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`LLC I
` UUS:
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`Patent Owner
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`Case IPR2014—OO416
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`Patent 8,217,612
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`Case IPR2014—OO4417
`Patent 7,579,802
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`J03 NO.: 5556
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`www. krusereporters .Com .
`KrLtse.:A§sociatn
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`4.
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`UUSI’LLC
`Patent Owner
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`Case:
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`|PR2014-00650
`Patent: 7,579,802
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`I)
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`called for examination pursuant to the Rules or
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`United States Patent and Trademark o "ice,
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`
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`before CERYL L. SAN u]«'.CK ,
`UUSI, LLC
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`
`
`Reporter for she Stare o" "
`EXhHflt2015
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`
`
`
`
`LaSalle Svreev, Chicago,
`September 26, 2014, at the
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`
`
`
`The deposition of C. ART MaCCARLEY,
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`taken
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`WEBASTO ROOF SYSTEMS,
`”HQ:
`Petltloner
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`BROSE NORTH AMER"
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`
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`and
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` %H & CO.
`HALLSTAI
`".
`T.]*'. GM
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`
`
`KG,
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`Petitioner
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`VS.
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`
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`LLC I
` UUS:
`
`
`Patent Owner
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`
`
`
`
`Case IPR2014—OO416
`
`Patent 8,217,612
`
`
`
`Case IPR2014—OO4417
`Patent 7,579,802
`
`
`
`
`
`a.m.
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`RdZBORTfiii %Y:
`CHdZRYT.
`..
`SAN
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`T. Castaz NO.:
`084—03710
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`
`
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`J03 NO.: 5556
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`www. krusereporters .Com .
`KrLtse.:A§sociatn
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`4.
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`V.
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`UUSI’LLC
`Patent Owner
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`Case:
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`|PR2014-00650
`Patent: 7,579,802
`
`
`
`
`
`I)
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`called for examination pursuant to the Rules or
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`
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`
`
`United States Patent and Trademark o "ice,
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`
`
`
`
`before CERYL L. SAN u]«'.CK ,
`UUSI, LLC
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`
`
`
`Reporter for she Stare o" "
`EXhHflt2015
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`
`
`
`
`LaSalle Svreev, Chicago,
`September 26, 2014, at the
`
`
`
`
`The deposition of C. ART MaCCARLEY,
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`taken
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`WEBASTO ROOF SYSTEMS,
`”HQ:
`Petltloner
`
`
`
`MacCarley
`
`Page 1
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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,
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`called for examination pursuant to the Rules of
`
`United States Patent and Trademark office, taken
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`before CHERYL L. SANDECKI, Certified Shorthand
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`Reporter for the State of Illinois, at 300 North
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`LaSalle Street, Chicago, Illinois, on
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`September 26, 2014, at the hour of 10:30 o'clock
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`a.m.
`
`REPORTED BY: CHERYL L. SANDECKI, CSR, RPR
`LICENSE NO.: 084-03710
`JOB NO.: 5556
`
`www.krusereporters.com
`
`312.345.1500
`
`UUSI, LLC
`Exhibit 2015
`1/214
`
`
`
`MacCarley
`
`Page 2
`
`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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`312.345.1500
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`UUSI, LLC
`Exhibit 2015
`2/214
`
`
`
`MacCarley
`
` INDEX
`
`WITNESS EXAMINATION
`
`Page 3
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` C. ART MacCARLEY
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` 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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` (Witness administered an oath.)
`
` C. ART MacCARLEY,
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`having been first administered an oath, was
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`examined and testified as follows:
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` 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
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`the patent owner UUSI, LLC. And for the record,
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`if you can state your full name, date of birth
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`and home address?
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` A. Carl Arthur MacCarley. Do you need me
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`to spell that?
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` Q. Not for me, thank you.
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` A. My home address is 1413 Eucalyptus
`
`Road, Nipomo, spelled N-I-P-O-M-O, California,
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`93444. My date of birth is January 10th, 1954.
`
` Q. Okay. Thank you.
`
` Have you been deposed before?
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` A. No.
`
` Q. Okay. Have you ever testified in court
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`before?
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`www.krusereporters.com
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`UUSI, LLC
`Exhibit 2015
`4/214
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`
`MacCarley
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`Page 5
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` A. No. Oh, let me take that back. Not on
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`an expert witness case. I have testified just
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`as a witness on a civil suit.
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` Q. Okay. Were you a party to that?
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` A. No.
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` Q. Okay. Well, let me go over just some
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`basic ground rules of depositions.
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` My job is to ask questions and your job
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`is to answer them.
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` Brose's attorney may object to my
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`questions, but answer them anyway unless they
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`are attorney/client privileged.
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` You must answer all questions
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`truthfully under penalty of perjury. You must
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`give answers with a yes, no or explanation.
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`Uh-huhs and shrugs -- I can't see shrugs, and
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`it's difficult for the court reporter to pick up
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`the uh-huhs.
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` I will do my best to make my questions
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`clear. But if you don't understand them, either
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`technically or just the way I word them, please
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`let me know and I will try to rephrase them.
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` If you answer the question, I will
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`presume you understood it. Do you understand
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`www.krusereporters.com
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`312.345.1500
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`Exhibit 2015
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`MacCarley
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`those instructions?
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` A. Yes, I do.
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` Q. Great. This deposition is for both of
`
`the U.S. Patent Office Inter Parte Review
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`proceedings filed by Brose against UUSI. So
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`that would be IPR2014-00416 and 417.
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` Are you represented by an attorney
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`today at this deposition?
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` A. I am with Kirkland & Ellis attorneys.
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`I do not have my own personal attorney here.
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` Q. Okay. Are those attorneys actually
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`representing you in an attorney/client
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`relationship?
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` MR. LEAVELL: Monte, this is Craig. I will
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`answer that.
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` We were not. We are not counsel to the
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`witness. We are here on behalf of the
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`petitioners who have retained the witness in his
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`expert capacity for this case.
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`BY MR. FALCOFF:
`
` Q. And do you agree with that,
`
`Dr. MacCarley?
`
` A. Yes.
`
` Q. Great. Thank you.
`
`www.krusereporters.com
`
`312.345.1500
`
`UUSI, LLC
`Exhibit 2015
`6/214
`
`
`
`MacCarley
`
` Have you ever been an expert in a
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`Page 7
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`patent lawsuit before?
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` A. Yes.
`
` Q. Okay. And which one or ones?
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` A. It was -- I was a defense expert in
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`support of a lawsuit against Harley-Davidson
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`Motor Corporation -- Motor Company, excuse me,
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`in a patent infringement possible invalidation
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`suit. I believe it -- just a few years ago.
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` Q. Who was the plaintiff in that lawsuit?
`
` A. I don't recall the exact name.
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` Q. Would that possibly have been
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`Combustion Controls?
`
` A. Yes, it was. They went by three other
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`names, I believe.
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` Q. I see. Okay.
`
` And did you submit an expert
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`declaration or report in that lawsuit?
`
` A. I submitted a report. I did not submit
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`an expert declaration.
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` Q. I believe before you testified that you
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`have not testified as an expert witness in a
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`deposition or a trial before. So do I take it
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`that you did not have your deposition taken in
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`Exhibit 2015
`7/214
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`MacCarley
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`Page 8
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`that Harley-Davidson case?
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` A. That's correct.
`
` Q. Okay. Did you act as an expert in any
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`other patent lawsuit?
`
` A. No.
`
` Q. Okay. Have you ever testified in a
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`patent office Inter Partes Review proceeding
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`before?
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` A. No.
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` Q. Submit any declarations or expert
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`reports in any such Inter Partes Review
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`proceeding prior to this one?
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` A. Not in an IPR.
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` Q. Okay. I would have been amazed if you
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`said you had, given the newness of the
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`procedure.
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` Have you ever been an inventor on a
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`patent application before?
`
` A. Yes.
`
` Q. Pertaining to what technologies?
`
` A. Most recently an adaptive control -- an
`
`advanced adaptive control method used for
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`automated sensor and detector validation. This
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`was as a result of work I do for Cal Trans.
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`www.krusereporters.com
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`312.345.1500
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`UUSI, LLC
`Exhibit 2015
`8/214
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`
`
`MacCarley
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`Page 9
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` Previously an assistive device for the
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`blind that provided graphical -- provides a
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`spoken interface in addition to the graphical
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`interface. This had to do with assisting
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`teaching science and engineering.
`
` Q. Okay. Did that patent or patent
`
`application pertain to electric motor controls
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`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
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`usually I'm referring to -- I will always be
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`referring to U.S. Patent 7,579,802.
`
` The '612 patent for U.S. Patent Number
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`8,217,612 patent. Itoh, I-T-O-H, for the '333
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`patent for U.S. Patent No. 4,807,333. Kinzl or
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`www.krusereporters.com
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`312.345.1500
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`UUSI, LLC
`Exhibit 2015
`9/214
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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.
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`Zuckerman or '000 patent for U.S. Patent
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`No. 5,069,000.
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` 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
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`refer to Brose as the petitioner or the
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`collective companies -- I think there is a
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`couple Brose entities that filed a petition with
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`the present IPRs in which your expert
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`declarations are in.
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` 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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`www.krusereporters.com
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`312.345.1500
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`UUSI, LLC
`Exhibit 2015
`10/214
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`
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`MacCarley
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`Page 11
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`witness, just let us know and we can mark them
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`or we can mark them in whatever order or do it
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`now. But she has the copies right now.
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` MR. FALCOFF: Okay. From an administrative
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`marking standpoint, I believe every exhibit we
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`are using is already introduced as an exhibit
`
`attached to the expert report are your
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`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
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`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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`www.krusereporters.com
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`312.345.1500
`
`UUSI, LLC
`Exhibit 2015
`11/214
`
`
`
`MacCarley
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`Page 12
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`on Monday of -- we will call and deal with this
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`separately. Sorry to waste your time now.
`
` You know how on Google Patents,
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`sometimes you print them out and the lines don't
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`show on the figures, that's apparently what
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`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
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`we printed out and gave to the court reporter
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`for the '802, '612, Itoh and Kinzl.
`
` So it may be easier for everybody if we
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`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
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`spend preparing for this deposition today,
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`approximately?
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` A. About 40 hours.
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` Q. Okay. And what did you do in that
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`preparation?
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` A. There was review of all of the relevant
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`documents that I did prior to coming to Chicago.
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`And then I have been meeting with the Kirkland &
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`Ellis attorneys for two days --
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` Q. Okay.
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` A. -- to help prepare me for the actual
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`deposition.
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` Q. The documents reviewed, were all of
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`those attached to your expert report or part of
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`your expert report or were there any additions
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`to that?
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` A. I believe the only additions was in the
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`course of our work in the past few days, we put
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`together an index so that I can find things
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`faster.
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` Q. I can certainly understand the need for
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`that. Did you actually review any parts in
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`preparation for today's deposition?
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` A. Could you explain what you mean by
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`parts?
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` Q. Physical parties.
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` A. Oh, physical, no, I did not.
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` Q. Okay. In preparation for your
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`deposition today, did you talk to any employees
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`of Brose? So by that I'm excluding the Kirkland
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`& Ellis attorneys.
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` A. No, I didn't.
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` Q. Prior to your signing of the expert
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`declarations for the '612 and '802 patents, did
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`you converse with any Brose employees other than
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`the Kirkland attorneys?
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` A. No.
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` Q. Okay. Who is your current employer?
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` A. I don't have a personal attorney on
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`retainer.
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` Q. Let me reask the question.
`
` A. I apologize. I misheard. You said
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`"employer".
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` Q. Employer. Yes.
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` A. California State University System.
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`I'm a professor at Cal Poly, San Luis Obispo,
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`which is primarily an engineering university.
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` Q. Is that different than Cal Tech?
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` A. Yes.
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` Q. Okay. In your current position, what's
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`your title there? Or if you have multiple
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`titles, what are they?
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` A. I am a professor of electrical and
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`computer engineering. I am currently the
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`department head of the BioResource and
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`Agricultural Engineering Department. I'm
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`director of the transportation research
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`laboratory. I suppose there is some committee
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`titles that aren't relevant.
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` Q. Okay. Now, the laboratory you
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`mentioned, what projects -- well, first off, how
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`long has that been in existence that you have
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`been a part of?
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` A. Since early '90s.
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` Q. Okay. Can you put a more definite year
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`on that when you first started working with that
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`group?
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` A. Not at this time. I would go back
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`through my records to pin it down.
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` Q. All right. Have you been involved with
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`it since it was created?
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` A. Yes.
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` Q. Okay. And what projects are currently
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`being worked on in that laboratory?
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` A. Currently, as of me accepting the
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`position of department head again, I have no
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`currently funded projects through that
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`laboratory. The question was current; is that
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`correct?
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` Q. Yes. This was correct.
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` So when was the last time you did have
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`a project with that laboratory or through that
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`laboratory?
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` A. I believe it terminated the end of the
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`summer before this last one. It was for the
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`California Department of Transportation
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`involving advanced automated sensor and detector
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`validation using an adaptive algorithm and
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`specialized hardware.
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` Q. Is that for traffic control management?
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` A. It's for evaluation of technologies
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`that are used for traffic control management.
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` Q. I see. Okay. Anything to deal with --
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`that deals directly with DC electric motors in
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`cars?
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` A. No.
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` Q. Has that laboratory since you first
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`started working with them in 1990s ever done any
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`projects there dealing with automotive vehicle
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`DC electric motors?
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` A. Yes.
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` Q. Okay. What was that?
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` A. In the late '90s, I did work funded by
`
`the California Energy Commission, Pacific Gas
`
`and Electric Company, some university support
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`also in which we were developing some advanced
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`technologies related to electric vehicles.
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` Q. So those would be traction drive
`
`motors?
`
` A. We weren't -- that project wasn't
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`directly in motor development. I also -- I also
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`did have my own company for about ten years in
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`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
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`battery exchange for electric vehicles, which
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`involves an automated mechanism with both
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`motors.
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` Q. I understand. And did you -- are there
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`any other projects through the laboratory there
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`at the university where you worked on automotive
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`Page 18
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`vehicle DC electric motors?
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` A. Well, I teach a course in which
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`electric vehicles is one of the major topics.
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`So I do go fairly -- I go to a level of
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`application depth associated with the various
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`types of motors that can be used for traction.
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` Q. Okay. That's separate from the
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`laboratory work, right?
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` A. Yes. I mean, I'm a professor. I
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`primarily teach.
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` Q. Okay. So, again, going back to the
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`question for the laboratory, have you ever
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`worked on any projects there where the work
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`pertained to automotive vehicle DC electric
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`motors through the laboratory?
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` A. I can't recall any of the work.
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` Q. Okay. Now, through your private
`
`company that you mentioned, what was the time
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`frame that you started that up?
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` A. 1997.
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` Q. Okay. And what -- does it still exist?
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` A. It exists as a name. But it's just --
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`it's just me now. I closed my bricks and mortar
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`location when I most recently -- it was in 2008
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`when I was appointed the department chair of the
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`electrical engineering department.
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` Q. Okay. So with your private company,
`
`did you ever do any work on DC electric motors
`
`in automotive vehicles?
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` A. Yes. We, in fact, developed an
`
`under -- with some funding from the U.S.
`
`Department of Energy and an external entity that
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`had developed a novel rotating machine, they
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`came to us to produce for them the required
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`specialized high-powered drive electronics that
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`would drive their machine.
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` Q. What kind of machine?
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` A. It's a -- it was a configuration of
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`a -- it's in the class of electronically
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`commutated DC motors. But it had a very novel
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`magnetic flux path that allowed the rotor
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`magnetic field to be developed by a toroidal
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`selenoid to the end case, avoiding the need for
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`brushes, but effectively coupling in the fixed
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`magnetic field to the rotor.
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` Q. This is used in automotive vehicles?
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` A. It never actually went into -- that
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`particular company that came to us to do this
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`for them never got it into production.
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` I might parenthetically add, though,
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`that their concept did find its way into
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`multiple other products, especially automotive
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`alternators.
`
` Q. Okay. So was this project that you
`
`were working on with your company for the
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`automotive use, was that primarily for or
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`intended for use in alternators?
`
` A. No.
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` Q. What were the other uses of this very
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`specialized motor?
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` A. The specific objective was to -- was to
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`deploy the rotating machine and drive
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`electronics as a very high-powered density
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`electric motor for electric vehicles.
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` Q. For the actual traction motor in
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`electric vehicles?
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` A. That's correct.
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` Q. Now, the work that you have done -- I
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`think you have done other, what, traction motor
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`work for automotive vehicles; is that correct?
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` A. It's not my specialization. So I can
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`say I have had a hand in quite a few
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`student-based projects. I have worked with
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`colleagues who have worked on this type of
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`thing. But I wouldn't go so far as to say
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`I've -- I could take primary responsibility for
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`something like that.
`
` Q. Okay. Would you consider yourself to
`
`be an expert in the field of automotive DC
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`electric motors?
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` A. I'm going to subdivide your question
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`because there are two broad classes of DC
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`electric motors. I mean, the type relevant in
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`this case is a permanent magnet motor, which
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`is -- it's -- they are ubiquitous in window
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`drive mechanisms.
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` It's such a well-established technology
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`that it hardly takes much expertise to say you
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`know everything about them. I certainly meet
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`that qualification.
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` As far as the whole broad range of
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`advanced DC electric drives, novel motor
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`configurations, I would not consider myself an
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`expert. That's a fairly specialized field.
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` Q. Let's break it down then. The
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`permanent -- let me rephrase the question.
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` For the type of electric motor that's
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`used in automotive vehicle window lift
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`mechanisms in the 1990s, specifically the early
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`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?
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` A. Yes.
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` 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
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`mechanisms?
`
` A. Yes. You said window lift mechanisms;
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`is that correct?
`
` Q. Yes.
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` So in the early 1990s, what were your
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`educational qualifications?
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` A. I had a Ph.D. in electrical engineering
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`with a specialization in applied digital
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`control. I had by then six years' experience in
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`industry and research. I had a master's degree
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`in electrical engineering and a bachelor's
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`degree in engineering with a specialization in
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`energy and kinetics.
`
` Q. Okay. So, I mean, you had a lot of
`
`education in electrical engineering back then,
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`clearly.
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` So are you taking the position that if
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`you were a person of ordinary skill in the art
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`in automotive window lift motors in the 1990s,
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`then the person would have to have, basically, a
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`Ph.D. in electrical engineering? Is that the
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`position you are taking?
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` A. No. I misspoke. I interpreted your
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`question as at least ordinary skill in the art.
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`I did not mean to imply that that is a
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`qualification that a Ph.D. is necessary for
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`ordinary skill in the art.
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` Q. Let me reask the question. In the
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`early 1990s, specifically April 1992 or earlier,
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`would you consider yourself to have been a
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`person of ordinary skill in the art at that
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`time? And the art is window lift motors.
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` A. I believe I had more than ordinary
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`skill in the art.
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` Q. Okay. So the answer would be no; is
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`that correct?
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` A. I guess with that phrasing of the
`
`question, yes. Yes, it would be no.
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` Q. Prior to April of 1992, did you ever
`
`work for an automotive company or a supplier to
`
`an automotive company?
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` 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?
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` A. Microprocessor controls, electronic
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`diesel fuel injection.
`
` Q. Any other projects?
`
` A. No. That was -- that was my design
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`group.
`
` Q. Were there electric motors involved
`
`with those injectors?
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` A. With the system, yes.
`
` Q. What kind of motors were those?
`
` A. Mostly stepper motors. But that was
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`actually a design decision that was often kicked
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`around. Not making it into the product were, in
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`fact, regular permanent magnet DC motors.
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` Q. Why was there a decision to go with
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`stepper motors versus the other kind?
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` A. Because stepper motors are, in essence,
`
`both a drive mechanism and a sensor. They
`
`provide positive indexing. That is a stepper
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`motor can be commanded to a specific position.
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`A DC motor can not. It's a torque-controlled
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`motor.
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` Q. So would a stepper motor be very
`
`similar in function or structure to a servo
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`motor?
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` A. Often stepper motors are used as servo
`
`motors. But -- let me leave it at that.
`
` There are other things that are used as
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`servo motors also.
`
` Q. Okay. So with stepper motors, are they
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`more accurate than the kind of motor used for a
`
`window lift mechanism in the early 1990s?
`
` A. Could you define accuracy in this
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`context?
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` Q. Accuracy in any way?
`
` A. In positioning, in precise positioning,
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`they are vastly more accurate because they move
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`a specific radial increment for every one of
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`generally four phases applied to them.
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` A DC motor can only approximately be
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`directly commanded to a particular position,
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`unless you have a separate rotary position
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`sensor that is used in a servo control loop with
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`that motor.
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` I think in the -- that's the extent of
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`which I could -- well, I just thought of
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`something.
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` Driven at a particular step rate, a
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`stepper motor can be made to turn very exactly a
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`particular rate of speed; whereas a DC motor
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`is -- could be driven only to an approximate
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`rate of speed, again, because it's a
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`torque-controlled device.
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` Q. I assume at least at that time in the
`
`early 1990s the stepper motors would have been,
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`I don't know, more expensive than the permanent
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`magnet window lift-type motors; is that correct?
`
` A. It depends on the application. A
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`stepper motor has -- is used where generally one
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`does need to positively locate a position and
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`one does not want to use an external sensor in
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`MacCarley
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`Page 27
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`addition to a DC motor in a feedback loop.
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` So we would find it in things like
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`printers, some type of automation mechanisms.
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`It would often be not any more expensive to
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`answer your question than a DC motor. It would
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`just be more appropriate.
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` A DC motor is a -- generally a higher
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`torque device, a higher power device. So if you
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`have an application in which you need to
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`generate greater torque, you would not use a
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`stepper motor, you would use a DC motor and go
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`to the extra length for positive positioning if
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`that is needed in the application.
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` Q. Okay. Now, how did you determine the
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`positional accuracy of a stepper motor versus a
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`window lift-type permanent magnet motor?
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` A. I didn't. I have never run that
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`experiment. This is just well known. In any
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`product information, in any textbook on motors,
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`you would find this.
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` Q. Okay. So what's the structure of the
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`stepper motor that allows for sensing the
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`position?
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` A. It doesn't sense the position. It can
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`www.krusereporters.com
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`312.345.1500
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`UUSI, LLC
`Exhibit 2015
`27/214
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`MacCarley
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`Page 28
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`be driven to a specific position by feeding it a
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`specific number of commutation steps.
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` Generally, these are pulses applied to
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`it. It generally has what are called quadrature
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`windings so that it can be very precisely
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`positioned rotationally with a specific number
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`of commutation pulses sent to it.
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` So that if you send it a chain of, you
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`know, 100 commutation pulses, it would take it
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`to step position 100 and there it would stop.
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` Q. Is there a way to know if it actually
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`got to that position in a typical stepper motor
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`application?
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` A. It is generally relied upon that it
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`would achieve that position. It's the basis of
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`almost all inkjet or former, you know, line feed
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`printers, impact-type printers.
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` But, no, you couldn't say for absolute
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`certainty that it didn't skip a step. That is
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`always the concern.
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` In a -- if it is an extremely high
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`reliability situation where that simply couldn't
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`be tolerated, it might not be the best choice.
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` Q. Okay. So there was no sensing of
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`www.krusereporters.com
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`UUSI, LLC
`Exhibit 2015
`28/214
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`MacCarley
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`Page 29
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`position of the motor going on in your uses for
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`the stepper motor?
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` A. No. And that's generally the advantage
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`of using a stepper motor: That you don't need a
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`position sensor.
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` Q. Now, are those differences and non-need
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`for sensing also true of servo motors?
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` A. Could you rephrase the question?
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` Q. Yeah, I would be happy to.
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` So are -- for a servo motor used in an
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`automotive vehicle in the early 1990s, would you
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`have the similar positional accuracy to that of
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`the stepper motors that you were just talking
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`about?
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` A. Did you mean to say permanent magnet
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`motor, not servo?
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` Q. No, I did not mean to say that. So I'm
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`comparing servo motors to stepper motors
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