FORD MOTOR COMPANY v. PAICE, LLC, ET AL.
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`NEIL HANNEMANN
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`April 8, 2015
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`Prepared for you by
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`Bingham Farms/Southfield • Grand Rapids
`Ann Arbor • Detroit • Flint • Jackson • Lansing • Mt. Clemens • Saginaw
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`FORD 1131
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`NEIL HANNEMANNNEIL HANNEMANN
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`April 8, 2015April 8, 2015
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`Page 1
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`Page 3
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` A P P E A R A N C E S
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`ON BEHALF OF PETITIONER:
` FRANK A. ANGILERI, ESQUIRE
` JOHN P. RONDINI, ESQUIRE
` ANDREW B. TURNER, ESQUIRE
` BROOKS KUSHMAN, PC
` 1000 Town Center
` 22nd Floor
` Southfield, MI 48075
` (248) 226-2913
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`ON BEHALF OF THE PATENT OWNER:
` W. PETER GUARNIERI, ESQUIRE
` LINDA LIU KORDZIEL, ESQUIRE
` FISH & RICHARDSON
` 1425 K Street, NW
` 11th Floor
` Washington, DC 20005
` (202) 783-5070
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`ALSO PRESENT:
` Frances Keenan, Paice LLC
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`Page 4
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` C O N T E N T S
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`EXAMINATION OF NEIL HANNEMANN PAGE
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` By Mr. Angileri 5
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` FORD MOTOR COMPANY, :
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` Petitioner, :
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` v. : IPR Case No:
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` PAICE LLC & ABELL FOUNDATION, : IPR2014-00570
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` INC., :
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` Patent Owner. :
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` :
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`- - - - - - - - - - - - - - - - -x
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` Oral Deposition of NEIL HANNEMANN
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` Washington, DC
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` Wednesday, April 8, 2015
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` 12:55 p.m.
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`Job No.: 78384
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`Pages: 1 - 87
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`Reported By: Rebecca Stonestreet, RPR, CRR
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` Oral Deposition of NEIL HANNEMANN, held at the
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`offices of:
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` FISH & RICHARDSON, PC
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` By Mr. Guarnieri 83
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` E X H I B I T S
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` (Retained by Counsel.)
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`HANNEMANN EXHIBIT PAGE
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` 1 Declaration of Neil Hannemann 5
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` 2 U.S. Patent No. 8,214,097 5
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` 3 U.S. Patent No. 5,343,970 5
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` 4 "The Effects of APU Characteristics on the
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` Design of Hybrid Control Strategies for
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` Hybrid Electric Vehicles" 5
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` 5 Curriculum Vitae 70
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` 6 Supplemental Declaration 80
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` 1425 K Street, NW
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` 11th Floor
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` Washington, DC 20005
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` (202) 783-5070
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` Pursuant to notice, before
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`Rebecca Stonestreet, Registered Professional Reporter,
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`Certified Realtime Reporter, and Notary Public in and for
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`the District of Columbia, who officiated in administering
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`the oath to the witness.
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`Pages 1 to 4Pages 1 to 4
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`FORD 1131
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`

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`NEIL HANNEMANNNEIL HANNEMANN
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`April 8, 2015April 8, 2015
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` P R O C E E D I N G S
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` (HANNEMANN Exhibits 1 through 4 were marked
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`for identification and retained by counsel.)
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` (NEIL HANNEMANN, having been duly sworn, testified as
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` follows:)
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` EXAMINATION BY COUNSEL FOR PETITIONER
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`BY MR. ANGILERI:
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` Q Can you state your name for the record,
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`please?
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` A Neil Hannemann.
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` Q Mr. Hannemann, the reporter has marked, as
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`Exhibits 1 through 4, documents that I expect we'll get
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`review the declaration, the prior art, and the patent.
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` Q When did you come here last week to meet with
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`counsel?
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` A On Wednesday.
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` Q How long were you here?
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` A Probably about most of the day, the normal
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`workday.
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` Q Did you leave at the end of the day?
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` A Yes.
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` Q Where did you go? Did you go back home?
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` A No, no, I stayed in Washington. I met for
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`three days last week. I arrived here Wednesday and met
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`13 Wednesday, Thursday, Friday.
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`into today.
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` What is Exhibit 1?
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` A Exhibit 1 is the declaration that I prepared
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`in this matter.
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` Q And this matter is IPR 2014-00570?
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` A That's correct.
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` Q Concerning -- strike that.
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` What's Exhibit 2?
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` A Exhibit 2 is U.S. Patent 8,214,097.
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` Q And that's the patent that's at issue in this
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`IPR?
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` A That's correct.
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` Q We sometimes call it the '097 patent?
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` Q With counsel?
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` A Yes.
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` Q Did you prepare at all on Monday?
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` A Yes, I did.
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` Q Did you -- were you on any flights on Monday?
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` A Yeah, I flew back here Monday.
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` Q From where?
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` A I was actually in Texas.
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` Q So you were in Washington, D.C., Wednesday,
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`Thursday, Friday of last week meeting with counsel for
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`Paice?
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` A Yes.
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`Page 8
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`Page 6
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` A That's correct.
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` Q What is Exhibit 3?
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` A It's Patent Number 5,343,970.
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` Q Sometimes we call that the '970 patent?
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` A That's correct.
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` Q That's part of the prior art that's at issue
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`in this IPR?
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` A Yes, it is.
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` Q What is Exhibit 4?
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` A It's an SAE paper, 950493, titled "The Effects
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`of APU Characteristics on the Design of Hybrid Control
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`Strategies for Hybrid Electric Vehicles."
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` Q And then you left Washington, D.C.?
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` A Yes.
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` Q And then you came back on Monday?
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` A That's correct.
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` Q Who did you meet with on Wednesday, Thursday
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`and Friday last week?
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` A Well, at various times Mr. Guarnieri,
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`Mr. Marcus, and Ms. Kordziel.
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` MR. GUARNIERI: For the record I think he's
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`referring to Mr. Livedalen, Brian.
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` THE WITNESS: Oh, sorry.
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` Q How did you prepare the declaration that's
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`been marked as Exhibit 1?
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` Q One of the named authors is a person named
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`Catherine Anderson. Correct?
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` A That's correct.
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` Q And as a result, we sometimes refer to this as
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`the Anderson paper or just Anderson?
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` A Yes.
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` Q What did you do to prepare for this deposition
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`and the depositions that you've had yesterday and today?
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` A Well, I --
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` MR. GUARNIERI: And I'll just caution him not
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`to get into any privileged communications.
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` But you can answer.
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` A I came here last week to meet with counsel and
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` A Quite a while ago, I reviewed all the material
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`that was the prior art and the patent and had -- I came
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`here to Washington to meet with counsel and discuss all
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`the elements, the technical matters.
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` And then I worked with counsel to, you know,
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`draft up various portions of this, or add or work through
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`a draft until arriving at this product.
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` Q Did counsel prepare first drafts of any
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`portions of Exhibit 1?
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` A Yeah, there were some portions that they
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`drafted up initially.
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` Q Do you know which portions?
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`Pages 5 to 8Pages 5 to 8
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`FORD 1131
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`

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`NEIL HANNEMANNNEIL HANNEMANN
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`April 8, 2015April 8, 2015
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`Page 9
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`Page 11
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` A You know, I might be able to pick some out.
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`I'm not sure I would be getting all of them correct.
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` Q Which portions of Section 8 did counsel
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`prepare the first draft of?
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` A That's one where I'm not sure which section
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`started with counsel or myself.
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` Q Can you identify any section that you prepared
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`the first draft of?
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` A Yeah. My memory is probably not that good to
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`go back and define it to that level of detail.
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` Q The other declarations that we marked in 571
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`and 579 depositions that were yesterday and today -- do
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`declarations?
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` A I really don't have any idea, as I sit here.
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` Q Do you know how much time you spent on all six
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`of those proceedings combined?
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` A Not really.
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` Q Do you know how much you've billed Paice for
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`these six proceedings?
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` A I would have invoices, but I don't have those
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`with me.
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` Q Can you estimate to within $100,000 of how
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`much you've billed Paice?
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` A Sure. I think it's pretty safe to say it's
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`you recall those declarations?
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` A Yes.
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` Q Were they prepared in a similar manner as the
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`manner you just described --
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` A Yeah.
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` Q -- in Exhibit 1?
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` A Yeah, in a similar manner.
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` Q And for those two declarations, can you recall
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`any section that you prepared the first draft of?
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` A Some of the sections and probably the more
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`technical sections are probably ones that I prepared.
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`And, certainly, my background is something that I
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`started.
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`less than $100,000.
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` Q Is it less than $50,000?
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` A It's really hard to say without checking, but
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`it's likely that it is.
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` Q Is it less than $25,000?
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` A Probably not.
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` Q Can you look at Exhibit 3, please?
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` A (Witness complies.)
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` Q Exhibit 3 is the '970 patent. Correct?
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` A Yes.
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` Q The '970 patent describes a parallel system.
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`Is that correct?
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` A Yes, it does.
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` Q Is there anything specifically that you can
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`identify as preparing the first draft of other than your
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`background?
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` A Specifically in this declaration, or are you
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`talking the other ones also?
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` Q Any of the three.
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` A Any of them. I just don't remember which ones
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`I started or somebody else may have started.
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` Q How much time did you spend preparing or
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`working on -- strike that.
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` How much time did you spend -- strike that.
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` How much time have you spent in these three
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`proceedings, 570, 571 and 579?
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` Q Does the '970 patent have a mode where only
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`the motor is used to propel the vehicle?
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` A Yes, it does.
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` Q And does it have a mode where only the engine
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`is used to propel the vehicle?
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` A Yes, it does.
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` Q Does it have a mode where the engine and the
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`motor are both used to propel the vehicle?
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` A Yes, it does.
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` Q When the motor is used to propel the vehicle,
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`is the engine disconnected from the wheels through a
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`clutch?
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` A I don't think I've really tracked my time for
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`each proceeding, so that's hard to say.
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` Q What about the three proceedings combined?
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` A Well, these have overlapped with three other
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`proceedings that are ongoing now, so it would be hard to
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`really break that out.
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` Q Can you tell me how much time you've spent on
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`the -- strike that.
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` How many proceedings have you worked on for
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`Paice thus far?
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` A The six that I've prepared declarations for.
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` Q How much time have you spent on those six
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` MR. GUARNIERI: I'm going to object to the
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`extent it calls for speculation.
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` A Figure 3 shows a clutch, and up through
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`Figure 9 shows a clutch. So at least the ones disclosed
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`in those figures appear to use a clutch to disconnect the
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`engine.
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` Q Is it true that in order to run in the
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`motor-only mode for the '970 patent, you actually have to
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`disconnect the engine from the wheels?
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` A Are you speaking generically or in the scope
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`of this patent?
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` Q In the '970 patent.
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` A I don't recall seeing any language where it
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`Pages 9 to 12Pages 9 to 12
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`FORD 1131
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`NEIL HANNEMANNNEIL HANNEMANN
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`April 8, 2015April 8, 2015
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`specifically requires the clutch be disconnected.
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` Q If the clutch doesn't disconnect the engine,
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`would you agree, then, that the engine would always have
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`to be running?
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` A Unless there's some mechanism within what they
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`total power required. So they're both providing less.
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` Q Do you agree that the '970 patent can enter an
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`acceleration hill-climbing mode before it reaches the
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`engine's MTO or minimum torque output?
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` A Yeah. According to the '970, it enters that
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`describe as a torque transfer unit that could allow the
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`6 mode based on vehicle speed.
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`unit to --
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` THE REPORTER: A torque trans?
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` THE WITNESS: Torque transfer unit.
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` Q Do you agree that for the -- to run in a
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`motor-only mode, somehow -- strike that.
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` Do you agree that for the '970 to run in the
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` Q And that can -- I don't agree with you there,
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`but you agree that can happen before the engine reaches
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`its maximum torque output or MTO?
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` MR. GUARNIERI: Objection. Form.
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` A Yeah. And I guess the word "reaching" implies
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`that the engine is already on. So if the engine is not
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`motor-only mode and not -- strike that.
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` Do you agree that for the '970 patent to run
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`in the motor-only mode, it somehow has to disconnect the
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`engine from the wheels in order to do that?
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` A I would think that's a reasonable thing to do.
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`I just don't see where it specifically states that.
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` Q Do you think that's how a person of ordinary
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`skill in the art would understand the '970 patent?
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` A I think in the presence of the clutch, that's
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`how someone would understand it operated.
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` Q So just to be clear, a person of skill in the
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`art would understand that when the '970 patent is running
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`in motor-only mode, it's using the clutch to disconnect
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`already on, it's not going to reach any torque.
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` Q Are you saying that the '970 can enter
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`acceleration hill-climbing mode by starting with the
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`motor and then adding the engine?
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` A I think that's one way it can enter that mode,
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`yes.
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` Q And obviously in that case you are using both
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`the motor and the engine in a situation where the engine
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`has not yet hit its maximum torque output. Correct?
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` A Yeah. I think that there's points in the
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`high-speed acceleration/hill-climbing mode where the
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`engine is not at its maximum torque.
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` Q And you're using the motor and the engine at
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`the engine from the wheels. Do you agree with that
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`statement?
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` A Yes, I do.
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` Q Do you agree that an object of the invention
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`of the '970 patent is reducing emissions?
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` A I think that's an aspirational goal, to reduce
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`emissions, yes.
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` Q In fact, if you look at Column 5, Lines 24 to
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`30, isn't that the first stated object of the invention
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`in the '970 patent?
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` A Yes.
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` Q Do you agree that in the acceleration
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`those times. Right?
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` A Yes.
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` Q Do hybrid vehicles use AC motors or DC motors?
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` A I would say most of them use AC motors
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`currently. There have been some that have used DC motors
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`in the past.
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` Q In the past, were DC motors a better fit?
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` MR. GUARNIERI: Objection. Vague.
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` A Yeah. It depends on the design goals and the
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`design criteria.
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` Q Which is a better -- which is better to use?
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`AC motors or DC motors?
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` MR. GUARNIERI: Same objection. Vague.
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`hill-climbing mode of the '970 patent, the motor is used
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`to supplement the engine?
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` MR. GUARNIERI: Objection. Assumes facts not
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`in evidence and calls for speculation.
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` A Yeah, I agree in the high-speed
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`acceleration/hill-climbing mode, both the internal
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`combustion engine and the electric motor provide torque
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`to the road wheels.
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` Q Do you agree, then, that in that situation,
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`the engine is providing less than the amount of torque
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`required to operate the vehicle?
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` A Yeah. You have torque coming from both the
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`engine and the motor, so neither one is providing the
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` A Yeah. It depends on what's important in your
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`design. If it's performance, weight, cost, all those
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`issues can drive a different design decision.
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` Q Is a person of ordinary skill in the art going
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`to consider those design criteria, that you just
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`mentioned, when making a choice between AC and DC motors?
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` A Yeah. I think every choice designing a car
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`has cost, weight, and performance implications.
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` Q So would a person of ordinary skill in the art
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`consider the factors you identified in choosing between
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`AC and DC motors?
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` A Those are some of the factors they would
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`Pages 13 to 16Pages 13 to 16
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`FORD 1131
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`

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`NEIL HANNEMANNNEIL HANNEMANN
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`April 8, 2015April 8, 2015
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`consider, yes.
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` Q Any others that come to mind?
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` A In a broad sense that's -- those are the main
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`criteria.
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` Q The Anderson reference, which is Exhibit 4 --
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`and you can certainly consult it if you want -- talks
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`about transients. Do you see that?
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` A Yes.
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` Q What are the transients that Anderson is
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`speaking about?
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` MR. GUARNIERI: Object to the extent that
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`calls for speculation.
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`the bookends of a series strategy, at least for
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`controlling the engine.
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` Q So that contemplates sort of a modified
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`follower strategy, where sometimes you follow demand and
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`sometimes you don't. Do you agree with that?
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` MR. GUARNIERI: Object to the extent that
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`calls for speculation.
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` A I think somebody that's skilled in the art
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`would realize you could -- you could blend these for a
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`specific strategy.
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` Q What would a nonextreme follower mode look
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`like? Strike that.
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` A Yeah. Transients can be -- transient is a
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` What would be one example of a nonextreme
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`generic term that can relate to any kind of a changing
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`condition. I think someone of skill in the art would
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`realize that Anderson is speaking about an engine speed
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`transient.
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` Q Anderson talks about an LLD. Do you remember
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`that?
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` A Yes.
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` Q Do you agree that's a battery?
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` A Not always. But I think in her context she's
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`always referring it back to a battery, but one of the
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`vehicles that I worked on had a flywheel as an LLD.
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` So it can be many other devices. That's why
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`follower mode that a person of skill in the art would
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`understand?
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` MR. GUARNIERI: Objection. Vague.
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` Q Circa 1988.
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` MR. GUARNIERI: Same objection.
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` A Well, I think that one thing that we may have
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`been thinking about is how to use these types of
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`strategies when you have a plug-in vehicle. And in that
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`case you might modify this strategy so that you -- to a
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`degree, deplete the state of charge through operation so
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`you can take advantage of plugging the vehicle in.
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`That's one area, one example I could conceive of
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`Page 20
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`she uses the generic term. But I think every specific
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`reference to that in her paper is referring to a battery.
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` Q Do you agree that if you use a motor to
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`supplement an engine, you're going to put a strain on the
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`battery --
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` MR. GUARNIERI: Objection.
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` Q -- by cycling the battery?
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` MR. GUARNIERI: Objection. Vague.
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` A Yeah. The word "strain" to me means something
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`that may be outside of its normal duty cycle. So hybrid
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`electric vehicle or any vehicle that uses a battery is
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`designed for a certain duty cycle. And if you work
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`modifying the strategy.
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` Q So in that example, you said it's a plug-in
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`hybrid?
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` A If your design goal or if your vehicle design
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`criteria included a plug-in strategy, then it's likely
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`you would modify the -- this control strategy.
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` Q When you use the term "plug-in," what do you
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`mean?
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` A Well, everything Anderson is discussing is
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`trying to maintain a given fixed state of charge in the
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`battery. If you realize that you have the capability to
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`plug the vehicle in, then you can deplete the charge, and
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`when you plug the vehicle in. You can take the energy
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`within that duty cycle, then you're not per se straining
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`the battery. You're operating it as intended.
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` Q Do you agree that Anderson identifies what she
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`calls two distinct extremes in the spectrum of control
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`strategies?
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` A In the context she's talking about is for a
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`series hybrid. She has extreme control strategy that she
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`calls the thermostat and one that she calls the follower
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`strategy.
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` Q And she says that neither of those extremes is
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`normally used in the real world. Right?
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` A Yeah. She says realistically you may use
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`something in between, but she feels that those are, say,
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`from the wall socket rather than generating all the
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`battery charge energy from the engine.
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` Q Okay. And in your answer you said that if
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`you're talking about a plug-in, your words were, "It's
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`likely you would modify this control strategy."
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` Which control strategy are you referring to in
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`that answer?
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` A Well, the control strategy that Anderson
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`discusses for a series hybrid, which is bookended by the
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`thermostat and follower modes.
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` Q What do you mean by "bookended"? Is it a
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`follower strategy or a thermostat strategy that you're
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`
`
`Pages 17 to 20Pages 17 to 20
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`FORD 1131
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`

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`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 8, 2015April 8, 2015
`
`Page 21
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`Page 23
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`modifying?
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` A Well, I think it would be -- I think they're
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`both different strategies. It would just be a third
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`strategy.
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` Q What would be the third strategy?
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` A I could conceive having a strategy for the
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`concept of using a plug-in vehicle.
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` Q And are you saying that this plug-in strategy
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`that you're describing is a modification of a follower
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`extreme, or is it a modification of a thermostat extreme?
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` MR. GUARNIERI: Objection. Vague.
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` A I mean, I think it would be a third strategy
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` A Yeah. A constant state of charge, but there
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`is a range for switching it on and off. So there is some
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`hysteresis built into the system.
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` Q Because Anderson says that you turn on the
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`engine when the state of charge of the battery is below a
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`certain lower threshold, and you turn off the engine when
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`the state of charge exceeds an upper threshold. Correct?
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` A That's correct.
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` Q So the state of charge of the battery in the
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`extreme thermostat strategy varies between this lower
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`threshold and upper threshold?
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` A That's correct.
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`that's somewhere in between the two.
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` Q How so?
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` A Well, as I said, both of these strategies
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`strive to maintain a certain state of charge. The third
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`strategy would have some kind of a depletion to the
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`charge. I guess you could do that with either one. You
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`could start with one or the other and modify it to arrive
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`at that.
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` Q Explain, for the record, the thermostat
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`strategy, the thermostat extreme strategy. Strike that.
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` Explain for the record the extreme thermostat
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`strategy.
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` MR. GUARNIERI: Object to the form of the
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` Q What about the extreme follower strategy? How
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`does that work?
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` MR. GUARNIERI: Object to the form of the
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`question.
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` A That strategy is the controller -- or the
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`strategy itself commands the APU to follow the actual
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`real torque whenever possible.
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` Q And the APU is the engine. Right?
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` A Yes.
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` Q Which of these two extremes has more engine
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`transients?
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` MR. GUARNIERI: Objection. Vague.
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` A That would depend on the upper and lower
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`question as vague.
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` A And you said the extreme thermostat strategy?
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` Q Yes.
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` A Okay. I'm just looking to find Anderson's
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`explanation, to be most accurate.
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` Okay. She describes the thermostat as the --
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`the thermostat algorithm is used to command an APU, which
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`is what she's referring to as an engine -- what she's --
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`auxiliary power unit, so her engine. You turn the
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`auxiliary power unit on to a constant power level when
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`the state of charge of the load-limiting device is below
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`a certain lower threshold.
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` Q Where are you reading?
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`threshold of the thermostat. If those were set very
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`close, that would create more transition.
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` So the thermostat algorithm could have a wide
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`variety of trance audience based on how the designers
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`choose to calibrate the system.
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` Q If the upper and lower thresholds and the
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`therm motors are not set very close, then you agree that
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`the follower extreme is going to have more transients
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`than the thermostat extreme?
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` MR. GUARNIERI: Same objection.
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` A I would say it would have more engine speed
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`transients.
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` A I'm on page 5 of 9 of the Anderson paper. I
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`believe it's -- 67 is another page number on it.
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` Q So please, again, describe the extreme
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`thermostat strategy.
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` A All right. The reference to a thermostat is
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`how a thermostat works in the home. But, basically, when
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`the stated charge drops to a certain level, the auxiliary
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`power unit is turned on to a constant power level, and
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`then it switches off again when the state of charge
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`exceeds an upper threshold.
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` Q So the thermostat strategy does not strive to
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`maintain a constant state of charge. Correct?
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` Q What are those engine speed transients caused
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`by?
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` A Well, engine speed would increase as a result
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`of opening the throttle in the engine. And it could also
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`result from closing the throttle because a decrease in
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`RPM is also an engine speed transient.
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` Q In the case of an increase, why is the engine
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`speed -- strike that.
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` In the case of an increase, why is the
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`controller opening throttle in the engine?
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` A Well, it wouldn't necessarily be a controller.
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`It could be the operator opening the throttle.
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` Q Okay. So let's --
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`Pages 21 to 24Pages 21 to 24
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`FORD 1131
`
`

`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 8, 2015April 8, 2015
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` A But --
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` Q Just -- since you said that --
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` MR. GUARNIERI: Do you want him to answer, let
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`him finish?
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` MR. ANGILERI: Not really. I'm going to
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`clarify so he doesn't waste our time.
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` Q Let's assume that this -- that we're talking
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`about a vehicle that's operated by a controller. Can you
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`accept that assumption?
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` A I can, although I think Anderson doesn't
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`specify a controller. But if you want to move more
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`generically, that's fine.
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`acceleration, and it's pretty transparent to most drivers
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`whether they're getting power or torque or what's going
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`on.
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` Q Do you agree that in order to accelerate the
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`vehicle, the vehicle is going to have to provide
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`additional torque at the wheels?
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` MR. GUARNIERI: Objection. Vague.
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` A I mean, I think you can talk about that in
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`aspects of power or torque.
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` Q So whether the driver knows it or not, they're
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`effectively requesting additional power and torque at the
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`wheels in order to accelerate the vehicle when they push
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` Q Let's do that. Because engine controllers
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`the pedal down. Do you agree with that?
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`were common at the time of Anderson, or at least they
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`were known to a person of skill in the art at the time of
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`Anderson. Correct?
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` A Well, engine controllers that -- so you're
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`talking about an engine controller that controls the
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`throttle?
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` Q Yes.
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` A Yeah. And they weren't in widespread usage,
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`but they were known on a prototype basis.
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` Q Okay. So let's go back to my question.
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` In the case of an engine speed increase for
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`the follower, extreme follower method -- strike that.
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` A Right. And it's power that they're
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`requesting, because depending on the engine RPM, the
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`torque can be, you know, varied or limited.
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` Q At the wheel, they're asking for power and
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`torque. Do you agree?
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` A I would say the driver is really asking for
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`power, and you can resolve that into torque and speed the
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`same way that Bumby does his calculations.
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` Q If there's no transmission or there's no
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`change in the gear in a transmission, then when the
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`driver pushes the pedal down, the driver is effectively
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`asking for more power and more torque. Do you agree with
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`Page 28
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`Page 26
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` In the case of an engine speed increase for
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`the follower method, why is the controller opening the
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`throttle in the engine?
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` MR. GUARNIERI: I'm going to object as vague.
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` A Well, that would also be in response to the
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`driver command.
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` Q What kind of command?
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` A Accelerator pedal. The operator -- the
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`follower strategy is very similar to how a conventional
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`vehicle operates, since it's trying to respond to the
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`actual wheel power, which comes from a -- you know, the
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`operator command.
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`that?
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` A Well, I can envision a situation where the
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`flat torque curve; somebody may increase the accelerator
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`pedal position and the torque remains the same over a
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`time period, but the engine speed is increasing. So the
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`power is going up, but the torque is staying the same.
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` So it's really more of a power-based demand.
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` Q And what if you're not at the point on the
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`torque curve where the torque flattens out? If you're on
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`the point of the torque curve where the torque is
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`increasing, then would you agree that when the driver
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`tips in with the accelerator pedal and tries to
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`accelerate the vehicle, the driver is requesting more
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` Q The operator is depressing the pedal?
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` A Pressing or releasing the pedal, yes.
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` Q In the case of an increase in speed, he's
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`probably pressing the pedal. Right?
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` A Yes.
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` Q And the driver is asking for more torque from
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`the engine. Right?
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` A Or power. I would say generally the driver is
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`after power because there's a speed element to the
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`engine.
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` Q At a given speed, the driver is going to be
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`asking for both, more power and more torque?
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` A The driver in reality is just requesting
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`torque at the wheel?
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` MR. GUARNIERI: Objection. Vague and object
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`to the form.
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` A Yeah. The torque is a result of the driver
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`command, but it's a coincidence if it goes up or down or
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`stays the same.
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` But in all considerations, when somebody
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`applies the accelerator, they're going to get, you know,
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`increasing power regardless of the torque going up and
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`down.
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` Q At the moment in time when