Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT AND APPEAL BOARD
`
`ZHONGSHAN BROAD OCEAN )
`MOTOR CO., LTD, BROAD )
`OCEAN MOTOR LLC, AND BROAD)
`OCEAN TECHNOLOGY, LLC. )
` Petitioners, )
` )
`vs. ) CASE NO. IPR2014-01121
` ) PATENT 7,626,349 B2
`NIDEC MOTOR CORPORATION )
` Patent Owner. )
` *****************************************************
` ORAL TELEPHONIC DEPOSITION
` DR. MARK EHSANI
` NOVEMBER 19, 2015
` *****************************************************
` ORAL DEPOSITION OF DR. MARK EHSANI, produced as a
`witness at the instance of the Patent Owner and duly
`sworn, was taken in the above-styled and numbered cause
`on the 19th day of November, 2015, from 11:06 a.m. to
`12:07 p.m., before Lori H. Hudgins, Certified Shorthand
`Reporter in and for the State of Texas, reported by
`computerized stenotype machine at the offices of Locke
`Lord, 600 Travis Street, Suite 2800, Houston, Texas,
`pursuant to the Federal Rules of Civil Procedure and the
`provisions stated on the record or attached hereto.
`
`Nidec Motor Corporation
`IPR2014-01121
`
`Exhibit 2037 - 1
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT AND APPEAL BOARD
`
`ZHONGSHAN BROAD OCEAN )
`MOTOR CO., LTD, BROAD )
`OCEAN MOTOR LLC, AND BROAD)
`OCEAN TECHNOLOGY, LLC. )
` Petitioners, )
` )
`vs. ) CASE NO. IPR2014-01121
` ) PATENT 7,626,349 B2
`NIDEC MOTOR CORPORATION )
` Patent Owner. )
` *****************************************************
` ORAL TELEPHONIC DEPOSITION
` DR. MARK EHSANI
` NOVEMBER 19, 2015
` *****************************************************
` ORAL DEPOSITION OF DR. MARK EHSANI, produced as a
`witness at the instance of the Patent Owner and duly
`sworn, was taken in the above-styled and numbered cause
`on the 19th day of November, 2015, from 11:06 a.m. to
`12:07 p.m., before Lori H. Hudgins, Certified Shorthand
`Reporter in and for the State of Texas, reported by
`computerized stenotype machine at the offices of Locke
`Lord, 600 Travis Street, Suite 2800, Houston, Texas,
`pursuant to the Federal Rules of Civil Procedure and the
`provisions stated on the record or attached hereto.
`
`Nidec Motor Corporation
`IPR2014-01121
`
`Exhibit 2037 - 1
`
`
`
`Page 2
`
` APPEARANCES
`
`FOR PATENT OWNER:
` Mr. Scott Brown - TELEPHONICALLY
` HOVEY WILLIAMS, LLP
` 10801 Mastin Boulevard
` Suite 1000
` Overland Park, KS 66210
` Telephone: 913.647.9050 - Fax: 913.647.9057
`
`FOR PETITIONER:
` Mr. Steven Meyer
` LOCKE LORD, LLP
` 3 World Financial Center
` New York New York 10281
` Telephone: 212.415.8535 - Fax: 212.303.2754
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`Nidec Motor Corporation
`IPR2014-01121
`
`Exhibit 2037 - 2
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`
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`Page 3
`
` INDEX
` PAGE
`Stipulations .........................................1
`Appearances ..........................................2
`TESTIMONY OF DR. MARK EHSANI
` Examination by Mr. Scott Brown ..................4
` Examination by Mr. Steven Meyer ................26
` Further Examination by Mr. Scott Brown .........27
`Court Reporter's Certificate ........................30
`
` EXHIBITS
`EXHIBIT DESCRIPTION PAGE
`Exhibit 1001 US Patent 7,626,349 B2 ................4
`Exhibit 1005 JP 2003-348885 Abstract ..............4
`Exhibit 1009 Declaration of Dr. Mark Ehsani ........4
` re Patent 7,626,349
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`IPR2014-01121
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`Exhibit 2037 - 3
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`Page 4
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` DR. MARK EHSANI,
` having been first duly sworn, testified as follows:
` EXAMINATION
`BY MR. SCOTT BROWN
` Q. Dr. Morning, Dr. Ehsani.
` A. Good morning. How are you?
` Q. I'm fine. Thanks.
` You understand that there is an
`additional inter partes review that has been
`consolidated into what we've referred to as the 1121
`matter, the lawyers do anyway, and that it introduces a
`new ground asserting anticipation of a reference called
`Hideji?
` A. I do.
` Q. Okay. And so you're familiar with the Hideji
`reference?
` A. Yes, sir.
` Q. Okay. I'm going to focus on that since that's
`the sole new issue that's been introduced into this
`matter.
` MR. BROWN: And I would ask that the
`court reporter hand to the witness what has been
`previously marked as Exhibit 1005.
` COURT REPORTER: (Complies.)
` Q. (BY MR. BROWN) Do you have Exhibit 1005 in
`
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`Exhibit 2037 - 4
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`Page 5
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`front of you, Dr. Ehsani?
` A. I do.
` Q. And this is -- confirm for me that what's in
`front of you is the English language translation of the
`Japanese reference?
` A. It is an English language document. I have to
`read through it to see exactly what it stands for.
` Q. Okay. Well, just take a moment and let me
`know if you're satisfied that that is the translation of
`the Hideji reference.
` MR. MEYER: Okay. Just for the record, I
`am going to object to this exhibit because it does not
`include the attestation statement.
` I'll allow you to ask him questions, but
`this -- this objection stands if you're going to use
`this version in any submission in the court.
` MR. BROWN: Okay.
` MR. MEYER: Okay.
` A. I do not see Hideji name mentioned anywhere.
`I'm willing to work with this if you represent that this
`is, in fact, a reliable translation of that patent.
` Q. (BY MR. BROWN) Okay. Would you look at -- I
`believe at the end of the document there should be some
`figures.
` A. Yes.
`
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`IPR2014-01121
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`Exhibit 2037 - 5
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`Page 6
` Q. And are -- do those figures look familiar to
`you?
` A. Yes.
` Q. Can you tell me -- Dr. Ehsani, with respect to
`the Hideji reference, what does Hideji say as its point
`of novelty? What does it purport to be disclosing as a
`new invention?
` A. I do not wish to do that from memory. I would
`have to read the claims of Hideji to tell you exactly by
`definition what he claims to be novel. I really do not
`have an opinion other than what the inventor claims.
` Q. Okay. So as you sit here today without
`reading the claims, do you have any general
`understanding about what Hideji thought he was
`introducing as new in his disclosure?
` A. Generally speaking, it is a HVAC motor drive
`using d-q -- decoupled control, which in every way
`anticipates the claims that have been asserted by the
`patent holder.
` Q. In Hideji is -- is it a sensorless control
`based system?
` A. I believe that is one of the methods that
`Hideji can be utilized, correct.
` Q. Can you tell me how does that sensorless
`control work in Hideji?
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`IPR2014-01121
`
`Exhibit 2037 - 6
`
`
`
`Page 7
` A. Again, I would have to -- I have not memorized
`the document, nor have I prepared to lecture on it. I
`would have to read the document in its entirety to give
`a specific answer to your question, and I'm happy to do
`that.
` Q. Maybe we can focus on one of the figures to
`get some of these answers. I'd like you to look at
`Figure 2 of Exhibit 1005.
` A. Correct.
` Q. Do you have that in front of you?
` A. Yes.
` Q. Okay. Looking at that figure, first, can you
`tell me what is the source of power for the system
`that's shown in Figure 2?
` A. The -- there are different ways to interpret
`this, but I will answer it at the level that you asked
`the question. It would be Box Number 32.
` Q. Okay. So you understand that's where the
`power to drive the motor is ultimately coming from?
` A. That is correct.
` Q. Okay. And then 32 feeds to a rectifier
`circuit, 33. Do you see that?
` A. Correct.
` Q. What is the function of that rectifier
`circuit?
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`IPR2014-01121
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`Exhibit 2037 - 7
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`Page 8
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` A. The rectifier circuit produces a DC-BUS
`voltage. That is what is utilized in conventional
`inverters that drive electric motors.
` Q. And then that -- that rectified -- would it be
`correct to call it a rectified signal that is output
`from Box 33?
` A. No -- no, it's not.
` Q. What would you call it?
` A. I would call it rectified power.
` Q. Okay. So the rectified power is output from
`Box 33 into Box 31; is that correct?
` A. That is what's shown here.
` Q. And Box 31 is labeled as a three-phase PWM
`inverter. Do you see that?
` A. I do.
` Q. What is your understanding of the function of
`Box 31?
` A. 31 is what is called an inverter that produces
`desired -- in this case, three-phase AC voltages under
`some sort of a control to be fed to the motor.
` Q. So the -- the three-phase, would they be
`alternating current signals?
` A. It is actually, I believe, a voltage source
`inverter, so it actually controls the voltage.
` Q. Okay. So there is three different phases of
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`IPR2014-01121
`
`Exhibit 2037 - 8
`
`
`
`Page 9
`voltage being output by the three-phase PWM inverter?
` A. Repeat the question again, please.
` MR. BROWN: Could you read the question
`back?
` (The record was read as requested.)
` A. There are three phases of voltage in a
`balanced three-phase system. I don't want to -- unless
`you tell me what you mean by different, they're
`obviously both coupled and different.
` Q. What is the purpose of having three-phase
`voltages being produced by Box 31?
` A. The voltages are the source of power to the
`motor.
` Q. And is it your understanding that -- let's
`take, for example, is one of those phases labeled as VG
`sub U?
` A. Correct.
` Q. Okay. So if you look at just one of those
`lead lines then, is that carrying a sinusoidal voltage
`signal?
` A. No, sir, not instantaneously.
` Q. And what did you mean by "not
`instantaneously"?
` A. The three-phase PWM inverter of Box 31 is, in
`fact, a power electronic device called a switching
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`Nidec Motor Corporation
`IPR2014-01121
`
`Exhibit 2037 - 9
`
`
`
`Page 10
`inverter, and the job of the switching inverters is to
`actually switch each phase voltage positive zero or
`negative at a very high frequency.
` The PWM or pulse with modulation control
`strategy then organizes these pulses in such a way that
`although instantaneously they appear like a sequence of
`discontinuous voltages, through a mathematical theory
`called Fourier transform can be decomposed into a
`fundamental signal voltage that is sinusoidal plus many
`harmonics, so it would be incorrect to say Vgu is
`sinusoidal.
` Q. And would the -- is there another part of the
`system that would carry out that Fourier transform that
`you're describing?
` A. No, sir.
` Q. So in other words, the motor itself -- that's
`labeled "M"; is that correct?
` A. That is correct.
` Q. The motor itself is receiving those voltage
`signals, and is it operating essentially as if it were a
`sinusoidal signal?
` A. I don't know what you mean by operating. I
`will try to help you out with the construction of the
`question, so that I can then give it an answer.
` The motor, due to its own
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`IPR2014-01121
`
`Exhibit 2037 - 10
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`
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`Page 11
`characteristics, which we will not talk about right now,
`acts as a filter and is more sensitive to the theoretic
`fundamental component of voltage, which can be
`decomposed from those sequence of pulses. It's more
`sensitive to the lower frequency specifically the
`fundamental. Therefore, it is going to draw a current
`which is substantially sinusoidal but not exactly and
`completely.
` Q. Okay. Thank you.
` Now, what is the purpose of Box 42
`labeled "induced voltage detecting part"?
` A. That, I believe, is a way of detecting what is
`sometimes called the air-gap voltage or the back EMF.
` Q. And what information would detecting the back
`EMF or air gap provide for the motor -- for the motor
`system?
` A. Well, it gives enough information to
`reconstruct, in some approximate way, the air-gap
`voltage, which can be used for many purposes, among them
`might be under certain conditions indirect rotor
`position detection.
` Q. And with regard to the disclosure of Hideji,
`is that what Hideji says it's using the induced voltage
`detection part for to infer rotor position?
` A. You would have to refer me to the specific
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`IPR2014-01121
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`Exhibit 2037 - 11
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`Page 12
`passages. I would have to read the whole thing. I
`haven't memorized it, but that would be a useful signal
`for that.
` Q. Are there any other useful -- to use your
`terminology -- useful things you can do with that
`information other than determining rotor position?
` A. Yes, sir.
` Q. What else can be done with that information?
` A. Oh, a very large number of things. Would you
`like for me to list them all or just give you one more
`example?
` Q. Well, let's start with one more example.
` A. It can be used for, for example, field
`weakening control.
` Q. If you look at paragraph -- perhaps, if you
`look at Paragraph 45 of the disclosure, tell me -- 45
`and 46, tell me if that's describing that this induced
`voltage, at least in part, is used to detect rotor
`position?
` A. Could you repeat the question again?
` Q. Let me ask it more open-ended.
` Do those paragraphs describe at least one
`of the uses that Hideji has for detecting the induced
`voltage?
` A. Sorry. Repeat the question again.
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`Exhibit 2037 - 12
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`Page 13
` Q. Do those paragraphs describe at least one of
`the uses that Hideji has for detecting induced voltage?
` A. It does refer to it, yes.
` Q. Okay. And what does Hideji say there that
`it's using this detection for?
` A. It is -- it's referring to what is known in
`the state of the art as indirect rotor position sensing
`based on back EMF or air-gap voltage, which in this
`patent, I believe, is referred to as the induced
`voltage, and it says that that is, in fact, used for
`detection of the rotation.
` Again, these are very rough translations
`by a non-technical person, but one can see through it as
`a person of ordinary skill at least that it's referring
`to that body of knowledge --
` Q. And --
` A. -- which pre-exists, by the way, this patent.
` Q. Is -- is -- the induced voltage detecting
`part, does that contribute to making this a sensorless
`control based system?
` A. That would be one way to do it, yes.
` Q. And the -- the voltages that are being
`detected on those lead lines are also the same voltages
`that are being fed by the three-phase PWM inverter to
`the motor; is that correct?
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`IPR2014-01121
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`Exhibit 2037 - 13
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`Page 14
`
` A. No, sir, that is not correct.
` Q. What's incorrect about that statement?
` A. It's just not right. It is not sensing the
`voltage that it's creating. That would be superfluous.
` Q. Okay. Well, what voltage is it sensing then?
` A. It's sensing the induced voltage, not the
`applied voltage.
` Q. And the -- the induced voltage is also -- must
`also be present on those lines that it shows that it's
`being connected to, correct?
` A. Not always.
` Q. But in order for an induced voltage to be
`sensed by this detecting part, it would have to be
`present on one of those lines, correct?
` A. Approximately correct. Also, its absence
`might be detected.
` Q. Okay. And the induced voltage then is
`something that is created by the spinning of the motor?
` A. Correct.
` Q. There is two lead lines. One is labeled "Iu,"
`and one is labeled "Iv" that are shown as inputs to the
`current input part A/D 35. Do you see that?
` A. I do.
` Q. What is the purpose of Iu?
` A. To sense the current on Lead U.
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`Exhibit 2037 - 14
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`Page 15
` Q. And is the current on Lead U going to the
`motor?
` A. That is the current that the motor draws on
`Lead U.
` Q. So -- okay. So that is sensing the current
`being drawn by the motor on Lead U?
` A. That is correct.
` Q. And then likewise, on the lead that's labeled
`"Iv," that is sensing the current that is drawn by the
`motor on Lead V?
` A. That is correct.
` Q. And then part 35 converts that from analogue
`to digital values?
` A. That's what is written in that box.
` Q. And do you have any reason to doubt that
`that's what the purpose of Box 35 is?
` A. Well, a person of order skill would know that
`in order to do digital computations based on the values
`of current from the leads to the motor, they would have
`to first be sensed and then converted from analogue
`signals to digital signals, so with that necessarily
`being part of the system, one can say that 35 is
`performing that function. We don't know if it's
`performing other functions or not. These boxes are
`extremely at high level, not all lines or functions are
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`Exhibit 2037 - 15
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`Page 16
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`shown.
` Q. So it might be doing more than that, but it's
`doing at least that. Would that be accurate?
` A. I think that's -- that's fair to say.
` Q. Then the results of that analogue-to-digital
`conversion of Iu and Iv are fed to part 36, which is
`labeled "three-phase/two-phase coordinate conversion
`part." Do you see that?
` A. I do.
` Q. What is the function of part 36?
` A. The function of part 36 is manifold. Among
`them is conversion from three-axis current information
`to two-axis decoupled Cartesian coordinate current
`information, v and q, as well as other things.
` Q. So when the conversion occurs, the resulting
`signals Iq and Id represent the value of the current
`that's being drawn by the motor but in the q-d frame of
`reference?
` A. No. The frame of reference is a separate
`issue. That is not mathematically speaking but speaking
`in the language of motor drives.
` The -- it is a three-axis to two-axis
`conversion of the current information, so if you are
`talking about that aspect, yes, it is a frame of
`reference, but the frame of reference in this motor
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`IPR2014-01121
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`Exhibit 2037 - 16
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`Page 17
`drive has other meanings, not to be confused with what
`you said.
` Q. Would it be accurate to say that, for
`instance, the value on the Lead Iq coming out of
`conversion part 36 represents the quadrature current
`that's being drawn -- by the motor at any given point in
`time?
` A. That is partially -- it's an incomplete
`correct statement.
` Q. And would it be correct to say that the value
`of Id coming out of conversion part 36 represents the
`value of the direct axis current that's being drawn by
`the motor at any given point in time?
` A. When you say that what frame of reference in
`the motor -- in the air gap are you thinking of?
` Q. Well, let's take the Id lead for instance.
`You see that value of Id is also fed to a -- what I
`believe the Hideji reference refers to as a PI
`conversion, which is represented by a circle with a plus
`and a minus up above part 36?
` A. No, that's not correct. This is -- the PI
`does not occur at that summer.
` Q. Okay. At that summer -- but there is a value
`of Id that comes out of part 36 that goes to the
`summer; is that correct?
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`IPR2014-01121
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`Exhibit 2037 - 17
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`Page 18
`
` A. That is correct.
` Q. Okay. We'll get to it in a moment, but coming
`out of phase control part 39 is a target value for Id;
`is that correct?
` A. Yes, that comes from outside of the motor
`control universe.
` Q. Well, but the volume coming out of phase
`control part 39 will be a target value for Id; is that
`correct?
` A. Understanding that target values come from
`outside of the motor control not from within the motor
`control.
` Q. Okay. With that correction -- or with that
`addition, the statement is correct?
` A. Yes, you can call it that way. The standard
`jargon for that is reference current.
` Q. As opposed to target?
` A. That's -- in control systems, it's referred to
`as reference current or I star, but I'm willing to work
`with target, yes.
` Q. Okay. Well, I used target because in the
`Hideji reference, it refers to it as target.
` A. Right. It's a translation by a translator,
`correct.
` Q. What is the function of the rotor speed and
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`Nidec Motor Corporation
`IPR2014-01121
`
`Exhibit 2037 - 18
`
`
`
`Page 19
`
`position calculating part 37?
` A. That implies that this control system is
`capable of indirect rotor position and speed sensing.
` Q. And it uses the converted values for Iq and Id
`to do that?
` A. Not exclusively.
` Q. Those would be some of the inputs to whatever
`is going on in Box 37?
` A. That is what is shown here.
` Q. And do you have an understanding of how Box 37
`would use the converted Iq and Id values to determine
`rotor speed position -- rotor speed and position?
` A. Well, again, these are very approximate. You
`would have to read the detailed description to figure
`out what he's thinking. There is a lot of
`unconventional names and symbols that are used here so
`one knows that indirect position sensing is done there
`but -- and there are many different ways of doing it.
` Q. What is your understanding of the function of
`the speed control part 38 in Hideji?
` A. This is, again, something that really is
`responding to the demands outside -- outside of the
`motor control. The system control commands a target
`speed, and in feedback control technology, in order to
`satisfy that target speed, the actual speed must first
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`Nidec Motor Corporation
`IPR2014-01121
`
`Exhibit 2037 - 19
`
`
`
`Page 20
`
`be detected in some way, and an error signal
`proportional to the error in the speed between the
`desired and the actual is produced, which then commands
`other parts of the system directly related to motor
`control to respond to, and the speed control part is
`part of that function that I just described to you.
` Q. And at least one of the functions of the speed
`control part is to produce the torque current Iq target
`value; is that correct?
` A. That is correct.
` Q. And that's an input to a summer?
` A. That is what is shown.
` Q. And then the calculated or sensed and
`transformed current Iq that comes from Part 36 is also
`fed to the summer to determine a difference between the
`target Iq and the actual Iq?
` A. That is a correct characterization.
` Q. And based on the difference between those two,
`that is fed to the current control part which is then
`able to -- in this feedback system, it then attempts to
`adjust to make Iq match the target value. Would that be
`correct?
` A. In a very vague and approximate way, you're
`right. That Box 40 is pregnant with many, many
`different elements.
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`Nidec Motor Corporation
`IPR2014-01121
`
`Exhibit 2037 - 20
`
`
`
`Page 21
` Q. Now, phase control part, 39, at least one of
`its functions is to output the target value for the flux
`current Id; is that correct?
` A. Repeat the question, again.
` Q. Phase control part 39, one of its functions is
`to produce a target value for the flux current Id.
` A. A better way to think of that is that is where
`target value comes from. It could come from anywhere.
`It's external to the control. It has to do with the --
`it could come from anywhere, so just like target speed
`comes mysteriously from the left, the target Id, a
`little bit less mysteriously, comes from the box 39, so
`it is an independent target that can come from anywhere
`based on many things.
` Q. But that box is producing the target value for
`the Id current to run the motor at any given time?
` A. It's a representative of how the target Id is
`produced.
` Notice that all these boxes are highly
`representative. For example, box 42 just detects the
`air-gap voltage and doesn't do anything with it.
`Obviously, on its face, this doesn't make sense, so
`there is a lot of implicit information not to be taken
`literally.
` Q. Now, Hideji says that the target flux current
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`Nidec Motor Corporation
`IPR2014-01121
`
`Exhibit 2037 - 21
`
`
`
`Page 22
`Id is developed using a formula that is based upon the
`value of Iq, correct?
` A. It gives that as an example of how to compute
`the decoupled Id and Iq, and everyone understands that
`these can be calculated -- these can be targeted based
`on whatever preference the system operator has.
` Q. And Hideji's stated preference is to develop
`the target value for Id based upon a formula that's
`recited in Paragraph 39; is that correct? Will you look
`at 39?
` A. Sure. Allow me to review that paragraph.
` Yes, this is a very brief and broad
`representation of using the capability of an independent
`d-axis control for field weakening, and again, this is
`not exactly written here but is obvious to a person of
`ordinary skill that he says that in order to make the
`terminal voltages that are imposed on the motor
`reasonable and manageable -- in other words, not beyond
`the capability of the inverter or the power source,
`field weakening can be done, and it gives an example of
`one strategy for field weakening as shown in 39, but the
`objective is that field weakening capability is inherit
`with this technique.
` Q. And so the field weakening that you're
`describing there involves setting target values for the
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`Nidec Motor Corporation
`IPR2014-01121
`
`Exhibit 2037 - 22
`
`
`
`Page 23
`
`current Id; is that correct?
` A. Correct.
` Q. And in this case what Hideji discloses is that
`the target current Id is equal to some constant k times
`Iq squared, right?
` A. This is an example given, and you must
`understand that it depends on two elements, Iq and k,
`and k is also at the discretion of the operator.
` Q. And it's true, isn't it, that Hideji does not
`describe any other way of setting the target value Id
`other than using this proposed equation?
` A. I cannot vouch for that. I see that this
`representation is given in this passage.
` Q. As you sit here today, are you aware of any
`other passages in Hideji that gives an alternative to
`this?
` A. Again, my understanding is that Hideji is
`simply describing a technology which precedes the patent
`which is well known in the art and that is independent
`d-q axis control of the motor, and it says that in my
`ability to independently control the d-axis current, I
`would respond to a target, and that target can come from
`anywhere, for example, for limiting terminal voltages to
`a manageable magnitude, and then it suggests one way of
`doing it.
`
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`Nidec Motor Corporation
`IPR2014-01121
`
`Exhibit 2037 - 23
`
`
`
`Page 24
` Q. And there is no other disclosure, is there, in
`Hideji of how to set the target value other than by
`using this proposed equation k times Iq squared?
` A. Are you asking this as a -- as it appears --
`as it reads to a person of ordinary skill, or are you
`asking a linguistic question?
` Q. I'm asking where else in Hideji it says to
`develop Id other than by using this equation which is
`set forth in Paragraph 39.
` A. He is suggesting a method of externally coming
`up with a target Id, which is one way to control the
`independent Id current -- the decoupled Id current. A
`person of ordinary skill understands that this target
`can be based on many other things, and this is simply an
`example.
` Q. Does Hideji disclose any other examples other
`than this one?
` A. To a person of ordinary skill, this
`communicates that Hideji gives an example of target
`calculation.
` Q. My question was: Does Hideji disclose any
`other example for developing target for Id?
` A. To a person of ordinary skill, it discloses an
`example among many for target calculation, but if by
`disclose you mean what is printed on this page, then
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`Nidec Motor Corporation
`IPR2014-01121
`
`Exhibit 2037 - 24
`
`
`
`Page 25
`this is the only example that is printed. You have to
`clarify the meaning of disclosure because the way I
`answer it and the way you might use it in the future
`might not be identical.
` Q. I mean does Hideji describe in words another
`example of how to develop the target current Id other
`than the equation set forth in Paragraph 39?
` A. In Paragraph 39 only one example is given.
` Q. Outside of the confines of Paragraph 39, is
`there other disclosure in Hideji that gives another
`example of how to develop the target current Id?
` A. To a person of ordinary skill, it shows a
`representation of target Id calculation because a person
`of ordinary skill understands that targets always come
`from outside of the control system.
` Q. And would you agree with me that there is no
`express disclosure in Hideji of another example beyond
`the one given in Paragraph 39 of how to develop a target
`value for Id?
` A. I believe it's fair to say that one explicit
`example of target calculation is given.
` MR. BROWN: Why don't we take like a sort
`break like five minutes, and I might be done?
` MR. MEYER: Okay.
` (Recess taken 11:54 to 11:59.)
`
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`Nidec Motor Corporation
`IPR2014-01121
`
`Exhibit 2037 - 25
`
`
`
`Page 26
`
` MR. BROWN: Back on the record.
` Q. (BY MR. BROWN) Dr. Ehsani, is it correct that
`the speed control part 38 outputs a target value for Iq
`to a summer and the measured Iq comes from Part 36, and
`based upon the difference between the target Iq and the
`measured Iq, if any current control part 40 will alter
`the voltage Vq to try and obtain the target value for
`Iq?
` A. I believe that would be a fair statement.
` Q. Okay. And then I have the same question with
`respect to phase control part 39. It outputs a target
`value for Id to the summer, and based upon any
`difference between the target value for Id and the
`measured value for Id that comes from Part 36, current
`control part 40 will develop a value for Vd that is
`intended to obtain the target value for Id?
` A. That is a generic and correct statement, and
`it will function for a target value for Id coming from
`any consideration, and that's why they are decoupled.
` MR. BROWN: Okay. I think I have no
`further questions.
` MR. MEYER: Okay. I have a few questions
`on redirect.
` EXAMINATION
`BY MR. STEVEN MEYER
`
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`Nidec Motor Corporation
`IPR2014-01121
`
`Exhibit 2037 - 26
`
`
`
`Page 27
` Q. Okay. Does the motor driving device 50
`depicted in Figure of Hideji use I sub q and I sub d as
`opposed to the I sub q target value and the I sub d
`target value for performing sine wave commutation?
` A. It does use it.
` Q. And are those I sub q and I sub d values
`independent?
` A. They are.
` MR. MEYER: I have no further questions.
` MR. BROWN: I have a question then, or
`two.
` FURTHER EXAMINATION
`BY MR. SCOTT BROWN.
` Q. In your opinion, Dr. Ehsani, if, in fact,
`phase control part 39 is developing a target Id value
`based upon the formula set forth in Paragraph 39 of
`Hideji, in your opinion is Id developed without
`reference to Iq?
` MR. MEYER: Objection, outside the scope
`of my redirect.
` A. Sorry. Repeat the question. It had some
`subtle parts so I want to make sure I fully understand.
` MR. BROWN: Could you read the question
`back, please?
` (The record was read as requested.)
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`Nidec Motor Corporation
`IPR2014-01121
`
`Exhibit 2037 - 27
`
`
`
`Page 28
` MR. BROWN: Let me rephrase the question
`because I might have stated it incorrectly.
` Q. (BY MR. BROWN) In your opinion, Dr. Ehsani,
`if phase control part 39 develops a target current for
`I sub d
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