FORD MOTOR COMPANY v. PAICE, LLC, ET AL.
`
`NEIL HANNEMANN
`
`April 7, 2015
`
`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 1132
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`

`
`
`NEIL HANNEMANNNEIL HANNEMANN
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`April 7, 2015April 7, 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
` BROOKS KUSHMAN, PC
` 1000 Town Center
` 22nd Floor
` Southfield, MI 48075
` (248) 226-2913
`
` - and -
`
` THOMAS W. YEH, ESQUIRE
` LATHAM & WATKINS, LLP
` 555 Eleventh Street, NW
` Suite 1000
` Washington, DC 20004
` (202) 637-1039
`
` A P P E A R A N C E S C O N T I N U E D
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`Page 4
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`ON BEHALF OF THE PATENT OWNER:
` BRIAN J. LIVEDALEN, ESQUIRE
` LINDA LIU KORDZIEL, ESQUIRE
` FISH & RICHARDSON
` 1425 K Street, NW
` 11th Floor
` Washington, DC 20005
` (202) 783-5070
`
`ALSO PRESENT:
` Frances Keenan, Paice LLC
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` FORD MOTOR COMPANY, :
`
` Petitioner, :
`
` v. : IPR Case No:
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` PAICE LLC & ABELL FOUNDATION, : IPR2014-00571
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` INC., :
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` Patent Owner. :
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` :
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`- - - - - - - - - - - - - - - - -x
`
` Oral Deposition of NEIL HANNEMANN
`
` Washington, DC
`
` Tuesday, April 7, 2015
`
` 9:58 a.m.
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`Job No.: 79874
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`Pages: 1 - 145
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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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`Page 2
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` FISH & RICHARDSON, PC
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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 1132
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`

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`NEIL HANNEMANNNEIL HANNEMANN
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`April 7, 2015April 7, 2015
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`Page 5
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`Page 7
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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 6
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` By Mr. Livedalen 141
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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 8
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` 2 Curriculum Vitae 9
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` 3 U.S. Patent No. 7,104,347 52
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` 4 U.S. Patent No. 5,343,970 52
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` P R O C E E D I N G S
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`hybrid vehicles weren't really a course of study in --
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`that would have been 1981.
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` Q Did you focus at all on hybrid vehicles in
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`your undergraduate work at GMI?
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` A No. I would say I focused more on power train
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`and emissions.
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` Q What experience do you have in the
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`hybrid/electric vehicle area?
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` A Well, I can refer to my declaration.
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`Actually, I think there was a supplemental declaration
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`that has most of my qualifications.
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` But it was more the -- the hybrid vehicle work
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`was probably within the last 10 years, and specifically
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`hybrids, probably the first time I did anything was at
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`McLaren, where I worked on some architecture for hybrid
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`vehicles based on a McLaren product.
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` And then in 2008 I was working at a company
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`called Aptera, where we looked at hybrid concepts, and
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`the patent that I worked on could be applied to a hybrid
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`vehicle.
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` Q Have you ever designed a hybrid vehicle?
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` A Well, I mean, "designed" is a pretty broad
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`term. The work I did at McLaren was design work in the
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`designing the architecture of the hybrid vehicle. So
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`yes, I would say I've designed a hybrid vehicle.
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` MR. ANGILERI: Let's mark as Exhibit 1
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`Mr. Hannemann's declaration.
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`Page 8
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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
`
`BY MR. ANGILERI:
`
` Q Good morning.
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` A Good morning.
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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, what's the extent of your
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`formal education?
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` A Well, I have a bachelor's degree from General
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`Motors Institute. That's the only other degree I have.
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`I've gone to some graduate classes but didn't receive a
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`degree.
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` Q What graduate classes?
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` A Oh, attended some classes at the University of
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`California at Santa Barbara, and when I took a different
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`job and moved away, I just did not -- chose not to
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`complete that course.
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` Q Are any of those graduate classes relevant to
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`the hybrid vehicles?
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` A You know, in 19 -- I mean, other than they
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`were, you know, mechanical engineering classes, but
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` (HANNEMANN Exhibit 1 was marked for
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`identification and retained by counsel.)
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` A Like I said, there's some additional detail of
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`my background in the supplemental declaration, which I
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`don't have with me.
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` Q Supplemental declaration, you said?
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` MR. LIVEDALEN: Objection.
`
` (OFF THE RECORD.)
`
` Q Let's look at -- have you ever worked for Ford
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`Motor Company?
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` A For two years I've worked for Ford Motor
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`Company as a contract employee through a company called
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`Saleen.
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` Q So you've never been a Ford Motor Company
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`employee?
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` A Well, I was a contract employee. It's a
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`little bit of a subtlety, but probably 10 or 15 percent
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`of all Ford engineers are working under contract. The
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`best way to describe it is like a Kelly Girl thing, where
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`your paycheck comes through a different company, but
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`you're called a contract employee. So that would make me
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`an employee of Ford.
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` Q I guess that's your view. But your paycheck
`
`
`
`Pages 5 to 8Pages 5 to 8
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`FORD 1132
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`

`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 7, 2015April 7, 2015
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`Page 9
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`came from Saleen. Right?
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` A Yes.
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` Q So you never got a paycheck from Ford Motor
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`Company?
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` A That's correct.
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` Q What time period were you a contract employee
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`with Saleen but located at Ford?
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` A That was 2002 through 2004.
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` Q How long were you employed at Saleen?
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` A I was at Saleen for four or five years. And
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`two years of that was the time at Ford.
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` Q So did your employment with Saleen start
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` A Well, Saleen had a working relationship with
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`Ford, and Ford, they had a project that Saleen was
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`working on from a subcontract standpoint. And, you know,
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`Ford just requested that I be assigned to them as the
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`chief engineer of that project.
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` Q Who at Ford made that request?
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` A That would have been John Coletti.
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` Q How did you know John Coletti?
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` A I really didn't know John. I think John
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`was -- worked more with other people at Saleen.
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` And I think -- well, possibly other people
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`were involved in that decision. I just -- John Coletti
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`before 2002?
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` A Yes.
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` Q When? Would your CV help?
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` A Yes.
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` MR. ANGILERI: Let's mark this.
`
` (HANNEMANN Exhibit 2 was marked for
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`identification and retained by counsel.)
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` Q So we marked as Exhibit 2 a -- strike that.
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` What is Exhibit 2?
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` A Exhibit 2 is my CV.
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` Q And just for the record, what is Exhibit 1,
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`that thing we marked earlier?
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` A Exhibit 1 is my declaration for IPR 571.
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`is the one I met with who made that request. Other
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`people may have been involved in the decision; it would
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`have been Chris Theodore and possible Neil Ressler.
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` Q So you never met John Coletti, but you know
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`he's the one that requested that you work on the project?
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` A I met him in the process of this project
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`starting up.
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` Q How do you know he asked that you work on the
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`project?
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` A Well, he's the first one that asked me to come
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`to Detroit.
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` Q So he literally spoke to you directly and
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`said, Please come to Detroit?
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` Q Back to Exhibit 2, my question is, when did
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`you work for Saleen?
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` A I started working for Saleen in October of
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`2000.
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` Q And when did you finish working for Saleen?
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` A I was assigned by Saleen to Ford in 2002, and
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`that went through February of 2004.
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` And there's a typo on this CV. So under Ford
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`Motor Company it should be January 2002.
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` Q This says you were at Ford Motor Company
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`from now, as corrected by you, January 2002 through
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`February 2004. Correct?
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` A That's correct.
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` A Yes.
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` Q Gotcha.
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` Where were you before you came to Detroit?
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` A Oh, I was based in Irvine, California.
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` Q That's where Saleen is?
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` A Yes.
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` Q Do you know why Ford wanted somebody from
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`Saleen to come on-site and work with them at that time?
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` A I think that had less to do with Saleen and
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`more to do with my background.
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` Q What about your background gives you that
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`impression?
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` Q And then it says in March 2004 you were at
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`McLaren Automotive?
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` A Correct.
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` Q So were you still employed by Saleen when you
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`were at McLaren or were you now a McLaren employee?
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` A I was an employee of McLaren at that time.
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` Q So just to be clear, you were employed by
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`Saleen from October 2000 through February 2004. Right?
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` A That's -- yeah. And as a contract employee, I
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`was assigned to Ford Motor Company for part of that time.
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` Q How did it come that Saleen assigned you to
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`work at Ford Motor Company?
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` A Just the work I had done on the Dodge Viper at
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`Chrysler was similar type of work that they were looking
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`to do with the Ford GT.
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` Q And what work is that?
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` A Well, it was more the project, that it was
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`going to be a low-volume, high-performance, two-seat
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`sports car. So the Viper and Ford GT were similar
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`vehicles from that viewpoint.
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` Q In your declaration, which is Exhibit 1 in the
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`deposition and Exhibit 2002 in the IPR, paragraph 22 has
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`a definition of a person of skill in the art.
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` Do you see that?
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` A Yes.
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`
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`Pages 9 to 12Pages 9 to 12
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`FORD 1132
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`

`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 7, 2015April 7, 2015
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`Page 13
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` Q Where did that come from?
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` A Oh, that was, you know, my definition in
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`consultation with attorneys here at Fish & Richardson.
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` MR. LIVEDALEN: I would counsel the witness
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`not to reveal any substance in any communication between
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`the client and himself.
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` Q How did you come up with this definition?
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` A Well --
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` MR. LIVEDALEN: Same instruction.
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` A I guess for my part of it, it seems that I had
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`a number of jobs where I had to build teams from scratch
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`and hired quite a few engineers. At Chrysler, they had
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`working through various jobs and programs. You know, at
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`least two but three years was about the time frame it
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`takes to get, you know, a full understanding of how
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`vehicles and systems and components all interrelate with
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`each other.
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` Q What were you doing in 1998, September of
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`1998?
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` A I was working at Chrysler and I was...I was
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`either in the small car platform as a vehicle development
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`specialist, and I think during that year I transitioned
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`to being the supervisor of the aerothermal lab.
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` Let me correct that. I would have been the
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`programs where I mentored engineers, and I was pretty
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`suspension design supervisor job, transitioning to the
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`active in that.
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` So I had a lot of experience with engineers
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`out of school, and then how a career might develop and
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`transition. And I understood and had really my own idea
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`of what an engineer should be doing after 5 or 10 years,
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`and the best way to gain experience.
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` So -- you know, that experience that I had, I
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`used that to determine, you know, what type of experience
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`that someone in this time frame would have.
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` Q What time frame?
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` A Well, I guess you're looking at September of
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`1998 as the time frame for this particular IPR.
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`aerothermal development supervisor job.
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` Q Are you looking at something on your CV to
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`help you with that answer?
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` A Yes.
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` Q Where are you looking?
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` A Under my DaimlerChrysler corporation
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`experience, which was from '89 until 2000.
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` Q Just as a note, this Chrysler corporation has
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`a typo as well. Right? It should be 1982 to 1988?
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` A Yes. That's correct.
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` Q So in the DaimlerChrysler section of your CV,
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`you list these various jobs. And you said in 1998 you
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`Page 16
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`Page 14
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` Q Did your conversations with Fish & Richardson
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`attorneys influence your analysis of the definition of a
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`person of skill in the art?
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` MR. LIVEDALEN: Same instruction.
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` A Really, the conversations, I just -- you know,
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`I was told that a definition was needed, so I would say
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`that I wasn't influenced.
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` Q Were you aware of the definition of skill in
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`the art of a -- strike that.
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` Were you aware of the definition of a person
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`of skill in the art that was put forth in the litigation
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`against Toyota?
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`were transitioning from what to what?
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` A In 1998, the year it started, I was the
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`suspension design supervisor. And I think during that
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`year I transitioned to becoming the aerothermal
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`development supervisor.
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` Q You were suspension design -- so these aren't
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`in chronological order, then, obviously. Correct?
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` A Correct. Correct.
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` Can I add just a little bit more to the
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`conversation we had about the person of skill in the art?
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` Q Sure.
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` A Because at Chrysler we had a two-year program
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`where we trained engineers out of school. So if you came
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` MR. LIVEDALEN: Objection. Vague.
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` A No, I wasn't aware of that. I probably was
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`only aware of the definition in Dr. Davis and Stein's
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`declarations. That's all I had really seen at that
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`point.
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` Q At what point?
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` A The point where I came up with this
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`definition.
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` Q So you're not aware of any definition that
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`Paice offered in litigation?
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` A No.
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` Q Why did you pick three years of experience?
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` A Well, I had students coming out of school and
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`into that program with a bachelor's degree, it was a
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`two-year program, and the reason I went three years is
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`because if a company didn't have an organized program, it
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`might take a little longer for an engineer to gain that
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`type of experience. So that was -- the Chrysler program
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`was one thing that influenced my decision.
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` Q As of 1998, had you worked on any hybrid
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`electric vehicles?
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` A Well, yes. I had done -- not as a full-time
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`job, but Chrysler had a program, it was a race car called
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`the Chrysler Patriot, and I was involved in what we call
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`fresh eyes reviews, which -- in a fresh eyes review is
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`Pages 13 to 16Pages 13 to 16
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`FORD 1132
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`NEIL HANNEMANNNEIL HANNEMANN
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`April 7, 2015April 7, 2015
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`where you take people that are not directly working on a
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`program, give them a design review presentation just to
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`have another viewpoint. So I participated in the Patriot
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`program from that standpoint.
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` Q Anything else?
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` A That was probably -- there may be something
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`else in that supplemental declaration. I just don't
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`recall at this time every little job or task I may have
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`done.
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` Q The last sentence of paragraph 22 says, quote,
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`"I note that the differences between the level of skill
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`above and the level of skill defined by Dr. Davis are
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`how the systems interrelate into a total vehicle is the
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`important experience.
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` Q Why?
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` A Well, because systems do have
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`interrelationships, and you can't consider a system in a
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`vacuum. You need to analyze it all as it relates to the
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`total vehicle.
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` Q What systems are you talking about?
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` A Well, I typically break it down to -- I mean,
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`at a higher level, I typically look at five major areas,
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`and then it can be broken down into probably 70 different
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`systems in a vehicle.
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`minor and do not affect my opinions set forth below," end
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` Q What are the five major areas?
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`quote.
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` Do you see that?
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` A Yes.
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` Q Why do the differences in your respective
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`opinions on the level of skill in the art not affect your
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`opinions in this IPR?
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` A Well, I guess I have to refresh my memory on
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`Dr. Davis's definition, because I don't recall that as I
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`sit here right now.
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` Q Do you know why the differences didn't affect
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`your opinions in this IPR?
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` A Well, because they were -- like I say, they
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` A Well, the five major areas are body, interior,
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`chassis, power train, and electrical.
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` Q Which major area is relevant to the '347
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`patent?
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` MR. LIVEDALEN: Objection. Vague. Calls for
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`legal conclusion.
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` A It would have, probably in order of -- I mean,
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`power train and electrical are two that are probably the
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`major ones. Then probably there is some chassis
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`involvement. And the body involvement may be related to
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`how the parts are packaged, and probably, you know,
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`interior may be if the -- if how somebody may design a
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`were relatively minor, I think, and he -- if I recall
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`correctly, he had an option for an advanced degree as a
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`trade-off for work experience.
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` Q And so you don't see that as significant?
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` A No. I would say the difference there is
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`actually less than the difference, say, between the car
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`companies. A company that has a more organized training
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`program may develop people of skill in the art in less
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`time than a company that doesn't have an organized
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`program.
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` Q All right. With respect to your definition of
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`a person of skill in the art, what can that person do, in
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`the way of solving problems?
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`system, they put a switch in, if there were some type of
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`switch. And I guess that's more my opinion on how a
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`hybrid system would fit in; maybe less as it relates to
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`the patent, I think.
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` The patent, you could probably design
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`different systems or apply to the patent to different
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`systems. I don't think the patent really gives you
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`enough to, you know, design the entire hybrid system.
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` Q Why not?
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` A Well, for example, the engine. It doesn't
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`specify that the engine should be a gas engine or diesel
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`engine. So there's design choices like that that would
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` MR. LIVEDALEN: Objection. Vague and calls
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`for speculation.
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` A Yeah, well, it depends on what exactly the job
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`is. But during that time frame, engineers would gain
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`experience that lets them understand how the different
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`systems on a vehicle interrelate with each other, and
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`that in general is the important thing.
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` Now, they'll have different detail skills,
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`depending on if their particular line of work is then
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`focused on a system, you know, from air conditioning to
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`suspension systems to brake systems. Those are all
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`different specialties. But I think the understanding of
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`be left open to the people designing the vehicle, even
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`following the patent.
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` Q Is there any other area where the patent
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`doesn't give you enough to design the entire system?
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` MR. LIVEDALEN: Objection. Vague. Calls for
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`legal conclusion.
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` A Yeah. And I don't think -- I'm not sure I'd
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`say the patent doesn't have enough that you couldn't
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`design the system. But there are design elements that
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`the patent is not specific about. It's specific about
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`certain things, but not everything that you would use to
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`design the system.
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` Q So what sort of problem-solving capacity or
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`Pages 17 to 20Pages 17 to 20
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`FORD 1132
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`

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`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 7, 2015April 7, 2015
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`capability does the person of ordinary skill have?
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` MR. LIVEDALEN: Objection. Vague.
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` A Specifically, it varies on their area. But in
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`the time frame that somebody is gaining experience, they
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`would have been trained or exposed or practiced some of
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`the problem-solving techniques that the automotive
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`companies typically follow.
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` Q What are those?
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` A Well, they're different from company to
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`company. But -- you know, they generally fall under some
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`type of a root cause analysis, which would be an overall
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`type of problem-solving technique. Ford had developed
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`the -- Ford's 8D process to go through analyzing that.
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`And it involves analyzing the design and includes the
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`manufacturing process and -- you know, help you determine
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`if it's a design problem or a manufacturing problem or
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`whatever other type of problem it might be.
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` Q How would a person of ordinary skill decide
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`what sort of data to gather in a root cause analysis?
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` MR. LIVEDALEN: Objection. Vague.
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` A Yeah. It probably depends on what type of
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`system they're working on or what type of problem.
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` Q What if you were trying to decide how to run
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`an engine efficiently? What sort of data would you
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`what we call an 8D process, and Ford and other companies
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`gather? What sort of data would a person of ordinary
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`used a process called the 5 Whys. These are just ways to
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`help organize the problem solving in a logical type of
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`format.
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` Q So a person of skill in the art would solve
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`problems in a logical way?
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` MR. LIVEDALEN: Objection. Vague.
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`Mischaracterizes his previous testimony.
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` A I think there -- you know, the point of the
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`processes are to, you know, not only provide logic but
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`provide some consistency among the different
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`problem-solving techniques.
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` Q Would a person of skill in the art approach
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`skill gather?
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` MR. LIVEDALEN: Objection. Vague.
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` A Yeah, and you're jumping from problem solving
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`to design, so it's not really -- I don't think it's
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`really the same question.
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` Q If a person of ordinary skill in the art is
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`trying to decide how to run an engine efficiently, what
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`sort of data would that person gather?
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` A Okay. And that's different than problem
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`solving. Because when you design a system, you design
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`the system and you make decisions about your design, and
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`you -- you know, the problem -- the root cause analysis
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`problems, in your opinion, in a logical way?
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` MR. LIVEDALEN: Same objections. Asked and
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`answered.
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` A Well, you know, I can't account for how every
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`engineer would approach their job, but I certainly think
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`they would have been exposed to the problem-solving
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`techniques and processes.
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` Q And in your opinion, would a person of
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`ordinary skill in the art relative to the '347 patent
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`approach problems and attempt to solve problems in a
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`logical way?
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` MR. LIVEDALEN: Same objections.
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` A Yeah. I think that someone with engineering
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`comes later once problems occur. So you have to get
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`through the process to a certain point before you're
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`actually solving problems.
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` Q Can you answer my question, please?
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` A Okay. Can you repeat the question, then?
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` Q Sure. If a person of ordinary skill in the
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`art is trying to decide how to run an engine efficiently,
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`what sort of data would that person gather?
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` A Well -- again, in trying to run an engine, I'm
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`going to take it more as you're designing some type of
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`engine control system.
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` I mean, trying to make an engine run more
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`background, someone of skill in the art would approach it
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`in a logical fashion, yes.
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` Q You mentioned a root cause analysis. Can you
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`explain what that is, please?
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` A Well, I mean, it sometimes covers a lot of
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`different techniques. But basically, it's a way to help
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`focus on what is the actual problem. So it has to do
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`with gathering data and performing analysis to make sure
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`that you really have gotten to the actual solution.
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` Q Can you give me an example?
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` A Well, probably one we used on the Ford GT is
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`we had failures of a suspension component, and so we used
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`efficiently, like you said, could be either a
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`problem-solving exercise, or it could be what's called
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`continuous improvement, where somebody is taking an
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`existing design and trying to improve it. Or it could be
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`a ground-up design. And you would approach them
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`differently, depending on what you're trying to do.
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` Q Just for economy of language, when I talk
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`about a person of ordinary skill in the art, I'm talking
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`about your definition of a person of ordinary skill in
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`the art as it applies to this IPR. Okay?
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` A Yes.
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` Q Is that how you've understood my questions for
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`the last 5 or 10 minutes?
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`
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`Pages 21 to 24Pages 21 to 24
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`FORD 1132
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`

`
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`NEIL HANNEMANNNEIL HANNEMANN
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`April 7, 2015April 7, 2015
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`Page 25
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`Page 27
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` A Yes.
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` Q Is a person of ordinary skill in the art good
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`at solving problems?
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` MR. LIVEDALEN: Objection. Vague.
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` A Yeah, I would say it covers the whole range.
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`Some may inherently be good, and some people may never
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`become good at solving problems.
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` Q Well, this hypothetical person of ordinary
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`skill in the art, are they somewhere in the middle of
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`that range of solving problems?
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` MR. LIVEDALEN: Same objection.
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` A I think that it covers the range. I mean,
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` Q Do you think that's especially likely if the
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`related references are for the same project?
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` MR. LIVEDALEN: Objection. Vague. Calls for
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`speculation.
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` A Yeah, and I'm not sure a person of skill in
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`the art would know if they're all related to the same
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`project or not.
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` Q What if the first reference says they are?
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`Don't you think that person would be especially likely to
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`consult them?
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` MR. LIVEDALEN: Same objections.
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` Q Together?
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`when we start breaking down what a person of skill in the
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`art can do from very specific standpoints like that --
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`it's just like somebody who specialized in heating,
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`ventilation, and air conditioning may not be as adept at
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`suspension design as somebody who learned more about
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`suspension design.
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` So there are a lot of variables, and the skill
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`at problem solving depends on if a particular person had
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`practice or experience, or if after three years it's the
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`first time they're trying to solve a problem.
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` Q If a person of ordinary skill in the art is
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`experienced in engine controls and encounters a problem
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`with emissions, is that person likely to consult someone
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` A I think they would consider them, and then
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`they would make decisions based on if those references
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`are appropriate.
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` Q Does a person of skill in the art understand
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`that if you're comparing two things, they have to be in
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`the same units?
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` A I would think that would be something they
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`would understand, yes.
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` Q If a person of skill in the art is reviewing a
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`reference and there are two portions of that reference
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`that relate to one another, do you agree that the person
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`of skill would read them together and consider those two
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`related portions together?
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`who has knowledge in emissions?
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` MR. LIVEDALEN: Objection. Vague.
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` A Yeah. Typically, somebody of skill in the
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`art, as we've defined it here, is going to have a
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`supervisor or a manager, somebody who they would be
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`working with on a daily basis. So somebody of skill in
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`the art would have -- at least a large auto company would
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`have the kind of support and knowledge depth to rely on.
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` Q If a person of skill in the art is trying to
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`reduce emissions, and that person encounters some
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`teaching that helps reduce emissions, do you think that
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`person would consider it and apply it if it helps?
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` MR. LIVEDALEN: Objection. Vague. Compound.
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` MR. LIVEDALEN: Objection. Vague. Calls for
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`speculation.
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` A I mean, it just depends on if it applies to
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`what they're actually looking at.
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`BY MR. ANGILERI:
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` Q So if these two portions of a reference apply
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`to what they're looking at, then the person of skill is
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`going to consider both portions of that reference.
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`Right?
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` A Well, I think they look at both of them in the
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`totality, and, you know, make a judgment based on that.
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` Q Does a person of skill in the art -- strike
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` A Yeah, I think they would consider whether it
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`applies, and if it is applicable, then they would
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`consider that. And it could be that there's some
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`emission reduction that might apply to, for example,
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`diesel engines that you wouldn't apply to gas engines.
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` Q If a person of skill in the art is consulting
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`past publications that are relevant, and notices that
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`they cite to other related publications, is that person
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`likely to consult those related publications?
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` MR. LIVEDALEN: Objection. Vague.
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` A Yeah, if they feel that they're related, then
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`I think that they would consult them.
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`that.
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` Did a person of skill in the art know what a
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`series hybrid is?
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` A I would say yes. Even though in September of
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`'98, there was -- you know, the definitions weren't clear
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`about series and parallel as they are now. But there's
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`some interpretation, particularly in that time.
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` Q That was -- my next question, was, would a
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`person of skill in the art also have known what parallel
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`and series parallel systems are?
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` A They would have. And they would have -- b