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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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`084—03710
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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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`before CERYL L. SAN u]«'.CK ,
`UUSI, LLC
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`Reporter for she Stare o" "
`EXhHflt2015
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`
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`LaSalle Svreev, Chicago,
`September 26, 2014, at the
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`
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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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`
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`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
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`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
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`
`
`MacCarley
`
`Page 2
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`APPEARANCES:
`
` KIRKLAND & ELLIS LLP, by
` MR. CRAIG D. LEAVELL
` MS. ALYSE WU
` 300 North LaSalle Street
` Chicago, Illinois 60654
` (312) 862-2105
` craig.leavell@kirkland.com
` alyse.wu@kirkland.com
`
` Representing the Petitioner;
`
` HARNESS, DICKEY & PIERCE, P.L.C., by
` MR. MONTE L. FALCOFF
` MR. MICHAEL R. NYE,
` 5445 Corporate Drive
` Suite 200
` Troy, Michigan 48098
` (248) 641-1600
` mfalcoff@hdp.com
` mnye@hdp.com
`
` (Telephonically) Representing the
` Patent Owner.
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`312.345.1500
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`Exhibit 2015
`2/214
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`
`
`MacCarley
`
` INDEX
`
`WITNESS EXAMINATION
`
`Page 3
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` C. ART MacCARLEY
`
` EXAMINATION BY MR. FALCOFF 4
` Examination BY MR. LEAVELL 177
` Examination BY MR. FALCOFF (FURTHER) 204
`
` EXHIBITS
`
`NUMBER MARKED FOR ID
`
`MacCarley Deposition Exhibit
`
`Exhibit 1 Declaration for '802 69
` Patent
`Exhibit 2 Declaration for '612 69
` Patent
`Exhibit 3 '802 Patent 69
`Exhibit 4 '612 Patent 69
`Exhibit 5 Kinzl '596 Patent 105
`Exhibit 6 Itoh '333 Patent 120
`Exhibit 7 Zuckerman '000 Patent 134
`Exhibit 8 Book Excerpt 185
`Exhibit 9 DeSilva Complete Book 207
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` (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
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`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
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`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
`
`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?
`
` A. No.
`
` 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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`Exhibit 2015
`5/214
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`MacCarley
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`Page 6
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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
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`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:
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` Q. And do you agree with that,
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`Dr. MacCarley?
`
` A. Yes.
`
` Q. Great. Thank you.
`
`www.krusereporters.com
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`312.345.1500
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`UUSI, LLC
`Exhibit 2015
`6/214
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`
`
`MacCarley
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` 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.
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` 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?
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` A. I don't recall the exact name.
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` Q. Would that possibly have been
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`Combustion Controls?
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` A. Yes, it was. They went by three other
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`names, I believe.
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` Q. I see. Okay.
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` And did you submit an expert
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`declaration or report in that lawsuit?
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` 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.
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` Q. Okay. Did you act as an expert in any
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`other patent lawsuit?
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` A. No.
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` 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?
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` A. Yes.
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` 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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`UUSI, LLC
`Exhibit 2015
`8/214
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`
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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
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`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
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`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
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`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.
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` 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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`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.
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`They should be at the top of the exhibits you
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`may be looking at today.
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` I may interchangeably refer to the
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`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
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`the documents that you asked us to have
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`available for you. She has not yet marked them.
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`We didn't know what order you wanted to
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`introduce them.
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` So if you want to use them with the
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`www.krusereporters.com
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`Exhibit 2015
`10/214
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`MacCarley
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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
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`attached to the expert report are your
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`petitions.
`
` Unless you want me to, Craig, or unless
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`the witness actually marks on them, most cases,
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`if not all, I'm not sure we even need to truly
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`enter them as a deposition exhibit unless you
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`want to.
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` MR. LEAVELL: You know, I don't -- it looks
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`like the versions we have got here with the
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`court reporter don't have the exhibit stamp on
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`them, so why don't we have her mark them and put
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`them in just for housekeeping matters.
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` MR. FALCOFF: Fair enough.
`
` MR. LEAVELL: The other thing I will mention
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`is I don't know if you guys noticed this. I
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`just noticed this yesterday. Some of the copies
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`of the patents that were filed apparently are
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`missing some of the lines. So we are thinking
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`www.krusereporters.com
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`UUSI, LLC
`Exhibit 2015
`11/214
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`
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`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.
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` 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.
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` MR. FALCOFF: Yeah, we have seen that.
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` MR. LEAVELL: So we have got the right copies
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`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.
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` So it may be easier for everybody if we
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`mark them as dep exhibits today, then they will
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`be in the record either way. But we will sort
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`that out and work with you to get that
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`straightened out.
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` MR. FALCOFF: Thank you. I appreciate you
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`letting us know.
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`BY MR. FALCOFF:
`
` Q. Okay. If we are ready, we will
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`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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`www.krusereporters.com
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`Exhibit 2015
`12/214
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`MacCarley
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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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`MacCarley
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` A. Oh, physical, no, I did not.
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` Q. Okay. In preparation for your
`
`deposition today, did you talk to any employees
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`of Brose? So by that I'm excluding the Kirkland
`
`& 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
`
`you converse with any Brose employees other than
`
`the Kirkland attorneys?
`
` A. No.
`
` Q. Okay. Who is your current employer?
`
` A. I don't have a personal attorney on
`
`retainer.
`
` Q. Let me reask the question.
`
` A. I apologize. I misheard. You said
`
`"employer".
`
` Q. Employer. Yes.
`
` A. California State University System.
`
`I'm a professor at Cal Poly, San Luis Obispo,
`
`which is primarily an engineering university.
`
` Q. Is that different than Cal Tech?
`
` A. Yes.
`
` Q. Okay. In your current position, what's
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`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
`
`computer engineering. I am currently the
`
`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.
`
` Q. Okay. Now, the laboratory you
`
`mentioned, what projects -- well, first off, how
`
`long has that been in existence that you have
`
`been a part of?
`
` A. Since early '90s.
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` Q. Okay. Can you put a more definite year
`
`on that when you first started working with that
`
`group?
`
` A. Not at this time. I would go back
`
`through my records to pin it down.
`
` Q. All right. Have you been involved with
`
`it since it was created?
`
` A. Yes.
`
` Q. Okay. And what projects are currently
`
`being worked on in that laboratory?
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` 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
`
`laboratory. The question was current; is that
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`correct?
`
` Q. Yes. This was correct.
`
` So when was the last time you did have
`
`a project with that laboratory or through that
`
`laboratory?
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` A. I believe it terminated the end of the
`
`summer before this last one. It was for the
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`California Department of Transportation
`
`involving advanced automated sensor and detector
`
`validation using an adaptive algorithm and
`
`specialized hardware.
`
` Q. Is that for traffic control management?
`
` A. It's for evaluation of technologies
`
`that are used for traffic control management.
`
` Q. I see. Okay. Anything to deal with --
`
`that deals directly with DC electric motors in
`
`cars?
`
` A. No.
`
` Q. Has that laboratory since you first
`
`started working with them in 1990s ever done any
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`projects there dealing with automotive vehicle
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`Page 17
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`DC electric motors?
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` A. Yes.
`
` Q. Okay. What was that?
`
` A. In the late '90s, I did work funded by
`
`the California Energy Commission, Pacific Gas
`
`and Electric Company, some university support
`
`also in which we were developing some advanced
`
`technologies related to electric vehicles.
`
` Q. So those would be traction drive
`
`motors?
`
` A. We weren't -- that project wasn't
`
`directly in motor development. I also -- I also
`
`did have my own company for about ten years in
`
`which we did do specific drive -- high-powered
`
`drive electronics for advanced electric vehicle
`
`motors.
`
` But back to your original question,
`
`that project was associated with automated
`
`battery exchange for electric vehicles, which
`
`involves an automated mechanism with both
`
`motors.
`
` Q. I understand. And did you -- are there
`
`any other projects through the laboratory there
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`at the university where you worked on automotive
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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.
`
`So I do go fairly -- I go to a level of
`
`application depth associated with the various
`
`types of motors that can be used for traction.
`
` Q. Okay. That's separate from the
`
`laboratory work, right?
`
` A. Yes. I mean, I'm a professor. I
`
`primarily teach.
`
` Q. Okay. So, again, going back to the
`
`question for the laboratory, have you ever
`
`worked on any projects there where the work
`
`pertained to automotive vehicle DC electric
`
`motors through the laboratory?
`
` A. I can't recall any of the work.
`
` Q. Okay. Now, through your private
`
`company that you mentioned, what was the time
`
`frame that you started that up?
`
` A. 1997.
`
` Q. Okay. And what -- does it still exist?
`
` A. It exists as a name. But it's just --
`
`it's just me now. I closed my bricks and mortar
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`location when I most recently -- it was in 2008
`
`when I was appointed the department chair of the
`
`electrical engineering department.
`
` Q. Okay. So with your private company,
`
`did you ever do any work on DC electric motors
`
`in automotive vehicles?
`
` A. Yes. We, in fact, developed an
`
`under -- with some funding from the U.S.
`
`Department of Energy and an external entity that
`
`had developed a novel rotating machine, they
`
`came to us to produce for them the required
`
`specialized high-powered drive electronics that
`
`would drive their machine.
`
` Q. What kind of machine?
`
` A. It's a -- it was a configuration of
`
`a -- it's in the class of electronically
`
`commutated DC motors. But it had a very novel
`
`magnetic flux path that allowed the rotor
`
`magnetic field to be developed by a toroidal
`
`selenoid to the end case, avoiding the need for
`
`brushes, but effectively coupling in the fixed
`
`magnetic field to the rotor.
`
` Q. This is used in automotive vehicles?
`
` A. It never actually went into -- that
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`particular company that came to us to do this
`
`for them never got it into production.
`
` I might parenthetically add, though,
`
`that their concept did find its way into
`
`multiple other products, especially automotive
`
`alternators.
`
` Q. Okay. So was this project that you
`
`were working on with your company for the
`
`automotive use, was that primarily for or
`
`intended for use in alternators?
`
` A. No.
`
` Q. What were the other uses of this very
`
`specialized motor?
`
` A. The specific objective was to -- was to
`
`deploy the rotating machine and drive
`
`electronics as a very high-powered density
`
`electric motor for electric vehicles.
`
` Q. For the actual traction motor in
`
`electric vehicles?
`
` A. That's correct.
`
` Q. Now, the work that you have done -- I
`
`think you have done other, what, traction motor
`
`work for automotive vehicles; is that correct?
`
` A. It's not my specialization. So I can
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`say I have had a hand in quite a few
`
`student-based projects. I have worked with
`
`colleagues who have worked on this type of
`
`thing. But I wouldn't go so far as to say
`
`I've -- I could take primary responsibility for
`
`something like that.
`
` Q. Okay. Would you consider yourself to
`
`be an expert in the field of automotive DC
`
`electric motors?
`
` A. I'm going to subdivide your question
`
`because there are two broad classes of DC
`
`electric motors. I mean, the type relevant in
`
`this case is a permanent magnet motor, which
`
`is -- it's -- they are ubiquitous in window
`
`drive mechanisms.
`
` It's such a well-established technology
`
`that it hardly takes much expertise to say you
`
`know everything about them. I certainly meet
`
`that qualification.
`
` As far as the whole broad range of
`
`advanced DC electric drives, novel motor
`
`configurations, I would not consider myself an
`
`expert. That's a fairly specialized field.
`
` Q. Let's break it down then. The
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`permanent -- let me rephrase the question.
`
` For the type of electric motor that's
`
`used in automotive vehicle window lift
`
`mechanisms in the 1990s, specifically the early
`
`1990s, would you consider yourself currently an
`
`expert in that area?
`
` A. Yes.
`
` Q. Okay. Would you consider yourself an
`
`expert in that area in the early 1990s?
`
` A. Yes.
`
` Q. Now, in the early 1990s, would you have
`
`considered yourself to be a person of ordinary
`
`skill in the art in the type of electric motor
`
`that's used in automotive window lift
`
`mechanisms?
`
` A. Yes. You said window lift mechanisms;
`
`is that correct?
`
` Q. Yes.
`
` So in the early 1990s, what were your
`
`educational qualifications?
`
` A. I had a Ph.D. in electrical engineering
`
`with a specialization in applied digital
`
`control. I had by then six years' experience in
`
`industry and research. I had a master's degree
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`in electrical engineering and a bachelor's
`
`degree in engineering with a specialization in
`
`energy and kinetics.
`
` Q. Okay. So, I mean, you had a lot of
`
`education in electrical engineering back then,
`
`clearly.
`
` So are you taking the position that if
`
`you were a person of ordinary skill in the art
`
`in automotive window lift motors in the 1990s,
`
`then the person would have to have, basically, a
`
`Ph.D. in electrical engineering? Is that the
`
`position you are taking?
`
` A. No. I misspoke. I interpreted your
`
`question as at least ordinary skill in the art.
`
`I did not mean to imply that that is a
`
`qualification that a Ph.D. is necessary for
`
`ordinary skill in the art.
`
` Q. Let me reask the question. In the
`
`early 1990s, specifically April 1992 or earlier,
`
`would you consider yourself to have been a
`
`person of ordinary skill in the art at that
`
`time? And the art is window lift motors.
`
` A. I believe I had more than ordinary
`
`skill in the art.
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` Q. Okay. So the answer would be no; is
`
`that correct?
`
` A. I guess with that phrasing of the
`
`question, yes. Yes, it would be no.
`
` Q. Prior to April of 1992, did you ever
`
`work for an automotive company or a supplier to
`
`an automotive company?
`
` A. Yes.
`
` Q. Okay. Who would that have been?
`
` A. American Bosch Division of United
`
`Technologies.
`
` Q. What projects did you work on them for?
`
` A. Microprocessor controls, electronic
`
`diesel fuel injection.
`
` Q. Any other projects?
`
` A. No. That was -- that was my design
`
`group.
`
` Q. Were there electric motors involved
`
`with those injectors?
`
` A. With the system, yes.
`
` Q. What kind of motors were those?
`
` A. Mostly stepper motors. But that was
`
`actually a design decision that was often kicked
`
`around. Not making it into the product were, in
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`fact, regular permanent magnet DC motors.
`
` Q. Why was there a decision to go with
`
`stepper motors versus the other kind?
`
` A. Because stepper motors are, in essence,
`
`both a drive mechanism and a sensor. They
`
`provide positive indexing. That is a stepper
`
`motor can be commanded to a specific position.
`
`A DC motor can not. It's a torque-controlled
`
`motor.
`
` Q. So would a stepper motor be very
`
`similar in function or structure to a servo
`
`motor?
`
` A. Often stepper motors are used as servo
`
`motors. But -- let me leave it at that.
`
` There are other things that are used as
`
`servo motors also.
`
` Q. Okay. So with stepper motors, are they
`
`more accurate than the kind of motor used for a
`
`window lift mechanism in the early 1990s?
`
` A. Could you define accuracy in this
`
`context?
`
` Q. Accuracy in any way?
`
` A. In positioning, in precise positioning,
`
`they are vastly more accurate because they move
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`a specific radial increment for every one of
`
`generally four phases applied to them.
`
` A DC motor can only approximately be
`
`directly commanded to a particular position,
`
`unless you have a separate rotary position
`
`sensor that is used in a servo control loop with
`
`that motor.
`
` I think in the -- that's the extent of
`
`which I could -- well, I just thought of
`
`something.
`
` Driven at a particular step rate, a
`
`stepper motor can be made to turn very exactly a
`
`particular rate of speed; whereas a DC motor
`
`is -- could be driven only to an approximate
`
`rate of speed, again, because it's a
`
`torque-controlled device.
`
` Q. I assume at least at that time in the
`
`early 1990s the stepper motors would have been,
`
`I don't know, more expensive than the permanent
`
`magnet window lift-type motors; is that correct?
`
` A. It depends on the application. A
`
`stepper motor has -- is used where generally one
`
`does need to positively locate a position and
`
`one does not want to use an external sensor in
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`addition to a DC motor in a feedback loop.
`
` So we would find it in things like
`
`printers, some type of automation mechanisms.
`
`It would often be not any more expensive to
`
`answer your question than a DC motor. It would
`
`just be more appropriate.
`
` A DC motor is a -- generally a higher
`
`torque device, a higher power device. So if you
`
`have an application in which you need to
`
`generate greater torque, you would not use a
`
`stepper motor, you would use a DC motor and go
`
`to the extra length for positive positioning if
`
`that is needed in the application.
`
` Q. Okay. Now, how did you determine the
`
`positional accuracy of a stepper motor versus a
`
`window lift-type permanent magnet motor?
`
` A. I didn't. I have never run that
`
`experiment. This is just well known. In any
`
`product information, in any textbook on motors,
`
`you would find this.
`
` Q. Okay. So what's the structure of the
`
`stepper motor that allows for sensing the
`
`position?
`
` A. It doesn't sense the position. It can
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`be driven to a specific position by feeding it a
`
`specific number of commutation steps.
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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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`312.345.1500
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`UUSI, LLC
`Exhibit 2015
`28/214
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`MacCarley
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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