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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________________________________
`ZHONGSHAN BROAD OCEAN
`MOTOR CO., LTD.; BROAD
`OCEAN MOTOR, LLC; AND BROAD
`OCEAN TECHNOLOGIES, LLC,
`
` Petitioners,
`
` vs. No. IPR2014-01121
` U.S. Patent No. 7,626,349
`NIDEC MOTOR CORPORATION,
`
` Patent Owner.
`_________________________________________________
`
` DEPOSITION OF DR. GARY BLANK
` Taken on behalf of the Petitioners
` January 6, 2016
`
` Saundra Tippins, CCR
`
` (The deposition began at 9:05 a.m.)
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`BOM Exhibit 1043
`BOM v. Nidec
`IPR2014-01121
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________________________________
`ZHONGSHAN BROAD OCEAN
`MOTOR CO., LTD.; BROAD
`OCEAN MOTOR, LLC; AND BROAD
`OCEAN TECHNOLOGIES, LLC,
`
` Petitioners,
`
` vs. No. IPR2014-01121
` U.S. Patent No. 7,626,349
`NIDEC MOTOR CORPORATION,
`
` Patent Owner.
`_________________________________________________
`
` DEPOSITION OF DR. GARY BLANK
` Taken on behalf of the Petitioners
` January 6, 2016
`
` Saundra Tippins, CCR
`
` (The deposition began at 9:05 a.m.)
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`BOM v. Nidec
`IPR2014-01121
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`QUESTIONS BY: PAGE NO.
`MR. MEYER 5
`MR. BROWN 90
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` INDEX OF EXHIBITS
`
`EXHIBIT DESCRIPTION PAGE
`NO.
`Exhibit 1039 Declaration 7
`Exhibit 1040 '349 Patent 10
`Exhibit 1041 '750 Patent 12
`Exhibit 1042 '895 Patent 13
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`(Whereupon exhibits were attached to the
` original and copies.)
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________________________________
`ZHONGSHAN BROAD OCEAN
`MOTOR CO., LTD.; BROAD
`OCEAN MOTOR, LLC; AND BROAD
`OCEAN TECHNOLOGIES, LLC,
`
` Petitioners,
`
` vs. No. IPR2014-01121
` U.S. Patent No. 7,626,349
`NIDEC MOTOR CORPORATION,
`
` Patent Owner.
`_________________________________________________
` DEPOSITION OF DR. GARY BLANK,
`produced, sworn, and examined on the 6th day of
`January, 2016, between the hours of nine o'clock
`in the forenoon and five o'clock in the afternoon
`of that day, at the law office of Hovey Williams,
`10801 Mastin Boulevard, Suite 1000, Overland Park,
`Kansas, before SAUNDRA TIPPINS, a Notary Public,
`and Certified Court Reporter within and for the
`States of Missouri and Kansas, in a certain cause
`now pending before the U.S. Patent and Trademark
`Office, wherein ZHONGSHAN BROAD OCEAN MOTOR CO.,
`LTD.; BROAD OCEAN MOTOR, LLC; AND BROAD OCEAN
`TECHNOLOGIES, LLC, are the Petitioners, and NIDEC
`MOTOR CORPORATION is the Patent Owner.
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` A P P E A R A N C E S
` For the Petitioners:
` MR. STEVEN F. MEYER
` LOCKE LORD
` 3 World Financial Center
` New York, New York 10281
` (212)415-8535
` smeyer@lockelord.com
`
` For the Patent Owner:
` MR. SCOTT R. BROWN
` HOVEY WILLIAMS
` 10801 Mastin Boulevard, Suite 1000
` Overland Park, Kansas 66210
` (913)647-9050
` sbrown@hoveywilliams.com
`
` The Court Reporter:
` Ms. Saundra Tippins
` Also Present (by phone):
` Mr. Daniel Nguyen
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` IT IS HEREBY STIPULATED AND AGREED,
`by and between counsel for Petitioners and counsel
`for Patent Owner that the deposition of DR. GARY
`BLANK may be taken in shorthand by Saundra Tippins,
`a notary public and shorthand reporter, and
`afterwards transcribed into typewriting; and the
`signature of the witness is expressly reserved.
` * * * * *
` DR. GARY BLANK,
` of lawful age, produced, sworn and examined on
` behalf of Petitioners, deposes and says:
` EXAMINATION
` QUESTIONS BY MR. MEYER:
` Q Can you please state your name and
` address for the record.
` A Gary Blank, 8N173 Ickenham Lane, Plato
` Center, Illinois, 64124.
` Q Is there any reason why you cannot
` provide complete and honest testimony today, such
` as an illness or the use of medication?
` A There is no reason.
` Q What is your billing rate for the time
` you spent on this matter?
` A It varies, 225 to 250.
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` Q And why is there a variation?
` A The research is 225, and deposition is
` 250.
` Q Okay. In order to help your client
` out, I'll try to make this deposition as fast as
` possible.
` A Take your time.
` Q Are you aware that in July of 2014,
` Broad Ocean filed three separate IPR petitions
` against three patents owned by Nidec?
` A Yes, I do.
` Q When did you first become aware of
` that?
` A Around July of 2015.
` Q When were you first retained by Nidec?
` A October 2014.
` Q To do what?
` A To do research on the patent, patent
` number '895.
` Q Were you asked to do anything on the
` '349 patent at that time?
` A Very little.
` Q What were you asked to do?
` A To review it.
` Q Anything else?
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` A Not at that time.
` Q Who asked you to do that?
` A Hovey Williams, Scott Brown.
` Q Have you ever spoken to any Nidec
` employees?
` A No.
` Q What were you told about the '349
` patent, if anything, before you started your
` review?
` A I was asked to look at it from an
` engineering point of view to understand what a
` patent was about and to consider what possibly
` could be some argument made against it.
` Q And what arguments did you anticipate
` that could be made against it?
` A At the time I did not anticipate any
` arguments.
` Q Were you aware of the Hideji patent at
` the time you did your first analysis of the '349
` patent?
` A Yes.
` Q Okay. I'd like to have marked as
` Exhibit 1039 the declaration by Gary Blank in
` IPR2014-01122.
` (The reporter marked Exhibit No.
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` 1039.)
` Q (By Mr. Meyer) Okay, can you please
` turn to page 22 of this document.
` A (Witness complies.)
` Q Is that your signature?
` A Yes, it is.
` Q And did you place the date of May 8th,
` 2015, next to your signature?
` A Yes, I did.
` Q Did you prepare all of the statements
` appearing in this declaration?
` A Yes.
` Q Did Nidec's attorneys review this
` declaration before you signed it?
` A Yes.
` Q Okay. So both you and Nidec's
` attorneys were aware of U.S. patent number
` 7,208,895 as of May 8th, 2015?
` A Yes.
` Q Okay, can you please turn to paragraph
` 24 on pages 14 to 15 of your declaration. It's
` paragraph 24, page 14, and paragraph 24 bridges
` over to page 15.
` A I see it.
` Q Okay. This paragraph refers to Kusaka
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` and reproduces Figure 1 of Kusaka, correct?
` A Yes.
` Q So you and Nidec's attorneys knew
` about Kusaka as of May 8th, 2015, correct?
` A Correct.
` Q Okay. Can you please turn to
` paragraph 29 on pages 18 to 19 of your
` declaration.
` A (Witness complies.)
` Q And this paragraph refers to Walters
` and reproduces Figure 3 of Walters, correct?
` A Correct.
` Q So you and Nidec's attorneys knew
` about Walters as of May 8th, 2015, correct?
` A Yes.
` (Off the record.)
` Q (By Mr. Meyer) I'd like to place
` before the witness what has been previously
` marked as Exhibit 1001. It's the '349 patent.
` How much time have you spent reviewing the
` '349 patent in total?
` A Would you want me to answer in terms
` of hours or days or weeks or?
` Q How about hours?
` A Hours. Possibly 40 hours.
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` Q And I'd like to direct your attention
` to column four, lines 23 through 29.
` A (Witness complies.)
` Q It says, additional details regarding
` sensorless control techniques and sinewave
` commutation using vector control, in
` parentheticals, as well as speed, torque and
` constant airflow control schemes, comma, discussed
` below, close parens, are disclosed in U.S. patent
` numbers 6,326 750; next one, 6,756,757; next one,
` 7,208,895 and 7,342,379, the entire disclosures of
` which are incorporated herein by reference.
` Have you reviewed those patents?
` A I reviewed the '895 and the '379.
` Q Okay. I'd like to just as a
` housekeeping measure mark all of them.
` (The reporter marked Exhibit No.
` 1040.)
` Q (By Mr. Meyer) Okay, I'd like to have
` marked as Exhibit 1040 U.S. patent number
` 6,326,750. Is this one of the ones that you did
` review?
` A Yes.
` Q Okay. And how much time did you spend
` reviewing this one?
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` A Ten to 15 hours.
` Q And do you understand it?
` A Yes, I do.
` Q And what is your understanding of what
` is disclosed in this patent?
` A In the patent it describes a method of
` controlling torque in a rotating machine.
` Q Does it use vector control?
` A Yes.
` Q And what are you looking at that
` prompted you to say yes?
` A Figure 26.
` Q What in Figure 26 indicates to you
` that vector control is being used?
` A The fact that some of the boxes show
` multiple inputs, which are separate quantities and
` are being combined in some fashion which is not
` clear by looking at the diagram. We'd need to go
` look closely at what's inside each box.
` But it's possible that these boxes may be
` doing some sort of vector control, but it's not
` obvious from the diagram.
` Q What more would you need to know to
` conclusively determine whether or not vector
` control is being performed?
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` A We would need to do a definition of
` the variables that are inputs to the boxes, as
` well as the mathematical operations that are being
` performed within the boxes.
` Q I'd like to have marked as
` Exhibit 1041 U.S. patent number 6,756,757.
` (The reporter marked Exhibit No.
` 1041.)
` Q (By Mr. Meyer) Is this one of the
` ones that you reviewed?
` A No.
` Q And why didn't you review this one if
` it was incorporated by reference into the '349
` patent specification?
` A Repeat that again, please.
` MR. MEYER: Can you repeat my
` question, please.
` (The reporter read back the
` question: And why didn't you review this
` one if it was incorporated by reference
` into the '349 patent specification?)
` A I do not remember.
` Q (By Mr. Meyer) Were you told not to
` review this one?
` A No, I was not told that.
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` Q So as you stand here, you have no idea
` what is disclosed in this patent?
` A I don't know.
` Q I'd like to have marked as
` Exhibit 1042, U.S. patent number 7,208,895.
` (The reporter marked Exhibit No.
` 1042.)
` Q (By Mr. Meyer) And this is one that
` you have reviewed, correct?
` A Yes.
` Q And how much time did you spend
` reviewing this patent?
` A Several hours.
` Q And what is your understanding of this
` patent?
` A It describes systems and techniques
` for controlling permanent magnet motors.
` Q Does it use vector control?
` A Yes, it does.
` Q And how do you know that?
` A By the diagram on the very first page.
` Q And what in that diagram leads you to
` conclude that it does perform vector control?
` A In the center of the diagram, there's
` a box that says vectorize, and the inputs, in my
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` understanding, is that the inputs to the
` vectorized box are being combined into a vector.
` Q Is it necessary for a controller to
` have a vectorized box like box 212 to perform
` vector control?
` A Yes.
` Q So if a block diagram of a controller
` does not have a vectorized box such as vectorized
` box 212, would that lead you to believe that it is
` not possible at all for the motor controller to
` perform vector control?
` A The only way to determine that is to
` know what's inside a box.
` Q I'd like to place before the witness
` what has been previously marked as Exhibit 1010 in
` IPR2015-00762, which has been combined or joined
` with the subject IPR.
` Did you review this one?
` A Yes.
` Q And how much time did you spend
` reviewing the '379 patent?
` A Five to 10 hours.
` Q And what is your understanding of what
` this patent discloses?
` A This patent discloses methods and
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`Page 15
` systems for controlling a rotating machine, for
` sensorless control of a rotating machine.
` Q And what is sensorless control?
` A Sensorless control is the lack of
` sensors and not using sensors for control
` purposes.
` Q Okay. Does this patent disclose the
` use of vector control?
` A It has a box that says vectorize.
` Q So therefore you conclude that it
` performs --
` A Yes.
` Q -- that it performs vector control?
` A Yes.
` Q I'd like to refer your attention back
` to the '349 patent.
` A (Witness complies.)
` Q Do you have an understanding of what
` the '349 patent is disclosing?
` A Yes, I do.
` Q What is your understanding?
` A It shows the description of an HVAC
` heating ventilating and/or air conditioning
` system, specifically one that exhibits low noise.
` Q Do you have any patents in your name?
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` A Not at present.
` Q Have you ever filed a patent
` application?
` A Yes.
` Q How many?
` A One.
` Q When did you do that?
` A In 1985.
` Q And so it did not issue as a patent?
` A Yes, it was, but it was sold
` subsequently.
` Q Okay. Okay, I understand.
` A It belongs to the university. It
` belongs to the university.
` Q It belongs to the university?
` A Yes.
` Q Were you involved in the process of
` submitting the application or first -- let me just
` step back.
` What was your involvement in the process
` of obtaining that patent?
` A As one of the two inventors -- the
` other inventor was one of my graduate students --
` the university provided the individual who knew
` what to do, and we provided technical information,
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` and they took care of the rest.
` Q Okay. Did you have any interaction --
` first, did you have any involvement in the
` preparation of the patent application? Did you
` review it before it was filed with the patent
` office?
` A Yes, yes, I did.
` Q Then when the patent office issued its
` first response, did you review that?
` A No.
` Q No. So that was the end of your
` involvement, reviewing the application after it
` was prepared but before it was filed with the
` patent office?
` A Before it was submitted, yes, I did.
` The result was it was accepted.
` Q Okay. I would like to place before
` you what has been previously marked as
` Exhibit 1002, and I'll represent to you that this
` is what is known as the prosecution history of the
` '349 patent. It is all of the documents back and
` forth between Nidec's predecessor and the patent
` office regarding the application that ultimately
` issued as the '349 patent. Okay?
` Now, I'd like to direct your attention to
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`Page 18
` exhibit pages 41 through 44. The exhibit pages
` are the ones in the lower right-hand corner.
` A (Witness complies.)
` Q Okay. Have you been provided with a
` copy of the prosecution history prior to today?
` A What is the prosecution history?
` Q The prosecution history is a summary
` of the correspondence between the patentee and the
` patent office dealing with the patent office's
` consideration of the patent application and the
` ongoing back and forth that makes up the decision
` whether to issue it as a patent or not.
` Let me just, have you been provided with
` this document before?
` A No.
` Q Okay. I'd like to direct your
` attention to pages 41 through 44, and I will
` represent to you that these are the claims as they
` were initially presented to the patent office by
` the patent applicants. Okay. And I'd like to
` direct your attention to claim one on page 41.
` The last clause in claim one reads,
` wherein the motor controller is configured for
` performing sinewave commutation in response to
` one or more control signals received from the
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` system controller to produce continuous phase
` currents in the permanent magnet motor for
` driving the air moving component.
` Do you see that?
` A Yes.
` Q My next question is, in accordance
` with that clause that I just read as stated on
` page 41, what is being done in response to the one
` or more control signals received from the system
` controlling?
` A The motor controller is provided with
` one or more control signals, and it uses the
` control signals to perform sinewave commutation.
` Q Thank you. And there's no mention of
` developing Q and d access currents in this
` earliest version of claim one, correct?
` A I don't see it in this page.
` Q Okay. Now, is it true that you need a
` control signal from the system controller to start
` the performance of sinewave commutation?
` A That's optional.
` Q Why is it optional?
` A Sinewave commutation can be started in
` several different ways.
` Q What are those different ways other
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` than the receipt of a control signal from a system
` controller?
` A Well, that's required, but what you
` did after that point would vary from one
` application to the other.
` Q Okay.
` A But in general, you would need to have
` all the inputs available, and then you would
` combine them to perform, to develop control
` signals.
` Q Okay. And I'd like to direct your
` attention to claim 16 on page 43. It has a
` similarly phrased clause at the end of it.
` Do you see that?
` A Yes.
` Q And I have the same question with
` respect to claim 16 as I did with claim one. What
` is being done in response to the one or more
` control signals received from the system
` controller?
` A What it says here. It says motor
` controller is provided -- is configured to do the
` sinewave commutation after you provide the input
` signals from the controller.
` Q And the same is true for claim 19,
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`
` correct?
` A Yes, correct.
` Q Okay. Now I'd like to direct your
` attention back to the '349 patent and column
` three, lines 16 to 17.
` A (Witness complies.)
` Q It reads, it reads, Figure 8 is a
` block diagram of a sensorless vector control
` scheme performed by the controller shown in
` Figure 7.
` Do you see that?
` A Yes.
` Q Are there schemes other than a vector
` control scheme that a motor controller can perform
` in order to control the operation of a motor?
` A Yes.
` Q What are those alternative schemes?
` A There are many. There are many other
` schemes available for controlling the motor.
` Q Okay. Is vector control the most
` frequently used control scheme in motors within
` the United States?
` A Within the United States, would you
` care to separate that?
` Q Okay. Let me step back.
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`Page 22
` In the HVAC field, a motor controller used
` to control a motor that turns a blower in an HVAC
` system, are there control schemes other than a
` vector control scheme that a motor controller can
` perform in order to control the operation of that
` motor in an HVAC system?
` A There are methods available; however,
` it's difficult to generalize. What I can provide
` is the information that in the HVAC operation, it
` is very seldom, if ever, to use sensorless
` vectorizing. However, if you look at -- that's
` why I asked about the United States.
` If you look at the military applications
` in aerospace, you'll find it's much more common.
` So the use of this in HVAC is rather unique.
` Q Okay. How about with sensors? Not to
` limit it to sensorless, but if you have a sensor,
` is it widely used, vector control in an HVAC
` system if it isn't sensorless?
` A It is unusual to use sensorless
` control in an HVAC system.
` Q Why is it unusual to use sensorless
` vector control?
` A It's usually the technology or the
` cost of technology that would motivate or
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`Page 23
` demotivate someone from using this technology in
` HVAC or any other area.
` Q Okay. Now, as I take it, there is
` sensorless and vector control, but there's also
` vector control using sensors, correct?
` A Correct.
` Q Now, with respect to vector control
` using sensors, is that type of vector control,
` using sensors, widely used in the HVAC systems?
` A Vector -- would you repeat that again,
` please?
` MR. MEYER: Can you read my
` question, please.
` (The reporter read back the
` question: Now, with respect to vector
` control using sensors, is that type of
` vector control, using sensors, widely
` used in the HVAC systems?)
` A No.
` Q (By Mr. Meyer) What type of control
` scheme is used in -- what type of control schemes
` are used by motor controllers in HVAC systems?
` A Many users use systems that are --
` require sensors, and many sensors, to sense many
` different parameters in order to get good control
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`Page 24
` for an HVAC system. If you can do it without
` using sensors, that's a tremendous advancement.
` Q Please turn to Figure 8 of the '349
` patent.
` A (Witness complies.)
` Q Do you agree that Figure 8 depicts a
` block diagram of a sensorless vector control
` scheme?
` A Yes.
` Q Okay. Is there some feature depicted
` in Figure 8 that you can point to and say because
` that feature is depicted in Figure 8, I know for
` certain that this controller performs vector
` control?
` A There are two boxes that show IQr and
` Idr current controllers, and the inputs to those
` controllers develop two vector voltages, VQr and
` Vdr.
` Q So the fact that there is VQr and Vdr
` is what leads you to conclude that there is vector
` control?
` A Yes.
` Q Looking at Figure 8, can you tell me
` what is the source of power for the motor drive
` box that's shown in Figure 8?
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`Page 25
` A It starts with the demand in the
` bottom left-hand corner.
` Q Uh-huh. Let me just, before -- can I
` interrupt your answer? Okay.
` You pointed to the demand box in the lower
` left-hand corner. Does that indicate the receipt
` of a demand signal from a system controller?
` A It's a demand that could be from a
` system controller.
` Q Okay. Do you know what kind of demand
` that is?
` A No.
` Q Is it a speed demand? I see that the
` output from the demand box goes to a box called
` input filter.
` A Yes.
` Q And then the output from the input
` filter is labeled filtered speed demand?
` A Yes.
` Q Do you see that?
` A Uh-huh.
` Q Does that lead you to believe that the
` demand shown in the box in the lower right-hand
` corner is a speed demand?
` A Yes, it is a speed demand.
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` Q Okay. Now, are there controllers
` other than a system controller that can send that
` speed demand to the demand box?
` A Would you repeat that, please?
` MR. MEYER: Can you repeat my
` question, please.
` (The reporter read back the
` question: Now, are there controllers
` other than a system controller that can
` send that speed demand to the demand
` box?)
` A Yes.
` Q (By Mr. Meyer) What type of
` controllers?
` A A large number of controllers.
` Q Okay.
` A Quite a few, quite a lot, can do it.
` Q Okay. Now, do you see the box labeled
` speed loop controller in the upper left-hand
` corner?
` A Yes.
` Q Is that part of the motor controller?
` A Yes.
` Q Okay. Now, does the power -- is the
` power to drive the motor ultimately coming from
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`Page 27
` the DC supply oval that's depicted in the left
` center of Figure 8?
` A Yes.
` Q Figure 8 depicts that the DC power is
` supplied by a link marked DC link to the bottom
` side of a box labeled PWM engine. Is that
` correct?
` A Yes.
` Q Do you know what PWM stands for?
` A PWM stands for pulse with modulation.
` Q What is pulse with modulation?
` A Pulse with modulation in a general
` sense is the process of converting a DC signal
` into alternating current voltages and controlling
` the magnitude of those voltages.
` Q And do you control the magnitude of
` those voltages by varying the width of the pulse?
` A Yes.
` Q Okay. And how is the width of the
` pulse modulated during pulse with modulation?
` A There are many methods for doing that.
` For this particular diagram --
` Q You anticipated my next question.
` A Okay.
` Q Thank you.
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`Page 28
` A It appears to be coming from the frame
` of reference transform the Qdr to alpha-beta.
` Q Okay. What is alpha-beta?
` A Alpha-beta are Greek letters, but they
` are often used to indicate a reference frame.
` Q Okay, so if you have a voltage in the
` alpha-beta, you would have V sub alpha and V sub
` beta?
` A Yes.
` Q And for current in alpha and beta, you
` would have I sub alpha and I sub beta?
` A Yes.
` Q Okay. And the alpha-beta voltage
` demand is used by the PWM engine depicted in
` Figure 8 to modulate the width of the power from
` the DC supply, correct?
` A Correct.
` Q And as you mentioned, this alpha-beta
` voltage demand signal is output by the frame of
` reference transform Qdr to alpha-beta box,
` correct?
` A Yes.
` Q And the alpha-beta voltage demand
` signal is generated by the frame of reference
` transform Qdr to alpha-beta box based on the VQr
`
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`Page 29
`
` and Vdr signals, correct?
` A Not entirely.
` Q Okay. Can you explain how it is
` correct and how is it not entirely correct?
` A It needs a third input of the
` estimated electrical angle --
` Q Okay.
` A -- to make the transformation.
` Q Okay. Is there any difference between
` the Vdr, let's see, the Vdr voltages, VQr, Vdr
` signals, and the alpha-beta voltage demand?
` A Would you repeat that, please?
` Q Okay. Let me rephrase it this time.
` The title of the box, frame of reference
` transform Qdr to alpha-beta, that box, indicates
` that there is a transformation going on from a
` Qdr frame of reference to an alpha-beta frame of
` reference, correct?
` A Correct.
` Q How is the alpha-beta frame of
` reference different from the Qdr frame of
` reference?
` A Usually the Q and d indicate a frame
` in which we're talking about a reference frame in
` which we have a direct and a quadrature axis, and
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`Page 30
` if we move to an alpha-beta, we're talking about a
` different coordinate system.
` And so the two are connected through
` mathematical transformation from the Q and d to
` the alpha-beta.
` Q Okay. We have been talking about
` mostly two different frames of reference, the
` quadrature, the Q and d frame of reference, which
` is as explained to me, I'm not an electrical
` engineer, as being you're on the rotor and you're
` rotating. Correct? It's a rotating frame of
` reference?
` A Yes, it's a rotating frame of
` reference.
` Q Is the alpha-beta frame of reference a
` rotating frame of reference?
` A No.
` Q It's stationary?
` A Yes.
` Q Now I'd like to discuss the generation
` of the VQr signal as shown in Figure 8. Now, the
` VQr signal is output by the IQr current
` controller, correct?
` A Yes.
` Q And the IQdr actual signal and the
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