filing date of the
`patent?
` A. I worked on automobiles that had crash
`pulse storage systems in them, but the one that
`I worked on that had a crash pulse storage type
`of a way to store the crash pulse was what I
`told you about. It went into production in the
`'96 ST truck platform. In fact, that didn't
`even make it into production, because after I
`left General Motors, they made bumper changes
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 27
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 28
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
`and went back to the old system that didn't do
`any type of storage. That was 1996 model year.
` So hopefully now that answers your
`question more specifically. When you ask the
`questions, please be more specific. I'm not
`trying to fight with you or argue with you; I'm
`just trying to understand exactly what it is
`that you're getting at. You can't make sweeping
`statements because there's a lot to this.
` Q. Have you ever designed a system for
`recording data in the event of a collision?
` A. Yeah.
` Q. Would one of ordinary skill in the art
`have known how to design such a system prior to
`the filing date of the '917 patent?
` A. There were different systems out there.
`That's too general sweeping of a statement.
` Q. Have you ever designed an EDR?
`Remember we agreed that EDR would stand for
`event data recorder?
` A. Okay.
` Q. Is that fair?
` A. Okay. Now what do you mean by event
`data recorder?
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 28
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 29
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
` Q. Do you know what an event data recorder
`is?
` A. I have all kinds of different meanings
`of what an event data recorder is. Explain to
`me what you mean by what an event data recorder
`is.
` Q. A device that records data in the event
`of a collision.
` Is that a fair definition?
` A. I think event data recorder can mean a
`lot more than that. You have parameters that
`you record in the event of a collision. You
`have parameters that you record if it's outside
`of certain values. You have parameters you
`record such as fault codes that you can record
`even irrespective of a collision. So what do
`you mean by event data recorder?
` See event data recorder can mean a lot
`more than just recording data if you get into a
`collision. In fact, even Hagenbuch, when he
`talks about fault codes, and when he talks about
`recording vital signs, he does -- it doesn't
`have to be a vital -- you know, a collision is
`just one example, right, that he talks about?
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 29
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 30
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
`You can have parameters recorded not even
`getting into a collision. Right?
` Q. What parameters would a person of
`ordinary skill in the art have deemed important
`enough to monitor and record at the time of the
`invention?
` A. Depends on what you could do.
` Q. Can you give examples?
` A. Whether there were any type of system
`diagnostic codes that might be outside of normal
`parameters. That would be one good example.
` Q. Well, if someone's designing a system
`for recording data in the event of a collision,
`say it's a person of ordinary skill in the art
`at the time of the invention --
` A. Okay.
` Q. -- what kinds of parameters would they
`deem important enough to record?
` A. Well, let me give you one specific
`example that I would deem important enough to
`record. Okay?
` Q. Would this also be true of one of
`ordinary skill in the art?
` A. Yeah, I think so.
`
`TSG Reporting - Worldwide 877-702-9580
`
`TOYOTA Ex. 1017, page 30
`Toyota v. Hagenbuch
`IPR2013-00483
`
`
`
`Page 31
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ** MICHAEL NRANIAN **
` Q. Okay.
` A. For example, you get into a collision.
`Your air bag doesn't deploy. You want to record
`the parameter of air bag squib resistance. You
`want to record the parameters of are the air bag
`sensors operating properly? What were the
`readings that we were getting from those prior
`to and up to the collision? That would be one
`thing that I would look at.
` Q. What are some of the other things?
` A. We're talking about in 1994, right?
` Q. At the time of the inv
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
