TOYOTA MOTOR CORP. V.
`LEROY G. HAGENBUCH
`
`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.
`
`I-IAGENBIJCH
`Patent Owner
`
`/
`
`Case IPR203-13-0|)-133
`
`Patent 8 , 014 . 9 1'.'r'
`
`The deposition of DAVID MCNAHARA was taken
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`the 17th day of April, 2014, commencing 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 &. Neustadt. LLP. 1940 Duke Street.
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`15 Alexandria. Virginia. before Brian M. McDonald. Notary
`1'? Public.
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`REPORTED BY: Brian M. McDonald
`
`DAVID :VlcNAMARA
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`April 17. 2014
`Page 3
`
`INDEX
`
`April 1'? , 2014
`Deposition of DAVID 1-1cNAMARA
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`5 Examination By:
`'3’ 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 :
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`3
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`FOR THE PETITIONER TOYOTA MOTOR CORPORATION:
`
`ROBERT C. MATTSON. ESQUI RE
`
`THOMAS C ' YEBERNETSKL ESQUIRE
`°”1°“ SP“”"‘
`1940 Duke street
`Alexandria. Virginia 22314
`Telephone :
`(703) 413‘3mm
`Facaimfle ‘ V703) 4134200
`Email :
`rma.t.t.aon@ob1on.c:om
`
`FOR THE PATENT OWNER LEROY G - HRGENBUCH =
`JONATHAN HILL. ESQUIRE
`Freeborn & Peters, LLP
`311 South ‘Wacker Drive
`Suite 3000
`Chicago, Illinois 50606
`Telephone:
`(312)
`3 so - soon
`Facsimile:
`(312) 350-5520
`
`Email :
`
`jhi11@freehorn . com
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`1
`2 whereupon,
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`‘
`_
`PROCEEDINCJS.
`.
`DAVID MCNAMARA.
`.
`.
`-
`.
`at witness herein. |1a\-"lug been tlrst duly sworn. was
`exainined and teslilied upon his oath as follows:
`EXAMINATION BY MR. HILL:
`Q. Good morning. Mr. McNaIneIreI.
`A_ Good morning
`l will be
`Q. My name is lorlallleln Hill.
`taking your deposition today. Have you been deposed
`before-Ir
`A. Yes I have.
`
`Q. You know the basics: l'llbeeIskin;_1 you 21
`series of questions; and you will provide answers to
`the best oliyour ability.
`lliyou need to lake :1
`break at any ti1ne_ pleasejust let me l(|‘l0W1ll‘ll.‘§
`isn't at lesl ofriltysical erldurelnee.
`[‘(| also ask
`that your answers be zludihlejust for the sake of
`the court reporter to create at record.
`I would like
`to show you what's been produced as Toyota Exhibit
`1008.
`
`A- Thank F0"-
`Q. And do you recognize this docu1nenl'.’
`A. Yes, I do.
`
`Q. Okay. This is a declaration that has your
`
`Barklev Court Reporters
`
`(11) Pages I - 4
`OWNER Ex. 2054, p.
`
`

`
`TOYOTA MOTOR CORP. V.
`LEROY G. HAGENBUCH
`
`Page 5
`
`DAVID McNAMARA
`
`April 17, 2014
`Page ?
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`signature"!
`A. Yes.
`
`Q. Okay. And this declaration has been
`submitted in connection with |PR2013—00483; is that
`correct?
`
`I believe so, yes.
`A.
`Q. T|1is relates to certain claims of'U.S.
`Patent No. 80|49l 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 cotnpensaled.’
`A.
`lam being compensated by check monthly --
`or when I 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 I believe you said your cotrtpertsation
`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 Oishi and Aoyanagi in
`light of Vollmer.
`Q. And these three t'eferenccs. Aoyanagi.
`Oishi and Vollnier are the bases for your conclusions
`on obviottsncss'?‘
`A. Yes.
`
`Q. How did Aoyanagi come to your attention?
`A. Through looking at prior art.
`Q. How did Oishi come to your attention?
`A. Same process. of looking at the prior art.
`Q. Same answer for Vo|hner'?‘
`A. Vollmer looking at the prior art, yes.
`Q. How did you go about your search through
`the prior art‘?
`A.
`I looked at what was available through
`discussions with attorneys and the Oblon attorneys
`and my own understanding of prior art out there.
`Q. Did you conduct any searches on the PTO
`web site‘?
`A. No.
`Q. Did you consider any other references as
`possible grounds for concluding that certain claims.
`ofthc 9| 7 patent were obvious‘?
`A. Can you repeat the question.
`
`Page 5
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`Q. Sure. did you consider any other
`re fcrcnces‘?
`
`A. Oh. references. yes.
`0. Okay.
`A.
`I considered the references that are
`
`listed in my report and they're listed, materials
`considered. paragraph [3, I list Aoyanagi and I list
`Oishi, Hamilton.
`I iist Trevor Jones, Fully
`I
`Integrated Trtlck 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 ofdocuments you
`looked at for purposes of preparing your
`declaration‘?
`A. My recollection today. yes.
`Q. You didn't consider any other patents as
`possible grounds of'inva|idity'?
`A.
`Invalidity‘?
`Q. Correct. obviousness.
`A. Okay. thank you. The scope of this report
`was those materials.
`
`Q. Okay. So you considered references listed
`here in paragraph I3 of your declaration?
`
`Page 8
`
`A. Yes.
`Q. And your declaration states that you've
`devoted your entire career to the field of
`atttomotivc 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
`
`probably broaden it to transportation.
`transportation systems in general.
`Q. Okay.
`A. Trucks. fleets, trains, very broad
`transportation, a lot of the information is shared
`amongst ail those different professions and areas.
`Q. Okay. Now, is it fair to say that the
`term automotive electronics refers to any electrical
`component ofa road vehicle‘?
`A. Automotive electronics to any component
`of...
`Q. Electrical con1ponent‘.’
`A.
`...electrical component. We tend to use
`broadly electri -- sorry to parse the words — but
`we tend to think in terms of electrical.
`electronics. sensors. microcomputers.
`communications. so when we use the term electronics.
`And then as I mentioned. I would be viewing the
`
`Barkley Court Reporters
`
`OWNER Ex‘ 2054,
`
`Pages 5 - 8
`
`

`
`TOYOTA MOTOR CORP. v.
`LEROY G. HAGENBUCH
`
`Page 9
`
`DAVID iVlcNAMARA
`
`April 17, 2014
`Page 11
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`application of sensors, computers and the
`communications to a broad array of transportation
`issues of which atltolnotive cars is a subset.
`Q.
`I see. Now, would the field ofautomotive
`electronics include engine control units‘?
`A. Yes.
`Q. Okay. And engine control units._ as I
`understand. perform a number of functions. one of
`which would be to control air fuel ratio: is that
`correct‘?
`
`A. Amongst others. yes. Air fuel ratio and
`other functions associated with controlling the
`engine, yes.
`Q. And would control of'ignition timing be
`one ofthose other functions‘?
`A. Yes.
`Q. What's the goal ofignition timing’? Is it
`fair to say that the goal otiigrtition timing is to
`optimize powerand fuel economy?
`A. There are actually three dimensions for
`engine controls and many variables ofcontrol which
`ignition is one, but in my career we would look at
`it from the viewpoint of performance; we would look
`at the idea of fuel economy and emissions. Those
`were the three big goals of an engine control system
`
`to optimize those three big goals, I would call it.
`Q. Okay. And another function of engine
`control unit would be the control idle speed: is
`that correct?
`A. Yes. idle speed along with ignition and
`other parameters. yes.
`Q. Would timing control be ainong those
`considerations‘?
`A. Yes.
`Q. Okay. cooling system control.
`A. Cooling system control.
`Q. Engine cooling system‘?
`A. Engine cooling. thank you. Trying to give
`the most accurate answer I can here. We tended to
`measure the engine coolant. the engine coolant would
`be input to an engine control system, especially as
`we can imagine, Washington on a cold day. you know,
`so it's, I tend to view it as one ofthe sensor
`inputs, yes.
`Q. Okay. Now, would you say that the claims
`ol‘ the "9 I 7 patent are directed to the Iicld ol"
`engine eontt'ol unit design?
`A. No.
`Q. Okay. And the field ofautomotive
`electronics also would include trarismission
`
`Page 10
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`electronics. correct‘?
`A. Yes.
`Q. Okay. And the claim ol‘9l "F patents are
`not directed to the field ofengine ~— excuse me. to
`the lield ofttansinissioti 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! 't' Patent
`relate in any way to the field oftransmission
`electronics‘?
`
`A. Well, I think that my understanding. I'm
`l
`having a little problem with the word directed.
`would say the claims, you know, talk about engine
`RPM, they talk about sensors that are measuring
`what's happening with the engine and the
`transmission and they are in the area of diagnostics
`and diagnostics is a broad subject that covers a lot
`of the components on a vehicle.
`0. Okay. Well, that's fair enough. Anti I
`think we'll agree that the lield otiautornotive
`electronics would include event data recorders.
`right‘?
`A. What do you mean by event data recorders?
`The common, just being clear. What do you mean by
`event...
`
`Q. Devices that store data relating to
`vehicle parameters.
`A.
`[would view event data recorders. that's
`terminology...
`(Speakers overlapping)
`Q. Fair enough. we want a clear record of
`your understanding.
`A. Yes, that is, using your word directed is
`capturing chronological events around a crash, of
`which I would say is a sub-set ofdiagnostics
`systems as a whole.
`Q. Okay.
`A. Specialized case.
`Q. Okay. And would the field ofautomotive
`electronics also include chassis electronics such as
`anti-lock braking systems‘?
`A. Yes.
`Q. Would it include traction control systems?
`A. Yes.
`Q. Electronic brake distribution, variable
`brake pressure.’
`I guess I would
`A. Variable brake pressure.
`call it electronic brake boost. I'm just trying to
`relate it to what I understand. I'd probably call
`it something a little bit different.
`
`Page ‘I2
`
`Barkley Court Reporters
`
`OWNER Ex. 2054, ;§'l”3P”g°§ 9 ' '2
`
`

`
`TOYOTA MOTOR CORP. v.
`LEROY G. HAGENBUCH
`
`Page 13
`
`DAVID tVlcNAMARA
`
`April 17. 2014
`Page 15
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`Okay. And are the claims ofthe 9|?
`Patent related in any way to the field ofchassis
`electronics‘?
`A. Could you hand me the 917 Patent, please?
`Q. SuI'e.
`A. Yes.
`Q.
`I‘m handing you what has been labeled
`Toyota Exhibit I001.
`A.
`I 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
`see or remember load leveling, so I know they talk
`about a sensor, is my answer.
`Q_ Okay. And the licld olautolrtotive
`electronics would include safety electronics such as
`air bag deployment systenis. correct?
`A. Yes.
`Q. That would also include. for example.
`collision avoidance system.-5'.’
`
`A. Yes.
`Q. Do you see anything in the 9] T patent that
`relates to those types ol‘ safety electronics‘?
`MR. MATTSON: Objection to form.
`A. Relates to?
`Q. Yes.
`A.
`I would say that they mention. the only
`sensor I see mentioned — can you repeat the
`question.
`I forgot the sensors you were referring
`to.
`I referred to air bag deployment systems
`Q.
`and collision avoidance systems.
`A.
`[see a mention of an Accelerometer but
`the field of automotive electronic air bag systems
`are much more sophisticated. Just the air bag
`sensor is the control auger and the actuator and
`those elements are missing.
`Q. Okay. And the field ofautomotive
`electronics would also include what's termed
`infotainment systems. correct‘?
`A. Yes.
`Q. You have a fair amount ofexpericncc in
`that field. riglttl’
`A. Yes, that is largely my career, a large
`part of my career, later part of my career was
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`Page 14
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`infotainment, yes.
`Q. But the claims ofthc 9]? Patent, they're
`not directed in any way to the lieltl 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 tocltnologics.
`Are you with me‘?
`A. Where are you‘? Paragraph three?
`Q. Paragraph three. about halfway down the
`page. For exarrtplc. I have been involved in the
`development and integration ofvarious motor vehicle
`
`Page 16
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`technologies.
`A. Yes.
`Q. Can you tell me what you mean by
`integration‘? is that simply the building of
`electrical sub-systems‘?
`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 he combining but
`in a way in which you do not compromise other
`performance quality and costs, goals.
`Q.
`I see.
`.\’iR. HILL: Can we go offthe record for 21
`moment.
`
`(W|1e1'eupon. a recess
`was taken)
`(By Mr. Hill) Mr. Mt:NaIrtarat. could you
`Q.
`describe for me what embedded vehicle controllers
`are‘?
`A. The question is what they are or...
`Q. Yes. what they are.
`
`Barkley Court Reporters
`
`OWNER Ex. 2054,‘? lziages '3 ' '6
`
`

`
`TOYOTA MOTOR CORP. v.
`LEROY G. HAGENBUCH
`
`Page 1?
`
`DAVID McNAMARA
`
`April 17. 2014
`Page 19
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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
`distinguislting the ntcehanism from general purposes
`processors‘?
`A. Well. no I 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 tlte controllers you worked on
`all electrical or have you worked on the Inechaltical
`controllers‘?
`A. Okay. So I have worked on both, to answer
`the question. And botlt mechanical in the sense of
`
`usually you don't say controllers. you'll say
`mechanisms, we would say mechanical systems, a
`handle on a door operating the locks, and then they
`become electrical which is now controlled by a
`switch and wiring and then even can go to electronic
`being part of a module that is actually controlling
`the locks and now on a vehicle network. That
`progression from mechanical to integrated systent
`where it is communicating with other systems on the
`car.
`I-lave yotl done any non~|inear
`Q. Okay.
`control work‘?
`A. What do you mean by non-linear control?
`0. Well. for example. adaptive control is
`often thought oliels non~|inear.
`A. Okay. I see.
`Q. Bang-bang relays.
`I've worked
`A. Yeah. thank you, thank you.
`on adaptive systems and most of the things in your
`control have non-linear behaviors.
`Q. The world is basically non—|inear
`A. Yeah. it's a car. it‘s not a -- so in
`other words. they're non-linear in nature but I have
`worked on adaptive control systems in the area of
`engine controls.
`
`Page 18
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`Q. Okay. Do you recall what kind ol‘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, Inore 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.
`I provided input for making those kind of adaptive
`decisions.
`I worked on the sensors.
`Q. May I infer from some of your previous
`answers that these control systems you've worked on
`are lcctlback controllers as opposed to open loop
`control‘?
`A.
`I've probably worked on both kinds. yes.
`Q. Okay. And have you worked with b0ll'l
`analogue and digital control systems‘?
`A. Mostly digital because I 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.
`
`A. Yes.
`Q. Okay. Can you tell me a little bit about
`what exactly your role was working on pressure
`sensor controls‘?
`A.
`I guess technically my answer is not
`pressure sensor control. You know, I didn't work on
`controlling pressure.
`I worked on measuring
`pressure.
`I just...
`Q. Okay. measuring pressure?
`A. Measuring pressure.
`Q. And pressure from wh2It'.’
`A. Two important operating pressures in the
`car manifold pressure and barometric pressure.
`Q. Why are those important?’
`A. Basically to control the air-fuel ratio on
`the car you do what is called -- had terminology.
`You do a speed density calculation. And part of the
`speed density calculation to determine the amount of
`air coming into the throttle body or the car, you
`need to know How so you need to know the pressure
`of the manifold and you need to know the barometric
`pressure. And ofcourse you would be controlling
`fuel injectors so you will know the mast coming in
`and you can do this calculation in the computer as
`to figure out your air fuel ratio which is very-
`
`Page 20
`
`Barkley Court Reporters
`
`OWNER Ex. 2054,? gages '7 ' 2"
`
`

`
`TOYOTA MOTOR CORP. v.
`LEROY G. HAGENBUCH
`
`Page 21
`
`DAVID McNAMARA
`
`April 17, 2014
`Page 23
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`important for catalyst and tl1c 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 t|1c 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 system‘?
`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 you weren't involved, for
`example. in terms ofsclccting what kind of feedback
`
`are input to an engine control system. Then much
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`more into I guess the next would be air bag
`2
`Accelerometers, I was responsible for an air bag
`3
`diagnostic Inodule. So we were looking at the
`4
`behavior of the accelerometers, and I was more the
`5
`system engineer, you might say.
`6
`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
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`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
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`looking at a millimeter wave technology that allowed
`22
`us to do collision warning if we wanted to.
`23
`Q. About what time frame was that?
`24
`A.
`I started working on that system in '95.
`25
`Then about that time, in that time frame, as shown
`
`Page 22
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`Page 24
`
`gain you would have in the control system.’
`A. Feedback gain. No, other than, you know,
`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
`loops 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 ofscnsors you have worked
`on‘?
`In my whole career?
`A.
`Q. We can start. And ilithis calls for an
`obscenely long narrative. then we'll curtail the
`discussion.
`
`I'll let you cut it off. How about a
`A.
`chronological order.
`It will help me remember.
`please. So first pressure sensors of all kinds and
`technologies because we were trying to select the
`technology. Temperature sensors. crank shaft
`position sensors, pretty much all the sensors that
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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 iirst 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 mcjusl go through a low in
`particular; this may jog your I'ccolleetion.
`A. Okay, sure.
`Q. You did mention acceleration sensors. You
`worked on tl1o5c'.’
`
`A. Yes.
`Q. Okay. And you rnentioncd the tcmpcraturt:
`sensors, I believe.
`A. Yes.
`Q. More specifically. those temperature
`Sensors were located in what part of the veliie-1e‘.’
`
`Barkley Court Reporters
`
`OWNER Ex. 2054,‘? gages 2' ' 24
`
`

`
`TOYOTA MOTOR CORP. v.
`LEROY G. HAGENBUCH
`
`Page 25
`
`DAVID McNAMARA
`
`April 17, 2014
`Page 2?
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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
`temperatures —~ excuse me. strike that. Sensors for
`measuring the temperature of oil?
`A. Forgot that one.
`I 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. So I have a lot of
`experience in oil temperature.
`I mean. I have
`experience in the packaging of the sensor to go in
`a car.
`I guess that's where I was really focused.
`Q. Cam you just brie Ily tell me why it is
`important to measure engine oil temperature‘?
`
`Page 25
`
`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
`
`change or this temperature is important. So it can
`be one of the inputs to your diagnosis...
`Q. Okay.
`A.
`...ofa problem.
`Q. Okay.
`A.
`It can also. it's also an important fluid
`in the vehicle that needs to he changed. and we used
`it to determine the life of the vehicle. [fy0u're
`in an environment where you're running at a high RPM
`and even driver abuse, you can elevate the oil
`temperature significantly and find yourself needing
`to change the oil quicker than if you're doing
`expressway driving or moderate driving.
`Q. Higher temperatures tend to cause oil
`degradation‘?
`A. 0h,yes. Yeah. yeah. Actually, low
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`temperatures are a problem. If you're in Minnesota
`and you 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 I apologize ifyou've 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 sensois?
`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 seiisors‘!
`A. Yes.
`Q. And what type of‘ Seltsors were t|iose‘.’
`That's probably a bad question. How did you
`
`measur ~- 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 eoatingm a disk
`with a resistive coating with a wiper. And so we
`would measure the change of resistance as position
`of the throttte.
`
`Q. That was mounted on a pivot point?
`A.
`It was -- good question.
`It depends on
`the execution.
`I can remember them and throttle
`bodies being, you know, off to the side of the
`throttle. Usually we did not want to have a big
`linkage between the sensor and the, you know. and
`the throttle because it's a source of error. So you
`try to mount the sensor by the measure end, the
`thing you're measuring which is a problem in
`environment conditions ofengines.
`Q. Have you worked on any sensors that could
`be used in measuring the ground speed of a vehicle?
`A. The actual speed of the vehicle over the
`ground?
`Q. Yes. linear speed.
`A. Not the distance traveled‘?
`
`Page 28
`
`Barkley Court Reporters
`
`(7') Pages 25 - 28
`OWNER Ex. 2054, p. ?'
`
`

`
`TOYOTA MOTOR CORP. v.
`LEROY G. HAGENBUCH
`
`Page 29
`
`DAVID McNAMARA
`
`April 17, 2014
`Page 31
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`Right.
`A. Not what's happening at tlte wheels. yeah.
`Yes, mainly haul effect type technologies for
`Ineasuring wheel speed, altd thelt also. You know, more
`recently in my career GPS, Global Positioning
`Satellite Phsitioning systelns.
`Q. What is hall effect as that phrase is
`used‘?
`
`A. Hall effect?
`Q. 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 off
`switches. determining whether you're in park or. you
`know. car's moving, very important. Yeah.
`Q. Okay.
`A. And then also pressure sensors in general,
`yes.
`In the brake cylindcri’
`Q.
`A. No, mainl_v manifold pressure but the sante
`
`Page 30
`
`principle. Variable brake boost, I've worked on for
`adaptive cruise control, more of an actuator. But
`you have to measure the pressure of the actuation as
`feedback to the actuator. yes.
`Q. Okay.
`l thought you said you have done
`work on a sensor for nicasurittg brake on~ofl‘status.
`Did 1 hear you correctly‘?
`A. Yes.
`Q. How did that sensor function‘?
`A. Well. mainly there's a break sensor on the
`cars. and we would use the output to determine if
`the car was in park, and so you could turn on your
`navigation system. You use the output of that
`sensor.
`Q. The sensor...
`A.
`It gives an output to the navigation
`system so brake state is a vcr_v important part of
`infotainment, knowing when to turn the infotainment
`on and off. Certain infotainment systems need to be
`off when the car is moving. Rather. it can be on
`when you're in park.
`Q. So the sensor that you worked on indicates
`whether the car is in park Inode‘?
`A. Yeah. yeah.
`Q. Okay. Have you worked on any sensors that
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`would indicate that the brake pedzll is being pI'cssI:Ll
`or a brake light is on‘?
`A. Well. that's the sensor usually. the
`sensor that we're getting the output from. Oh,
`excuse me. Oh, you're talking, yeah, 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, but 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 remember.
`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 32
`
`A. But it's been a while since I've worked on
`those specific systems.
`Q. Fair enough. Have you done any work with
`sensors that would indicate whether or not a seat
`belt is fastened‘?
`A. Yes.
`in what context?
`Q. Okay.
`A. Mainly that would be part of restraint
`systems.
`I did not have assignments directly in
`restraint systems but I was involved in the planning
`of those systems. So [was part of the evaluation
`of systems. passive restraint that would use. you
`know, those sensors and -- yeah.
`Q. Okay. Why was it important at least in
`your experience to know the status ofa seat bclt'.’
`A. Well, in passive restraint systems, I'm
`thinking of the system that in the 80's would. you
`know. which was mandated, would tell you that your
`seat belt would come into position, so we were
`determining, that's when we first started working on
`seat belt switches for those of kind of systems.
`Later in my career we started. I was working with
`seat belts where — I don't know how to put this
`nicely -- we were annoying our customers at Ford
`that they needed to put their seat belt on. And [
`
`Barkley Court Reporters
`
`(8) Pages 29 - 32
`OWNER Ex. 2054, p. 8
`
`

`
`TOYOTA MOTOR CORP. v.
`LEROY G. HAGENBUCH
`
`Page 33
`
`DAVID iVleNAMARA
`
`April 17, 2014
`Page 35
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