In The Matter Of:
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`Ford Motor Company vs.
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`Paice, LLC, et al.
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`Neil Hannemann
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`April 8, 2015
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`Original File HANNEMANN_NEIL.txt
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`Min-U-Script® with Word Index
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`Page 1 of 100
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`FORD 1044
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`
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`Ford Motor Company vs.
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`Paice, LLC, et al.
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`Neil Hannemann
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`April 8, 2015
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`Original File HANNEMANN_NEIL.txt
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`Min-U-Script® with Word Index
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`Page 1 of 100
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`FORD 1044
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`Neil Hannemann - April 8, 2015
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`1
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` 1 UNITED STATES PATENT AND TRADEMARK OFFICE
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` 2 BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` 3
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` 4
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` 5 FORD MOTOR COMPANY, :
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` 6 Petitioner, :
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` 7 v. : IPR Case No:
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` 8 PAICE LLC & ABELL FOUNDATION, : IPR2014-00570
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` 9 INC., :
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`10 Patent Owner. :
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`11 :
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`12 - - - - - - - - - - - - - - - - -x
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`13
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`14
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`15 Oral Deposition of NEIL HANNEMANN
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`16 Washington, DC
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`17 Wednesday, April 8, 2015
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`18 12:55 p.m.
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`19
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`20
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`21
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`22
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`23 Job No.: 78384
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`24 Pages: 1 - 87
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`25 Reported By: Rebecca Stonestreet, RPR, CRR
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`Bienenstock Court Reporting & Video
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`Neil Hannemann - April 8, 2015
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`2
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` 1 Oral Deposition of NEIL HANNEMANN, held at the
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` 2 offices of:
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` 3
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` 4
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` 5 FISH & RICHARDSON, PC
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` 6 1425 K Street, NW
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` 7 11th Floor
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` 8 Washington, DC 20005
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` 9 (202) 783-5070
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`10
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`11
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`12
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`13
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`14 Pursuant to notice, before
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`15 Rebecca Stonestreet, Registered Professional Reporter,
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`16 Certified Realtime Reporter, and Notary Public in and for
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`17 the District of Columbia, who officiated in administering
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`18 the oath to the witness.
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`19
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`20
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`Neil Hannemann - April 8, 2015
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`3
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` 1 A P P E A R A N C E S
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` 2
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` 3
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` 4 ON BEHALF OF PETITIONER:
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` 5 FRANK A. ANGILERI, ESQUIRE
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` 6 JOHN P. RONDINI, ESQUIRE
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` 7 ANDREW B. TURNER, ESQUIRE
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` 8 BROOKS KUSHMAN, PC
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` 9 1000 Town Center
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`10 22nd Floor
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`11 Southfield, MI 48075
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`12 (248) 226-2913
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`13
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`14 ON BEHALF OF THE PATENT OWNER:
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`15 W. PETER GUARNIERI, ESQUIRE
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`16 LINDA LIU KORDZIEL, ESQUIRE
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`17 FISH & RICHARDSON
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`18 1425 K Street, NW
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`19 11th Floor
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`20 Washington, DC 20005
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`21 (202) 783-5070
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`22
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`23
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`24 ALSO PRESENT:
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`25 Frances Keenan, Paice LLC
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`Neil Hannemann - April 8, 2015
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`4
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` 1 C O N T E N T S
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` 2
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` 3 EXAMINATION OF NEIL HANNEMANN PAGE
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` 4 By Mr. Angileri 5
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` 5 By Mr. Guarnieri 83
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` 6
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` 7
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` 8 E X H I B I T S
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` 9 (Retained by Counsel.)
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`10
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`11 HANNEMANN EXHIBIT PAGE
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`12 1 Declaration of Neil Hannemann 5
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`13 2 U.S. Patent No. 8,214,097 5
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`14 3 U.S. Patent No. 5,343,970 5
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`15 4 "The Effects of APU Characteristics on the
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`16 Design of Hybrid Control Strategies for
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`17 Hybrid Electric Vehicles" 5
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`18 5 Curriculum Vitae 70
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`19 6 Supplemental Declaration 80
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`20
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`21
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`25
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` 1 P R O C E E D I N G S
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` 2 (HANNEMANN Exhibits 1 through 4 were marked
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` 3 for identification and retained by counsel.)
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` 4 (NEIL HANNEMANN, having been duly sworn, testified as
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` 5 follows:)
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` 6 EXAMINATION BY COUNSEL FOR PETITIONER
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` 7 BY MR. ANGILERI:
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` 8 Q Can you state your name for the record,
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` 9 please?
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`10 A Neil Hannemann.
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`11 Q Mr. Hannemann, the reporter has marked, as
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`12 Exhibits 1 through 4, documents that I expect we'll get
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`13 into today.
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`14 What is Exhibit 1?
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`15 A Exhibit 1 is the declaration that I prepared
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`16 in this matter.
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`17 Q And this matter is IPR 2014-00570?
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`18 A That's correct.
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`19 Q Concerning -- strike that.
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`20 What's Exhibit 2?
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`21 A Exhibit 2 is U.S. Patent 8,214,097.
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`22 Q And that's the patent that's at issue in this
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`23 IPR?
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`24 A That's correct.
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`25 Q We sometimes call it the '097 patent?
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` 1 A That's correct.
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` 2 Q What is Exhibit 3?
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` 3 A It's Patent Number 5,343,970.
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` 4 Q Sometimes we call that the '970 patent?
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` 5 A That's correct.
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` 6 Q That's part of the prior art that's at issue
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` 7 in this IPR?
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` 8 A Yes, it is.
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` 9 Q What is Exhibit 4?
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`10 A It's an SAE paper, 950493, titled "The Effects
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`11 of APU Characteristics on the Design of Hybrid Control
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`12 Strategies for Hybrid Electric Vehicles."
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`13 Q One of the named authors is a person named
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`14 Catherine Anderson. Correct?
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`15 A That's correct.
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`16 Q And as a result, we sometimes refer to this as
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`17 the Anderson paper or just Anderson?
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`18 A Yes.
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`19 Q What did you do to prepare for this deposition
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`20 and the depositions that you've had yesterday and today?
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`21 A Well, I --
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`22 MR. GUARNIERI: And I'll just caution him not
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`23 to get into any privileged communications.
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`24 But you can answer.
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`25 A I came here last week to meet with counsel and
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`Neil Hannemann - April 8, 2015
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`7
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` 1 review the declaration, the prior art, and the patent.
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` 2 Q When did you come here last week to meet with
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` 3 counsel?
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` 4 A On Wednesday.
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` 5 Q How long were you here?
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` 6 A Probably about most of the day, the normal
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` 7 workday.
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` 8 Q Did you leave at the end of the day?
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` 9 A Yes.
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`10 Q Where did you go? Did you go back home?
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`11 A No, no, I stayed in Washington. I met for
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`12 three days last week. I arrived here Wednesday and met
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`13 Wednesday, Thursday, Friday.
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`14 Q With counsel?
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`15 A Yes.
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`16 Q Did you prepare at all on Monday?
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`17 A Yes, I did.
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`18 Q Did you -- were you on any flights on Monday?
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`19 A Yeah, I flew back here Monday.
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`20 Q From where?
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`21 A I was actually in Texas.
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`22 Q So you were in Washington, D.C., Wednesday,
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`23 Thursday, Friday of last week meeting with counsel for
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`24 Paice?
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`25 A Yes.
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` 1 Q And then you left Washington, D.C.?
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` 2 A Yes.
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` 3 Q And then you came back on Monday?
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` 4 A That's correct.
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` 5 Q Who did you meet with on Wednesday, Thursday
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` 6 and Friday last week?
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` 7 A Well, at various times Mr. Guarnieri,
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` 8 Mr. Marcus, and Ms. Kordziel.
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` 9 MR. GUARNIERI: For the record I think he's
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`10 referring to Mr. Livedalen, Brian.
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`11 THE WITNESS: Oh, sorry.
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`12 Q How did you prepare the declaration that's
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`13 been marked as Exhibit 1?
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`14 A Quite a while ago, I reviewed all the material
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`15 that was the prior art and the patent and had -- I came
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`16 here to Washington to meet with counsel and discuss all
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`17 the elements, the technical matters.
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`18 And then I worked with counsel to, you know,
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`19 draft up various portions of this, or add or work through
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`20 a draft until arriving at this product.
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`21 Q Did counsel prepare first drafts of any
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`22 portions of Exhibit 1?
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`23 A Yeah, there were some portions that they
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`24 drafted up initially.
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`25 Q Do you know which portions?
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` 1 A You know, I might be able to pick some out.
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` 2 I'm not sure I would be getting all of them correct.
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` 3 Q Which portions of Section 8 did counsel
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` 4 prepare the first draft of?
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` 5 A That's one where I'm not sure which section
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` 6 started with counsel or myself.
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` 7 Q Can you identify any section that you prepared
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` 8 the first draft of?
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` 9 A Yeah. My memory is probably not that good to
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`10 go back and define it to that level of detail.
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`11 Q The other declarations that we marked in 571
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`12 and 579 depositions that were yesterday and today -- do
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`13 you recall those declarations?
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`14 A Yes.
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`15 Q Were they prepared in a similar manner as the
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`16 manner you just described --
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`17 A Yeah.
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`18 Q -- in Exhibit 1?
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`19 A Yeah, in a similar manner.
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`20 Q And for those two declarations, can you recall
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`21 any section that you prepared the first draft of?
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`22 A Some of the sections and probably the more
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`23 technical sections are probably ones that I prepared.
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`24 And, certainly, my background is something that I
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`25 started.
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` 1 Q Is there anything specifically that you can
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` 2 identify as preparing the first draft of other than your
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` 3 background?
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` 4 A Specifically in this declaration, or are you
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` 5 talking the other ones also?
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` 6 Q Any of the three.
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` 7 A Any of them. I just don't remember which ones
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` 8 I started or somebody else may have started.
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` 9 Q How much time did you spend preparing or
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`10 working on -- strike that.
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`11 How much time did you spend -- strike that.
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`12 How much time have you spent in these three
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`13 proceedings, 570, 571 and 579?
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`14 A I don't think I've really tracked my time for
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`15 each proceeding, so that's hard to say.
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`16 Q What about the three proceedings combined?
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`17 A Well, these have overlapped with three other
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`18 proceedings that are ongoing now, so it would be hard to
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`19 really break that out.
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`20 Q Can you tell me how much time you've spent on
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`21 the -- strike that.
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`22 How many proceedings have you worked on for
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`23 Paice thus far?
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`24 A The six that I've prepared declarations for.
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`25 Q How much time have you spent on those six
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`11
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` 1 declarations?
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` 2 A I really don't have any idea, as I sit here.
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` 3 Q Do you know how much time you spent on all six
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` 4 of those proceedings combined?
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` 5 A Not really.
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` 6 Q Do you know how much you've billed Paice for
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` 7 these six proceedings?
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` 8 A I would have invoices, but I don't have those
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` 9 with me.
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`10 Q Can you estimate to within $100,000 of how
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`11 much you've billed Paice?
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`12 A Sure. I think it's pretty safe to say it's
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`13 less than $100,000.
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`14 Q Is it less than $50,000?
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`15 A It's really hard to say without checking, but
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`16 it's likely that it is.
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`17 Q Is it less than $25,000?
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`18 A Probably not.
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`19 Q Can you look at Exhibit 3, please?
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`20 A (Witness complies.)
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`21 Q Exhibit 3 is the '970 patent. Correct?
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`22 A Yes.
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`23 Q The '970 patent describes a parallel system.
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`24 Is that correct?
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`25 A Yes, it does.
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` 1 Q Does the '970 patent have a mode where only
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` 2 the motor is used to propel the vehicle?
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` 3 A Yes, it does.
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` 4 Q And does it have a mode where only the engine
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` 5 is used to propel the vehicle?
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` 6 A Yes, it does.
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` 7 Q Does it have a mode where the engine and the
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` 8 motor are both used to propel the vehicle?
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` 9 A Yes, it does.
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`10 Q When the motor is used to propel the vehicle,
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`11 is the engine disconnected from the wheels through a
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`12 clutch?
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`13 MR. GUARNIERI: I'm going to object to the
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`14 extent it calls for speculation.
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`15 A Figure 3 shows a clutch, and up through
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`16 Figure 9 shows a clutch. So at least the ones disclosed
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`17 in those figures appear to use a clutch to disconnect the
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`18 engine.
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`19 Q Is it true that in order to run in the
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`20 motor-only mode for the '970 patent, you actually have to
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`21 disconnect the engine from the wheels?
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`22 A Are you speaking generically or in the scope
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`23 of this patent?
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`24 Q In the '970 patent.
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`25 A I don't recall seeing any language where it
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`13
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` 1 specifically requires the clutch be disconnected.
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` 2 Q If the clutch doesn't disconnect the engine,
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` 3 would you agree, then, that the engine would always have
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` 4 to be running?
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` 5 A Unless there's some mechanism within what they
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` 6 describe as a torque transfer unit that could allow the
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` 7 unit to --
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` 8 THE REPORTER: A torque trans?
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` 9 THE WITNESS: Torque transfer unit.
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`10 Q Do you agree that for the -- to run in a
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`11 motor-only mode, somehow -- strike that.
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`12 Do you agree that for the '970 to run in the
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`13 motor-only mode and not -- strike that.
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`14 Do you agree that for the '970 patent to run
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`15 in the motor-only mode, it somehow has to disconnect the
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`16 engine from the wheels in order to do that?
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`17 A I would think that's a reasonable thing to do.
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`18 I just don't see where it specifically states that.
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`19 Q Do you think that's how a person of ordinary
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`20 skill in the art would understand the '970 patent?
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`21 A I think in the presence of the clutch, that's
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`22 how someone would understand it operated.
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`23 Q So just to be clear, a person of skill in the
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`24 art would understand that when the '970 patent is running
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`25 in motor-only mode, it's using the clutch to disconnect
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`14
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` 1 the engine from the wheels. Do you agree with that
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` 2 statement?
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` 3 A Yes, I do.
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` 4 Q Do you agree that an object of the invention
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` 5 of the '970 patent is reducing emissions?
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` 6 A I think that's an aspirational goal, to reduce
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` 7 emissions, yes.
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` 8 Q In fact, if you look at Column 5, Lines 24 to
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` 9 30, isn't that the first stated object of the invention
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`10 in the '970 patent?
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`11 A Yes.
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`12 Q Do you agree that in the acceleration
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`13 hill-climbing mode of the '970 patent, the motor is used
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`14 to supplement the engine?
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`15 MR. GUARNIERI: Objection. Assumes facts not
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`16 in evidence and calls for speculation.
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`17 A Yeah, I agree in the high-speed
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`18 acceleration/hill-climbing mode, both the internal
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`19 combustion engine and the electric motor provide torque
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`20 to the road wheels.
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`21 Q Do you agree, then, that in that situation,
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`22 the engine is providing less than the amount of torque
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`23 required to operate the vehicle?
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`24 A Yeah. You have torque coming from both the
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`25 engine and the motor, so neither one is providing the
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`15
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` 1 total power required. So they're both providing less.
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` 2 Q Do you agree that the '970 patent can enter an
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` 3 acceleration hill-climbing mode before it reaches the
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` 4 engine's MTO or minimum torque output?
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` 5 A Yeah. According to the '970, it enters that
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` 6 mode based on vehicle speed.
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` 7 Q And that can -- I don't agree with you there,
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` 8 but you agree that can happen before the engine reaches
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` 9 its maximum torque output or MTO?
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`10 MR. GUARNIERI: Objection. Form.
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`11 A Yeah. And I guess the word "reaching" implies
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`12 that the engine is already on. So if the engine is not
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`13 already on, it's not going to reach any torque.
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`14 Q Are you saying that the '970 can enter
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`15 acceleration hill-climbing mode by starting with the
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`16 motor and then adding the engine?
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`17 A I think that's one way it can enter that mode,
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`18 yes.
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`19 Q And obviously in that case you are using both
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`20 the motor and the engine in a situation where the engine
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`21 has not yet hit its maximum torque output. Correct?
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`22 A Yeah. I think that there's points in the
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`23 high-speed acceleration/hill-climbing mode where the
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`24 engine is not at its maximum torque.
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`25 Q And you're using the motor and the engine at
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`16
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` 1 those times. Right?
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` 2 A Yes.
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` 3 Q Do hybrid vehicles use AC motors or DC motors?
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` 4 A I would say most of them use AC motors
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` 5 currently. There have been some that have used DC motors
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` 6 in the past.
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` 7 Q In the past, were DC motors a better fit?
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` 8 MR. GUARNIERI: Objection. Vague.
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` 9 A Yeah. It depends on the design goals and the
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`10 design criteria.
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`11 Q Which is a better -- which is better to use?
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`12 AC motors or DC motors?
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`13 MR. GUARNIERI: Same objection. Vague.
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`14 A Yeah. It depends on what's important in your
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`15 design. If it's performance, weight, cost, all those
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`16 issues can drive a different design decision.
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`17 Q Is a person of ordinary skill in the art going
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`18 to consider those design criteria, that you just
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`19 mentioned, when making a choice between AC and DC motors?
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`20 A Yeah. I think every choice designing a car
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`21 has cost, weight, and performance implications.
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`22 Q So would a person of ordinary skill in the art
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`23 consider the factors you identified in choosing between
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`24 AC and DC motors?
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`25 A Those are some of the factors they would
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`17
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` 1 consider, yes.
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` 2 Q Any others that come to mind?
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` 3 A In a broad sense that's -- those are the main
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` 4 criteria.
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` 5 Q The Anderson reference, which is Exhibit 4 --
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` 6 and you can certainly consult it if you want -- talks
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` 7 about transients. Do you see that?
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` 8 A Yes.
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` 9 Q What are the transients that Anderson is
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`10 speaking about?
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`11 MR. GUARNIERI: Object to the extent that
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`12 calls for speculation.
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`13 A Yeah. Transients can be -- transient is a
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`14 generic term that can relate to any kind of a changing
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`15 condition. I think someone of skill in the art would
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`16 realize that Anderson is speaking about an engine speed
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`17 transient.
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`18 Q Anderson talks about an LLD. Do you remember
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`19 that?
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`20 A Yes.
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`21 Q Do you agree that's a battery?
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`22 A Not always. But I think in her context she's
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`23 always referring it back to a battery, but one of the
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`24 vehicles that I worked on had a flywheel as an LLD.
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`25 So it can be many other devices. That's why
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`18
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` 1 she uses the generic term. But I think every specific
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` 2 reference to that in her paper is referring to a battery.
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` 3 Q Do you agree that if you use a motor to
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` 4 supplement an engine, you're going to put a strain on the
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` 5 battery --
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` 6 MR. GUARNIERI: Objection.
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` 7 Q -- by cycling the battery?
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` 8 MR. GUARNIERI: Objection. Vague.
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` 9 A Yeah. The word "strain" to me means something
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`10 that may be outside of its normal duty cycle. So hybrid
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`11 electric vehicle or any vehicle that uses a battery is
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`12 designed for a certain duty cycle. And if you work
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`13 within that duty cycle, then you're not per se straining
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`14 the battery. You're operating it as intended.
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`15 Q Do you agree that Anderson identifies what she
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`16 calls two distinct extremes in the spectrum of control
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`17 strategies?
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`18 A In the context she's talking about is for a
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`19 series hybrid. She has extreme control strategy that she
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`20 calls the thermostat and one that she calls the follower
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`21 strategy.
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`22 Q And she says that neither of those extremes is
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`23 normally used in the real world. Right?
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`24 A Yeah. She says realistically you may use
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`25 something in between, but she feels that those are, say,
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` 1 the bookends of a series strategy, at least for
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` 2 controlling the engine.
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` 3 Q So that contemplates sort of a modified
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` 4 follower strategy, where sometimes you follow demand and
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` 5 sometimes you don't. Do you agree with that?
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` 6 MR. GUARNIERI: Object to the extent that
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` 7 calls for speculation.
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` 8 A I think somebody that's skilled in the art
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` 9 would realize you could -- you could blend these for a
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`10 specific strategy.
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`11 Q What would a nonextreme follower mode look
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`12 like? Strike that.
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`13 What would be one example of a nonextreme
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`14 follower mode that a person of skill in the art would
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`15 understand?
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`16 MR. GUARNIERI: Objection. Vague.
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`17 Q Circa 1988.
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`18 MR. GUARNIERI: Same objection.
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`19 A Well, I think that one thing that we may have
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`20 been thinking about is how to use these types of
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`21 strategies when you have a plug-in vehicle. And in that
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`22 case you might modify this strategy so that you -- to a
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`23 degree, deplete the state of charge through operation so
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`24 you can take advantage of plugging the vehicle in.
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`25 That's one area, one example I could conceive of
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` 1 modifying the strategy.
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` 2 Q So in that example, you said it's a plug-in
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` 3 hybrid?
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` 4 A If your design goal or if your vehicle design
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` 5 criteria included a plug-in strategy, then it's likely
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` 6 you would modify the -- this control strategy.
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` 7 Q When you use the term "plug-in," what do you
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` 8 mean?
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` 9 A Well, everything Anderson is discussing is
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`10 trying to maintain a given fixed state of charge in the
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`11 battery. If you realize that you have the capability to
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`12 plug the vehicle in, then you can deplete the charge, and
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`13 when you plug the vehicle in. You can take the energy
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`14 from the wall socket rather than generating all the
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`15 battery charge energy from the engine.
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`16 Q Okay. And in your answer you said that if
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`17 you're talking about a plug-in, your words were, "It's
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`18 likely you would modify this control strategy."
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`19 Which control strategy are you referring to in
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`20 that answer?
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`21 A Well, the control strategy that Anderson
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`22 discusses for a series hybrid, which is bookended by the
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`23 thermostat and follower modes.
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`24 Q What do you mean by "bookended"? Is it a
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`25 follower strategy or a thermostat strategy that you're
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` 1 modifying?
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` 2 A Well, I think it would be -- I think they're
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` 3 both different strategies. It would just be a third
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` 4 strategy.
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` 5 Q What would be the third strategy?
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` 6 A I could conceive having a strategy for the
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` 7 concept of using a plug-in vehicle.
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` 8 Q And are you saying that this plug-in strategy
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` 9 that you're describing is a modification of a follower
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`10 extreme, or is it a modification of a thermostat extreme?
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`11 MR. GUARNIERI: Objection. Vague.
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`12 A I mean, I think it would be a third strategy
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`13 that's somewhere in between the two.
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`14 Q How so?
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`15 A Well, as I said, both of these strategies
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`16 strive to maintain a certain state of charge. The third
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`17 strategy would have some kind of a depletion to the
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`18 charge. I guess you could do that with either one. You
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`19 could start with one or the other and modify it to arrive
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`20 at that.
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`21 Q Explain, for the record, the thermostat
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`22 strategy, the thermostat extreme strategy. Strike that.
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`23 Explain for the record the extreme thermostat
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`24 strategy.
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`25 MR. GUARNIERI: Object to the form of the
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` 1 question as vague.
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` 2 A And you said the extreme thermostat strategy?
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` 3 Q Yes.
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` 4 A Okay. I'm just looking to find Anderson's
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` 5 explanation, to be most accurate.
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` 6 Okay. She describes the thermostat as the --
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` 7 the thermostat algorithm is used to command an APU, which
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` 8 is what she's referring to as an engine -- what she's --
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` 9 auxiliary power unit, so her engine. You turn the
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`10 auxiliary power unit on to a constant power level when
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`11 the state of charge of the load-limiting device is below
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`12 a certain lower threshold.
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`13 Q Where are you reading?
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`14 A I'm on page 5 of 9 of the Anderson paper. I
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`15 believe it's -- 67 is another page number on it.
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`16 Q So please, again, describe the extreme
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`17 thermostat strategy.
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`18 A All right. The reference to a thermostat is
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`19 how a thermostat works in the home. But, basically, when
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`20 the stated charge drops to a certain level, the auxiliary
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`21 power unit is turned on to a constant power level, and
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`22 then it switches off again when the state of charge
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`23 exceeds an upper threshold.
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`24 Q So the thermostat strategy does not strive to
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`25 maintain a constant state of charge. Correct?
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` 1 A Yeah. A constant state of charge, but there
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` 2 is a range for switching it on and off. So there is some
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` 3 hysteresis built into the system.
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` 4 Q Because Anderson says that you turn on the
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` 5 engine when the state of charge of the battery is below a
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` 6 certain lower threshold, and you turn off the engine when
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` 7 the state of charge exceeds an upper threshold. Correct?
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` 8 A That's correct.
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` 9 Q So the state of charge of the battery in the
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`10 extreme thermostat strategy varies between this lower
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`11 threshold and upper threshold?
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`12 A That's correct.
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`13 Q What about the extreme follower strategy? How
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`14 does that work?
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`15 MR. GUARNIERI: Object to the form of the
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`16 question.
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`17 A That strategy is the controller -- or the
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`18 strategy itself commands the APU to follow the actual
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`19 real torque whenever possible.
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`20 Q And the APU is the engine. Right?
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`21 A Yes.
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`22 Q Which of these two extremes has more engine
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`23 transients?
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`24 MR. GUARNIERI: Objection. Vague.
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`25 A That would depend on the upper and lower
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` 1 threshold of the thermostat. If those were set very
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` 2 close, that would create more transition.
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` 3 So the thermostat algorithm could have a wide
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` 4 variety of trance audience based on how the designers
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` 5 choose to calibrate the system.
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` 6 Q If the upper and lower thresholds and the
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` 7 therm motors are not set very close, then you agree that
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` 8 the follower extreme is going to have more transients
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` 9 than the thermostat extreme?
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`10 MR. GUARNIERI: Same objection.
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`11 A I would say it would have more engine speed
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`12 transients.
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`13 Q What are those engine speed transients caused
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`14 by?
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`15 A Well, engine speed would increase as a result
`
`16 of opening the throttle in the engine. And it could also
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`17 result from closing the throttle because a decrease in
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`18 RPM is also an engine speed transient.
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`19 Q In the case of an increase, why is the engine
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`20 speed -- strike that.
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`21 In the case of an increase, why is the
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`22 controller opening throttle in the engine?
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`23 A Well, it wouldn't necessarily be a controller.
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`24 It could be the operator opening the throttle.
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`25 Q Okay. So let's --
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`Neil Hannemann - April 8, 2015
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`25
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` 1 A But --
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` 2 Q Just -- since you said that --
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` 3 MR. GUARNIERI: Do you want him to answer, let
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` 4 him finish?
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` 5 MR. ANGILERI: Not really. I'm going to
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` 6 cl
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