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` UNITED STATES PATENT AND TRADEMARK OFFICE
` _____________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ______________________________
` BROSE NORTH AMERICA, INC.
` and
` BROSE FAHRZEUGTEILE GMBH & CO. KG, HALLSTADT
` Petitioner
` vs.
` UUSI, LLC
` Patent Owner
` ____________________________
` Case IPR2014-00416
` Patent 8,217,612
` Case IPR2014-004417
` Patent 7,579,802
`
` The deposition of C. ART MacCARLEY,
`called for examination pursuant to the Rules of
`United States Patent and Trademark office, taken
`before CHERYL L. SANDECKI, Certified Shorthand
`Reporter for the State of Illinois, at 300 North
`LaSalle Street, Chicago, Illinois, on
`September 26, 2014, at the hour of 10:30 o'clock
`a.m.
`REPORTED BY: CHERYL L. SANDECKI, CSR, RPR
`LICENSE NO.: 084-03710
`JOB NO.: 5556
`
`www.krusereporters.com
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`312.345.1500
`
`UUSI Exhibit 2004
`Page 1
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`
`
`MacCarley
`
`Page 2
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`APPEARANCES:
` KIRKLAND & ELLIS LLP, by
` MR. CRAIG D. LEAVELL
` MS. ALYSE WU
` 300 North LaSalle Street
` Chicago, Illinois 60654
` (312) 862-2105
` craig.leavell@kirkland.com
` alyse.wu@kirkland.com
` Representing the Petitioner;
` HARNESS, DICKEY & PIERCE, P.L.C., by
` MR. MONTE L. FALCOFF
` MR. MICHAEL R. NYE,
` 5445 Corporate Drive
` Suite 200
` Troy, Michigan 48098
` (248) 641-1600
` mfalcoff@hdp.com
` mnye@hdp.com
` (Telephonically) Representing the
` Patent Owner.
`
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`UUSI Exhibit 2004
`Page 2
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`MacCarley
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`Page 3
`
` INDEX
`WITNESS EXAMINATION
`
` C. ART MacCARLEY
` EXAMINATION BY MR. FALCOFF 4
` Examination BY MR. LEAVELL 177
` Examination BY MR. FALCOFF (FURTHER) 204
`
` EXHIBITS
`
`NUMBER MARKED FOR ID
`MacCarley Deposition Exhibit
`Exhibit 1 Declaration for '802 69
` Patent
`Exhibit 2 Declaration for '612 69
` Patent
`Exhibit 3 '802 Patent 69
`Exhibit 4 '612 Patent 69
`Exhibit 5 Kinzl '596 Patent 105
`Exhibit 6 Itoh '333 Patent 120
`Exhibit 7 Zuckerman '000 Patent 134
`Exhibit 8 Book Excerpt 185
`Exhibit 9 DeSilva Complete Book 207
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`UUSI Exhibit 2004
`Page 3
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`MacCarley
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`Page 4
` (Witness administered an oath.)
` C. ART MacCARLEY,
`having been first administered an oath, was
`examined and testified as follows:
` EXAMINATION
`BY MR. FALCOFF:
` Q. Dr. MacCarley, did I pronounce your
`name right?
` A. Yes, you did.
` Q. I'm Monte Falcoff. I'm an attorney for
`the patent owner UUSI, LLC. And for the record,
`if you can state your full name, date of birth
`and home address?
` A. Carl Arthur MacCarley. Do you need me
`to spell that?
` Q. Not for me, thank you.
` A. My home address is 1413 Eucalyptus
`Road, Nipomo, spelled N-I-P-O-M-O, California,
`93444. My date of birth is January 10th, 1954.
` Q. Okay. Thank you.
` Have you been deposed before?
` A. No.
` Q. Okay. Have you ever testified in court
`before?
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` A. No. Oh, let me take that back. Not on
`an expert witness case. I have testified just
`as a witness on a civil suit.
` Q. Okay. Were you a party to that?
` A. No.
` Q. Okay. Well, let me go over just some
`basic ground rules of depositions.
` My job is to ask questions and your job
`is to answer them.
` Brose's attorney may object to my
`questions, but answer them anyway unless they
`are attorney/client privileged.
` You must answer all questions
`truthfully under penalty of perjury. You must
`give answers with a yes, no or explanation.
`Uh-huhs and shrugs -- I can't see shrugs, and
`it's difficult for the court reporter to pick up
`the uh-huhs.
` I will do my best to make my questions
`clear. But if you don't understand them, either
`technically or just the way I word them, please
`let me know and I will try to rephrase them.
` If you answer the question, I will
`presume you understood it. Do you understand
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`
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`MacCarley
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`those instructions?
` A. Yes, I do.
` Q. Great. This deposition is for both of
`the U.S. Patent Office Inter Parte Review
`proceedings filed by Brose against UUSI. So
`that would be IPR2014-00416 and 417.
` Are you represented by an attorney
`today at this deposition?
` A. I am with Kirkland & Ellis attorneys.
`I do not have my own personal attorney here.
` Q. Okay. Are those attorneys actually
`representing you in an attorney/client
`relationship?
` MR. LEAVELL: Monte, this is Craig. I will
`answer that.
` We were not. We are not counsel to the
`witness. We are here on behalf of the
`petitioners who have retained the witness in his
`expert capacity for this case.
`BY MR. FALCOFF:
` Q. And do you agree with that,
`Dr. MacCarley?
` A. Yes.
` Q. Great. Thank you.
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`UUSI Exhibit 2004
`Page 6
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`MacCarley
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` Have you ever been an expert in a
`patent lawsuit before?
` A. Yes.
` Q. Okay. And which one or ones?
` A. It was -- I was a defense expert in
`support of a lawsuit against Harley-Davidson
`Motor Corporation -- Motor Company, excuse me,
`in a patent infringement possible invalidation
`suit. I believe it -- just a few years ago.
` Q. Who was the plaintiff in that lawsuit?
` A. I don't recall the exact name.
` Q. Would that possibly have been
`Combustion Controls?
` A. Yes, it was. They went by three other
`names, I believe.
` Q. I see. Okay.
` And did you submit an expert
`declaration or report in that lawsuit?
` A. I submitted a report. I did not submit
`an expert declaration.
` Q. I believe before you testified that you
`have not testified as an expert witness in a
`deposition or a trial before. So do I take it
`that you did not have your deposition taken in
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`UUSI Exhibit 2004
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`MacCarley
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`Page 8
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`that Harley-Davidson case?
` A. That's correct.
` Q. Okay. Did you act as an expert in any
`other patent lawsuit?
` A. No.
` Q. Okay. Have you ever testified in a
`patent office Inter Partes Review proceeding
`before?
` A. No.
` Q. Submit any declarations or expert
`reports in any such Inter Partes Review
`proceeding prior to this one?
` A. Not in an IPR.
` Q. Okay. I would have been amazed if you
`said you had, given the newness of the
`procedure.
` Have you ever been an inventor on a
`patent application before?
` A. Yes.
` Q. Pertaining to what technologies?
` A. Most recently an adaptive control -- an
`advanced adaptive control method used for
`automated sensor and detector validation. This
`was as a result of work I do for Cal Trans.
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`MacCarley
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`Page 9
` Previously an assistive device for the
`blind that provided graphical -- provides a
`spoken interface in addition to the graphical
`interface. This had to do with assisting
`teaching science and engineering.
` Q. Okay. Did that patent or patent
`application pertain to electric motor controls
`in an automotive vehicle?
` A. That first one, no.
` Q. Any other patents that you were an
`inventor on?
` A. None that have issued.
` Q. How about any that are pending?
` A. None that are pending.
` Q. Okay. Now, through this deposition, I
`may use certain acronyms or abbreviations. Let
`me know if you are not clear on what they are.
` Let me give you some examples. IPR I'm
`using for Inter Partes Review. '802 patent
`usually I'm referring to -- I will always be
`referring to U.S. Patent 7,579,802.
` The '612 patent for U.S. Patent Number
`8,217,612 patent. Itoh, I-T-O-H, for the '333
`patent for U.S. Patent No. 4,807,333. Kinzl or
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`MacCarley
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`Page 10
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`'596 patent for U.S. Patent No. 4,468,596.
`Zuckerman or '000 patent for U.S. Patent
`No. 5,069,000.
` You don't need to write all those down.
`They should be at the top of the exhibits you
`may be looking at today.
` I may interchangeably refer to the
`patent owner as UUSI or its d/b/a Nartron, and
`refer to Brose as the petitioner or the
`collective companies -- I think there is a
`couple Brose entities that filed a petition with
`the present IPRs in which your expert
`declarations are in.
` Any of those confusing to you or do you
`understand?
` A. I understand.
` Q. Okay.
` MR. LEAVELL: Monte, sorry to interrupt.
`This is Craig. The court reporter has copies of
`the documents that you asked us to have
`available for you. She has not yet marked them.
`We didn't know what order you wanted to
`introduce them.
` So if you want to use them with the
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`MacCarley
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`Page 11
`witness, just let us know and we can mark them
`or we can mark them in whatever order or do it
`now. But she has the copies right now.
` MR. FALCOFF: Okay. From an administrative
`marking standpoint, I believe every exhibit we
`are using is already introduced as an exhibit
`attached to the expert report are your
`petitions.
` Unless you want me to, Craig, or unless
`the witness actually marks on them, most cases,
`if not all, I'm not sure we even need to truly
`enter them as a deposition exhibit unless you
`want to.
` MR. LEAVELL: You know, I don't -- it looks
`like the versions we have got here with the
`court reporter don't have the exhibit stamp on
`them, so why don't we have her mark them and put
`them in just for housekeeping matters.
` MR. FALCOFF: Fair enough.
` MR. LEAVELL: The other thing I will mention
`is I don't know if you guys noticed this. I
`just noticed this yesterday. Some of the copies
`of the patents that were filed apparently are
`missing some of the lines. So we are thinking
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`MacCarley
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`Page 12
`on Monday of -- we will call and deal with this
`separately. Sorry to waste your time now.
` You know how on Google Patents,
`sometimes you print them out and the lines don't
`show on the figures, that's apparently what
`happened here.
` MR. FALCOFF: Yeah, we have seen that.
` MR. LEAVELL: So we have got the right copies
`that have all the lines on them and that's what
`we printed out and gave to the court reporter
`for the '802, '612, Itoh and Kinzl.
` So it may be easier for everybody if we
`mark them as dep exhibits today, then they will
`be in the record either way. But we will sort
`that out and work with you to get that
`straightened out.
` MR. FALCOFF: Thank you. I appreciate you
`letting us know.
`BY MR. FALCOFF:
` Q. Okay. If we are ready, we will
`continue on.
` Dr. MacCarley, how much time did you
`spend preparing for this deposition today,
`approximately?
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`MacCarley
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`Page 13
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` A. About 40 hours.
` Q. Okay. And what did you do in that
`preparation?
` A. There was review of all of the relevant
`documents that I did prior to coming to Chicago.
`And then I have been meeting with the Kirkland &
`Ellis attorneys for two days --
` Q. Okay.
` A. -- to help prepare me for the actual
`deposition.
` Q. The documents reviewed, were all of
`those attached to your expert report or part of
`your expert report or were there any additions
`to that?
` A. I believe the only additions was in the
`course of our work in the past few days, we put
`together an index so that I can find things
`faster.
` Q. I can certainly understand the need for
`that. Did you actually review any parts in
`preparation for today's deposition?
` A. Could you explain what you mean by
`parts?
` Q. Physical parties.
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`MacCarley
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` A. Oh, physical, no, I did not.
` Q. Okay. In preparation for your
`deposition today, did you talk to any employees
`of Brose? So by that I'm excluding the Kirkland
`& Ellis attorneys.
` A. No, I didn't.
` Q. Prior to your signing of the expert
`declarations for the '612 and '802 patents, did
`you converse with any Brose employees other than
`the Kirkland attorneys?
` A. No.
` Q. Okay. Who is your current employer?
` A. I don't have a personal attorney on
`retainer.
` Q. Let me reask the question.
` A. I apologize. I misheard. You said
`"employer".
` Q. Employer. Yes.
` A. California State University System.
`I'm a professor at Cal Poly, San Luis Obispo,
`which is primarily an engineering university.
` Q. Is that different than Cal Tech?
` A. Yes.
` Q. Okay. In your current position, what's
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`MacCarley
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`Page 15
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`your title there? Or if you have multiple
`titles, what are they?
` A. I am a professor of electrical and
`computer engineering. I am currently the
`department head of the BioResource and
`Agricultural Engineering Department. I'm
`director of the transportation research
`laboratory. I suppose there is some committee
`titles that aren't relevant.
` Q. Okay. Now, the laboratory you
`mentioned, what projects -- well, first off, how
`long has that been in existence that you have
`been a part of?
` A. Since early '90s.
` Q. Okay. Can you put a more definite year
`on that when you first started working with that
`group?
` A. Not at this time. I would go back
`through my records to pin it down.
` Q. All right. Have you been involved with
`it since it was created?
` A. Yes.
` Q. Okay. And what projects are currently
`being worked on in that laboratory?
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`MacCarley
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` A. Currently, as of me accepting the
`position of department head again, I have no
`currently funded projects through that
`laboratory. The question was current; is that
`correct?
` Q. Yes. This was correct.
` So when was the last time you did have
`a project with that laboratory or through that
`laboratory?
` A. I believe it terminated the end of the
`summer before this last one. It was for the
`California Department of Transportation
`involving advanced automated sensor and detector
`validation using an adaptive algorithm and
`specialized hardware.
` Q. Is that for traffic control management?
` A. It's for evaluation of technologies
`that are used for traffic control management.
` Q. I see. Okay. Anything to deal with --
`that deals directly with DC electric motors in
`cars?
` A. No.
` Q. Has that laboratory since you first
`started working with them in 1990s ever done any
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`projects there dealing with automotive vehicle
`DC electric motors?
` A. Yes.
` Q. Okay. What was that?
` A. In the late '90s, I did work funded by
`the California Energy Commission, Pacific Gas
`and Electric Company, some university support
`also in which we were developing some advanced
`technologies related to electric vehicles.
` Q. So those would be traction drive
`motors?
` A. We weren't -- that project wasn't
`directly in motor development. I also -- I also
`did have my own company for about ten years in
`which we did do specific drive -- high-powered
`drive electronics for advanced electric vehicle
`motors.
` But back to your original question,
`that project was associated with automated
`battery exchange for electric vehicles, which
`involves an automated mechanism with both
`motors.
` Q. I understand. And did you -- are there
`any other projects through the laboratory there
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`at the university where you worked on automotive
`vehicle DC electric motors?
` A. Well, I teach a course in which
`electric vehicles is one of the major topics.
`So I do go fairly -- I go to a level of
`application depth associated with the various
`types of motors that can be used for traction.
` Q. Okay. That's separate from the
`laboratory work, right?
` A. Yes. I mean, I'm a professor. I
`primarily teach.
` Q. Okay. So, again, going back to the
`question for the laboratory, have you ever
`worked on any projects there where the work
`pertained to automotive vehicle DC electric
`motors through the laboratory?
` A. I can't recall any of the work.
` Q. Okay. Now, through your private
`company that you mentioned, what was the time
`frame that you started that up?
` A. 1997.
` Q. Okay. And what -- does it still exist?
` A. It exists as a name. But it's just --
`it's just me now. I closed my bricks and mortar
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`MacCarley
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`Page 19
`location when I most recently -- it was in 2008
`when I was appointed the department chair of the
`electrical engineering department.
` Q. Okay. So with your private company,
`did you ever do any work on DC electric motors
`in automotive vehicles?
` A. Yes. We, in fact, developed an
`under -- with some funding from the U.S.
`Department of Energy and an external entity that
`had developed a novel rotating machine, they
`came to us to produce for them the required
`specialized high-powered drive electronics that
`would drive their machine.
` Q. What kind of machine?
` A. It's a -- it was a configuration of
`a -- it's in the class of electronically
`commutated DC motors. But it had a very novel
`magnetic flux path that allowed the rotor
`magnetic field to be developed by a toroidal
`selenoid to the end case, avoiding the need for
`brushes, but effectively coupling in the fixed
`magnetic field to the rotor.
` Q. This is used in automotive vehicles?
` A. It never actually went into -- that
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`particular company that came to us to do this
`for them never got it into production.
` I might parenthetically add, though,
`that their concept did find its way into
`multiple other products, especially automotive
`alternators.
` Q. Okay. So was this project that you
`were working on with your company for the
`automotive use, was that primarily for or
`intended for use in alternators?
` A. No.
` Q. What were the other uses of this very
`specialized motor?
` A. The specific objective was to -- was to
`deploy the rotating machine and drive
`electronics as a very high-powered density
`electric motor for electric vehicles.
` Q. For the actual traction motor in
`electric vehicles?
` A. That's correct.
` Q. Now, the work that you have done -- I
`think you have done other, what, traction motor
`work for automotive vehicles; is that correct?
` A. It's not my specialization. So I can
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`say I have had a hand in quite a few
`student-based projects. I have worked with
`colleagues who have worked on this type of
`thing. But I wouldn't go so far as to say
`I've -- I could take primary responsibility for
`something like that.
` Q. Okay. Would you consider yourself to
`be an expert in the field of automotive DC
`electric motors?
` A. I'm going to subdivide your question
`because there are two broad classes of DC
`electric motors. I mean, the type relevant in
`this case is a permanent magnet motor, which
`is -- it's -- they are ubiquitous in window
`drive mechanisms.
` It's such a well-established technology
`that it hardly takes much expertise to say you
`know everything about them. I certainly meet
`that qualification.
` As far as the whole broad range of
`advanced DC electric drives, novel motor
`configurations, I would not consider myself an
`expert. That's a fairly specialized field.
` Q. Let's break it down then. The
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`permanent -- let me rephrase the question.
` For the type of electric motor that's
`used in automotive vehicle window lift
`mechanisms in the 1990s, specifically the early
`1990s, would you consider yourself currently an
`expert in that area?
` A. Yes.
` Q. Okay. Would you consider yourself an
`expert in that area in the early 1990s?
` A. Yes.
` Q. Now, in the early 1990s, would you have
`considered yourself to be a person of ordinary
`skill in the art in the type of electric motor
`that's used in automotive window lift
`mechanisms?
` A. Yes. You said window lift mechanisms;
`is that correct?
` Q. Yes.
` So in the early 1990s, what were your
`educational qualifications?
` A. I had a Ph.D. in electrical engineering
`with a specialization in applied digital
`control. I had by then six years' experience in
`industry and research. I had a master's degree
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`in electrical engineering and a bachelor's
`degree in engineering with a specialization in
`energy and kinetics.
` Q. Okay. So, I mean, you had a lot of
`education in electrical engineering back then,
`clearly.
` So are you taking the position that if
`you were a person of ordinary skill in the art
`in automotive window lift motors in the 1990s,
`then the person would have to have, basically, a
`Ph.D. in electrical engineering? Is that the
`position you are taking?
` A. No. I misspoke. I interpreted your
`question as at least ordinary skill in the art.
`I did not mean to imply that that is a
`qualification that a Ph.D. is necessary for
`ordinary skill in the art.
` Q. Let me reask the question. In the
`early 1990s, specifically April 1992 or earlier,
`would you consider yourself to have been a
`person of ordinary skill in the art at that
`time? And the art is window lift motors.
` A. I believe I had more than ordinary
`skill in the art.
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` Q. Okay. So the answer would be no; is
`that correct?
` A. I guess with that phrasing of the
`question, yes. Yes, it would be no.
` Q. Prior to April of 1992, did you ever
`work for an automotive company or a supplier to
`an automotive company?
` A. Yes.
` Q. Okay. Who would that have been?
` A. American Bosch Division of United
`Technologies.
` Q. What projects did you work on them for?
` A. Microprocessor controls, electronic
`diesel fuel injection.
` Q. Any other projects?
` A. No. That was -- that was my design
`group.
` Q. Were there electric motors involved
`with those injectors?
` A. With the system, yes.
` Q. What kind of motors were those?
` A. Mostly stepper motors. But that was
`actually a design decision that was often kicked
`around. Not making it into the product were, in
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`fact, regular permanent magnet DC motors.
` Q. Why was there a decision to go with
`stepper motors versus the other kind?
` A. Because stepper motors are, in essence,
`both a drive mechanism and a sensor. They
`provide positive indexing. That is a stepper
`motor can be commanded to a specific position.
`A DC motor can not. It's a torque-controlled
`motor.
` Q. So would a stepper motor be very
`similar in function or structure to a servo
`motor?
` A. Often stepper motors are used as servo
`motors. But -- let me leave it at that.
` There are other things that are used as
`servo motors also.
` Q. Okay. So with stepper motors, are they
`more accurate than the kind of motor used for a
`window lift mechanism in the early 1990s?
` A. Could you define accuracy in this
`context?
` Q. Accuracy in any way?
` A. In positioning, in precise positioning,
`they are vastly more accurate because they move
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`a specific radial increment for every one of
`generally four phases applied to them.
` A DC motor can only approximately be
`directly commanded to a particular position,
`unless you have a separate rotary position
`sensor that is used in a servo control loop with
`that motor.
` I think in the -- that's the extent of
`which I could -- well, I just thought of
`something.
` Driven at a particular step rate, a
`stepper motor can be made to turn very exactly a
`particular rate of speed; whereas a DC motor
`is -- could be driven only to an approximate
`rate of speed, again, because it's a
`torque-controlled device.
` Q. I assume at least at that time in the
`early 1990s the stepper motors would have been,
`I don't know, more expensive than the permanent
`magnet window lift-type motors; is that correct?
` A. It depends on the application. A
`stepper motor has -- is used where generally one
`does need to positively locate a position and
`one does not want to use an external sensor in
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`addition to a DC motor in a feedback loop.
` So we would find it in things like
`printers, some type of automation mechanisms.
`It would often be not any more expensive to
`answer your question than a DC motor. It would
`just be more appropriate.
` A DC motor is a -- generally a higher
`torque device, a higher power device. So if you
`have an application in which you need to
`generate greater torque, you would not use a
`stepper motor, you would use a DC motor and go
`to the extra length for positive positioning if
`that is needed in the application.
` Q. Okay. Now, how did you determine the
`positional accuracy of a stepper motor versus a
`window lift-type permanent magnet motor?
` A. I didn't. I have never run that
`experiment. This is just well known. In any
`product information, in any textbook on motors,
`you would find this.
` Q. Okay. So what's the structure of the
`stepper motor that allows for sensing the
`position?
` A. It doesn't sense the position. It can
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`be driven to a specific position by feeding it a
`specific number of commutation steps.
` Generally, these are pulses applied to
`it. It generally has what are called quadrature
`windings so that it can be very precisely
`positioned rotationally with a specific number
`of commutation pulses sent to it.
` So that if you send it a chain of, you
`know, 100 commutation pulses, it would take it
`to step position 100 and there it would stop.
` Q. Is there a way to know if it actually
`got to that position in a typical stepper motor
`application?
` A. It is generally relied upon that it
`would achieve that position. It's the basis of
`almost all inkjet or former, you know, line feed
`printers, impact-type printers.
` But, no, you couldn't say for absolute
`certainty that it didn't skip a step. That is
`always the concern.
` In a -- if it is an extremely high
`reliability situation where that simply couldn't
`be tolerated, it might not be the best choice.
` Q. Okay. So there was no sensing of
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`position of the motor going on in your uses for
`the stepper motor?
` A. No. And that's generally the advantage
`of using a stepper motor: That you don't need a
`position sensor.
` Q. Now, are those differences and non-need
`for sensing also true of servo motors?
` A. Could you rephrase the question?
` Q. Yeah, I would be happy to.
` So are -- for a servo motor used in an
`automotive vehicle in the early 1990s, would you
`have the similar positional accuracy to that of
`the stepper motors that you were just talking
`about?
` A. Did you mean to say permanent magnet
`motor, not servo?
` Q. No, I did not mean to say that. So I'm
`comparing servo motors to stepper motors in
`automotive use in the early 1990s.
` A. What's confusing me is sometimes a
`servo motor is a stepper motor, as I explained
`before.
` Q. Right. So to the extent -- let me
`rephrase the question.
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` Are you aware of any automotive uses of
`servo motors in the 1990s or before that were
`not stepper motors?
` A. Yes. Yes, of course.
` Q. What were those used in?
` A. Well, among other things -- I'm hedging
`only because servo in the controls world in
`which I live is kind of a well-constrained term.
`I think you are using it in a broader sense, but
`I'm not sure how broad.
` So the first example I would give you
`is it was common practice to use permanent
`magnet DC motors in windows regulators, power
`window regulators.
` They are used for air circulation
`blowers in HVAC units in cars. They are used
`for idle control throttle position actuators.
`They would be used for power antenna raise and
`lower devices. They are used in windshield
`wipers.
` They are just ubiquitous as low cost
`accessory drives that are a reasonable trade-off
`of cost and robustness.
` Q. So all of those uses you listed, you
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`consider those to be servo motors?
` A. I'm referring to permanent magnet DC
`motors which are in the class of servo motors.
` Q. Okay. How do you define technically
`accurately a servo motor?
` A. It's a motor used in a servo mechanism.
` Q. Okay. Can you define servo mechanism?
` A. It derives from the word servant or the
`Latin prefix for it, which I have forgot.
` A motor used in such a mechanism is one
`that is controlled to achieve a particular
`position or speed using a feedback device in the
`case of torque-control motors that would
`specifically -- would provide generally negative
`feedback, which is differenced with a control
`signal going into the input, so that it achieves
`that target speed or position.
` If a stepper motor is applied in a
`servo mechanism, you can -- there is that
`advantage, as I mentio