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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` __________________________________________
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` ________________________________________
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` VOLKSWAGEN GROUP OF AMERICA, INC.,
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` Petitioner,
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` v.
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` EMERACHEM HOLDINGS, LLC,
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` Patent Owner.
`
` _________________________________
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`10
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` Case IPR2014-01555
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` Patent 5,451,558
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`13
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` _________________________________
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` DATE: Thursday, September 3, 2015
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` TIME: 8:47 a.m.
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`14
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` PLACE: Luedeka Neely
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` Knoxville, Tennessee
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` DEPOSITION OF MARK CROCKER, PH.D.
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` Taken on behalf of the Petitioner, before Anna R. Schenck,
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`a licensed court reporter and notary public in and for the
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`state of Tennessee, pursuant to Notice for Deposition in the
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`above cause.
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`212-279-9424
`
`Veritext Legal Solutions
`www.veritext.com
`
`Volkswagen Ex. 1056
`Volkswagen v. EmeraChem
`IPR2014-01558
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` __________________________________________
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ________________________________________
`
` VOLKSWAGEN GROUP OF AMERICA, INC.,
`
` Petitioner,
`
` v.
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` EMERACHEM HOLDINGS, LLC,
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` Patent Owner.
`
` _________________________________
`
`10
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` Case IPR2014-01555
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` Patent 5,451,558
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`11
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`12
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`13
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` _________________________________
`
` DATE: Thursday, September 3, 2015
`
` TIME: 8:47 a.m.
`
`14
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` PLACE: Luedeka Neely
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` Knoxville, Tennessee
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` DEPOSITION OF MARK CROCKER, PH.D.
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` Taken on behalf of the Petitioner, before Anna R. Schenck,
`
`a licensed court reporter and notary public in and for the
`
`state of Tennessee, pursuant to Notice for Deposition in the
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`above cause.
`
`212-279-9424
`
`Veritext Legal Solutions
`www.veritext.com
`
`Volkswagen Ex. 1056
`Volkswagen v. EmeraChem
`IPR2014-01558
`
`1
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`Page 2
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` APPEARANCES
`For the Petitioner: Volkswagen Group of America, Inc.
` STEVEN F. MEYER, Esquire
` and JOHN F. SWEENEY, Esquire
` Locke Lord, LLP
` 3 World Financial Center
` New York, New York 10281
` Phone: (212) 415-8535 Fax: (212) 303-2754
` E-mail: Smeyer@lockelord.com
`
`For the Patent Owner: EmeraChem Holdings, LLC
` JACOBUS C. RASSER, Esquire
` Rasser De Haan
` Beethovenstraat 105 B
` 1077 HX Amsterdam, Netherlands
` Phone: +31 6 5245 2741
` E-mail: Krasser@rasserdehaan.com
`
`For the Patent Owner: EmeraChem Holdings, LLC
` MICHAEL J. BRADFORD, Esquire
` Luedeka Neely
` 900 South Gay Street, 1504 Riverview Tower
` Knoxville, Tennessee 37902
` Phone: (865) 546-4305 Fax: (865) 523-4478
` E-mail: MBradford@luedeka.com
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` I N D E X
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`Page 3
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`Witness Direct Cross Redir.
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`By Mr. Meyer. . . . . 5. . . . . . . . . . . . . . . 111
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`By Mr. Rasser. . . . . . . . . . . . . 100
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` E X H I B I T I N D E X
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`Description Page
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`Exhibit 1052, Wan et al patent # 5,254,519 . . . . . 48
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`Exhibit 1053, WO 93/07363 PCT/JP92/01279 Diagram . . 63
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`Exhibit 1054, Calculation by Dr. Crocker . . . . . . 68
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`Exhibit 1055, Canadian Patent, James Hoekstra,
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` Application No. 190,284 Filed 740116 . . . . . . 70
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` DOCUMENTS TO BE PRODUCED
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` (None Requested)
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` PREVIOUSLY-MARKED EXHIBITS REFERENCED
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`NUMBER PAGE
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`Volkswagen Exhibit 1001a in IPR2014-01554.............. 7
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`Volkswagen Exhibit 1001a in IPR2014-01557.............. 8
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`Emerachem Exhibit DECLARATION in IPR2014-01555......... 17
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`Exhibit 1001a in IPR2014-01555......................... 31
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` PREVIOUSLY MARKED EXHIBITS (Continued...)
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`Exhibit 1002a in IPR2014-01555.......................... 52
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`Volkswagen Exhibit 1004b in IPR2014-01555............... 55
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`Hoekstra patent Exhibit 1005a in IPR2014-01555.......... 65
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`Volkswagen Exhibit 1006a in IPR2014-01555............... 70
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`Inui patent Volkswagen Exhibit 1007b in IPR2014-01555... 74
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`Stiles Patent Exhibit 1008a in IPR2410-01555............ 76
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`'758 Patent Volkswagen Exhibit 1001a in IPR2014-01558... 79
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`DECLARATION in Emerachem Exhibit 2004 in IPR2014-01558.. 81
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`Hirota Patent Volkswagen Exhibit 1006a in IPR2014-01558. 83
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`Takeshima Patent Exhibit 1007a in IPR2014-01558......... 90
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`Stiles Patent Volkswagen Exhibit 1009a in IPR2014-01558. 92
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`'558 Patent Exhibit 1003a in IPR2014-01558.............. 96
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`'911 Patent Volkswagen Exhibit 1001a in IPR2014-01556... 97
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`Emerachem Exhibit 2007 in IPR2014-01556................. 97
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`Kanazawa Patent Volkswagen Exhibit 1008 in IPR2014-01556 99
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` MARK CROCKER, PH.D.,
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`105 Falcon Court, Georgetown, Kentucky 40324, having been first
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` duly sworn, was examined and testified as follows:
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`Page 5
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` (TIME NOTED 8:47 A.M.)
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` EXAMINATION
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`BY MR. MEYER:
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` Q. All right, Dr. Crocker, my name is Steve Meyer and I
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`represent Volkswagen in this matter and I will be taking your
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`deposition today. Have you ever had your deposition taken
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`before?
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` A. No, I have not.
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` Q. I assume that your counsel has or counsel for
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`EmeraChem has explained the ground rules of the deposition to
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`you?
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` A. Yes.
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` Q. I will be asking the questions and you'll respond to
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`my questions. If you need a break, just please say so and we
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`will take a break. Is there any reason why you cannot give
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`complete and accurate testimony today, such as any medications?
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` A. No.
`
` Q. Okay. Were you ever employed by Goal Line
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`Environmental Technologies or any of its related entities?
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` A. No.
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` Q. Have you ever been employed by EmeraChem or any of its
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`related entities?
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` A. No.
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` Q. Has any of your research work ever been funded by Goal
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`Page 6
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`Line Environmental Technologies?
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` A. No.
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` Q. Or same question with respect to EmeraChem.
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` A. Also no.
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` Q. When were you retained by EmeraChem in connection with
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`IPR petitions filed by Volkswagen?
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` A. I have to think a moment. Would have been about, I'm
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`going to say, eight months ago, something like that.
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` Q. So it was before -- before Volkswagen filed its --
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` MR. MEYER: Scratch that.
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`BY MR. MEYER:
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` Q. Who first approached you about being retained in
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`connection with the IPR petitions?
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` A. Michael Bradford.
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` Q. And what did he say to you?
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` A. He outlined in very broad detail that there was a case
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`involving two companies in the area of automotive catalysis and
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`would I be interested in functioning as an expert witness.
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` Q. Okay. What were you given to review or analyze at
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`that time, if anything?
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` A. Initially, I was just given the three EmeraChem
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`patents.
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` Q. Okay. You were not given five patents?
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` A. I think later I was given two additional patents, but
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`I was not actually asked to review them.
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` Q. Okay. Let me give you these patents.
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` MR. MEYER: I'd like to place before the witness
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` what has been previously marked as Volkswagen Exhibit
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` 1001A in IPR2014-01554.
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` (DOCUMENT HANDED TO WITNESS FOR REVIEW)
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` (PREVIOUSLY MARKED VOLKSWAGEN EXHIBIT 1001A IPR2014-01554
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` REFERENCED)
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` (DOCUMENT HANDED TO ATTORNEY)
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`BY MR. MEYER:
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` Q. Was this one of the patents that you were subsequently
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`given?
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` A. I believe it was, yes.
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` Q. Were you told why you were not given this particular
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`patent along with the three patents that you were originally
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`given?
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` A. I was told that they were germane to the case, but
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`that's all.
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` Q. Did you spend any time reviewing the '307 patent?
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` A. No, I did not. I was told to review the first three.
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` Q. Okay. I'd like to give you what was previously marked
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`as Volkswagen Exhibit 1001A in IPR2014-01557.
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` (DOCUMENT HANDED TO WITNESS FOR REVIEW)
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` (DOCUMENT HANDED TO ATTORNEY)
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` (PREVIOUSLY MARKED VOLKSWAGEN EXHIBIT 1001A IN IPR2014-01557
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`Page 8
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` REFERENCED)
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`BY MR. MEYER:
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` Q. Was this patent among the three patents that you were
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`originally given or one of the two that you were subsequently
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`given?
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` A. It was among one of the two that I was subsequently
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`given.
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` Q. Did you spend any time reviewing this patent?
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` A. No, I did not.
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` Q. Were you ever told why you were not asked to review
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`this patent?
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` A. To the best of my knowledge, no.
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` Q. What did you do when you received these two patents,
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`the '307 and the '346 patent; what did you do with them?
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` A. I printed them out, put them in my pile and just put
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`them to one side in case I was asked to review them.
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` Q. But, again, you never reviewed them?
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` A. I did not review them, no.
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` Q. Okay. How much time did you spend reviewing the other
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`three patents?
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` A. In total, I would have billed probably -- do you mean
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`the other three patents or all of the other related documents
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`to this case?
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` Q. Let's break it out. First, just reviewing the three
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`patents.
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` A. Probably initially two to three hours.
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` Q. Two to three hours each or two to three hours for the
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`Page 9
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`total of the three?
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` A. Total.
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` Q. Okay. Now, how much time did you spend with the
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`ancillary documents related to those three patents?
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` A. Probably 30 hours.
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` Q. How much have you charged EmeraChem in dollars for
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`your involvement to date?
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` A. Approximately $10,000.
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` Q. Okay. Now, you said that you were retained about
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`eight months ago, correct?
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` A. Correct, give or take a couple of months.
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` Q. Okay. And this was before Volkswagen filed its
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`response? I mean, before -- yes, before Volkswagen filed its
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`papers?
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` A. No, because I sub-- well, I did subsequently see the
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`Volkswagen papers, so I'm not sure if the first contact was
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`just before or just after that.
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` Q. Okay. I'm sorry. Now, did you receive Volkswagen's
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`petition along with the three patents when you first received
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`the three patents?
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` A. Initially, I just received the first three patents.
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` Q. And were you retained just for the IPR or for the
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`litigation as well?
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` A. My understanding, I was retained for the IPR.
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` Q. Not for the litigation?
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` A. Well, perhaps I should ask for clarification here.
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`How are you defining "litigation" as opposed to the IPR?
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` Q. Sure. This proceeding was precipitated by a Complaint
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`for patent infringement that was filed by EmeraChem in the
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`Tennessee District Court. I'm referring to that as "the
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`litigation." Subsequent to that, Volkswagen filed five
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`petitions with the patent office, so a different venue, so the
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`litigation is before the district court, the IPRs are before
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`the patent office. So my question is, were you also retained
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`as an expert in connection with the litigation before the
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`Tennessee District Court?
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` A. No. My understanding was that I was retained for the
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`IPR.
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` Q. Okay. What did you do to prepare for this deposition?
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` A. I met with Dr. Rasser for about three hours last week
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`in Oxford in the U.K., and I spent yesterday with Dr. Rasser
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`and Michael Bradford discussing the mechanics of the process
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`and likely topics of discussion.
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` Q. What "likely topics" for discussion did they raise
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`with you?
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` A. Essentially, we went through the -- my declarations
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`and they highlighted declarations that I have made where they
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`felt that questions would arise.
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` Q. Did you identify any errors in your declarations while
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`Page 11
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`you were reviewing them?
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` A. No, I did not.
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` Q. Okay. Did you review the transcript of the deposition
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`of Tom Girdlestone?
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` A. No, I did not.
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` Q. Did any of EmeraChem's attorneys ever suggest that you
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`try to volunteer any information in response to a question that
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`I may ask during this deposition?
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` A. I'm not sure I understand your question.
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` Q. Okay. Let me put it more simply. Did your attorneys
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`say, 'If you get the chance, volunteer this'?
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` A. I was told that if I -- that if the subject came up,
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`then it would be appropriate to emphasize the proximity of
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`platinum and the NOx absorber phase in LNT catalysts as being
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`important for their proper functioning.
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` Q. And what exactly did they tell you to emphasize?
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` A. Exactly what I said: That for the proper functioning
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`of a lean NOx trap catalyst, it is important that the platinum
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`and NOx absorber phases be in close proximity.
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` Q. What do you mean by "close proximity"?
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` A. That ideally on a molecular level they should be
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`adjoining or as close as possible.
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` Q. Are you comfortable talking about the proximity of the
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`catalyst in the absorber on a molecular level?
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` A. Yes.
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` Q. Have you ever investigated the proximity of the
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`platinum and the absorber on a molecular level?
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` A. Yes.
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` Q. How so?
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` A. In my work I have put quite a lot of effort into
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`characterizing commercially relevant lean NOx trap catalysts.
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`I tried to draw structure-activity correlations. I have looked
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`at the effect of simulated road aging on changes in the
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`microstructure of those catalysts, and I have tried to draw
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`structure-activity correlations for those age catalysts. In
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`other words, trying to understand how aging affects
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`microstructure and, in turn, how that affects the performance,
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`that's to say, the catalytic properties of those catalysts.
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` Q. And how do you determine that? Is it based upon your
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`view through an electron microscope or is it something that
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`I've seen reference to as an acronym - "DRIFT"?
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` A. DRIFTS.
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` Q. DRIFTS. Okay.
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` A. Principally it's done by means of electron microscopy,
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`but there are other techniques as well. Determining the
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`dispersion of the platinum is also an important factor.
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` Q. What do you mean by "dispersion of platinum"?
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` A. The -- put simply, the particle size of the supported
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`platinum on the catalyst.
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` Q. Okay. So you just don't coat the whole thing with
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`platinum? The -- I'm sorry. You just don't coat the alumina
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`support entirely with platinum? It's the platinum atoms are
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`dispersed?
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` A. Correct.
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` Q. And how widely are they dispersed on the alumina
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`support?
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` A. Obviously, that depends on a number of factors. It
`
`depends on the platinum loading, it depends on the efficacy of
`
`the catalyst preparation method, and it depends upon the
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`history of the catalyst, i.e., to the conditions to which its
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`being exposed.
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` Q. Okay. And one of ordinary skill in the art can take
`
`all of those factors into account and determine the dispersion
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`that should be used?
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` A. Well, one -- one aims for the highest dispersion
`
`possible when preparing the catalyst.
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` Q. Why is that?
`
` A. In that way one makes the most efficient use of the
`
`supported platinum.
`
` Q. Because platinum's expensive?
`
` A. Platinum is expensive.
`
` Q. So you want to use --
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` A. You want to use it as efficiently as possible.
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` Q. Is there some measure of dispersion or efficiency so
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`that you can compare one dispersion rate, I guess would be the
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`proper term, to another dispersion rate so that your bosses
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`will make sure that you're making the most effective use of the
`
`expensive platinum?
`
` A. Yes. As part of the standards procedure for
`
`characterizing a catalyst, one typically performs hydrogen chem
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`esorption in which one essentially titrates the surface
`
`platinum atoms with hydrogen, and by measuring the amount of
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`hydrogen taken up one gains an accurate measure of the number
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`of exposed platinum atoms, and from that and knowing the
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`platinum loading, one can calculate the dispersion.
`
` Q. So when you use the phrase that the "alumina support
`
`is coated with platinum," that doesn't mean that the entirety
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`of the alumina is covered by platinum atoms, correct?
`
` A. Exactly. In fact, as a chemist, I would typically not
`
`use the term "coated," but that is the language which is
`
`typically used in many patents.
`
` Q. And what is your understanding of the meaning of the
`
`word "coated" as it is used in those patents that you were
`
`referring to?
`
` A. It depends on the context. If one is talking about
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`coating a wash coat onto a monolithic substrate, then I take
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`that to mean covering the entirety of the monolith. When it's
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`talking about coating a catalyst wash coat with platinum, then
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`I take that to mean depositing a certain amount of platinum on
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`that wash coat.
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` Q. Okay. Now, you were rattling off a number of the
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`factors very quickly and I wrote down "efficacy of
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`preparation." Now, what was the preparation of that you were
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`referring to?
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` A. The preparation of the catalyst containing the
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`supported platinum.
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` Q. Okay. What are the different preparation methods that
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`you had in mind when you said "depends upon the efficacy of
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`those preparation methods"?
`
` A. Well, there are many different preparation methods
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`that can be used for depositing a precious metal such as
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`platinum onto a wash coat surface and some of those are more
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`effective than others. Additionally, the type of support
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`material will also play a role in determining the dispersion of
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`the -- of the platinum.
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` Q. Okay. Let's talk about alumina as the support
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`material. How many different preparation methods are there if
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`alumina is used as the support material?
`
` A. Off the top of my head, one could use incipient
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`wetness impregnation, one could use wet impregnation, one could
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`use deposition precipitation, one could use chemical vapor
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`deposition, one could use physical vapor deposition. Those are
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`the main methods that spring to mind.
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` Q. Okay. And which is the most effective?
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` A. That's going to depend to some extent on whether the
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`conditions for that particular method have been optimized or
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`Page 16
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`not.
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` Q. Um-hmm.
`
` A. So you could put -- you could ask somebody to perform
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`incipient wetness impregnation who is relatively unskilled in
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`the technique and they may not produce a good dispersion.
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`Somebody who is skilled --
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` Q. Okay. I'm sorry to interrupt. Let's -- hopefully
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`this will make it easier. Let's say the person performing the
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`preparation method is one of ordinary skill in the art.
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` A. I would say there's not going to be much difference
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`between incipient wetness impregnation, wet impregnation, or
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`homogeneous deposition precipitation; they will all produce
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`high dispersions.
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` Q. High dispersions. Okay. And it would be within the
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`skill -- it would be within the ability of one of ordinary
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`skill in the art to use any one of those methods that you just
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`mentioned?
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` A. Yes.
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` Q. Okay. And the end result would be the same in terms
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`of the produced product, correct?
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` A. Correct.
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` Q. Okay. I would like to continue this conversation
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`Page 17
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`about your background, but I'd like to use your declaration as
`
`a basis for continuing our questioning.
`
` (DOCUMENT HANDED TO ATTORNEY FOR REVIEW)
`
`BY MR. MEYER:
`
` Q. Okay. I'd like to place before you what has been
`
`previously marked as EmeraChem's Exhibit 2002, which is your
`
`declaration in IPR2014-01555 which is the '558 patent.
`
` (PREVIOUSLY MARKED EMERACHEM EXHIBIT DECLARATION IN
`
` IPR2014-01555 REFERENCED)
`
` MR. BRADFORD: And, Steve, COSA's defending
`
` this. Just to make sure, are we doing one big
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` deposition transcript? Is that kind of the plan?
`
` MR. MEYER: Yes, yes. Yes, it is. I think that
`
` worked out best.
`
` MR. BRADFORD: Yeah, I think.
`
` MR. MEYER: Um-hmm.
`
`BY MR. MEYER:
`
` Q. Okay. Did you prepare this declaration?
`
` A. I did.
`
` Q. Can you please describe the process of how this
`
`declaration was prepared, meaning, did you draft every single
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`word yourself or did it originate with your counsel and then
`
`you made modifications to it or anything in between?
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` A. So my counsel prepared a list of topics on which
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`they -- fairly specific topics on which they wanted me to
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`opine, so I drafted this document, I sent it to Michael
`
`Bradford, he performed some reformatting without altering the
`
`content, and the result is what you see before you.
`
` Q. Were any of your comments deleted from the final
`
`version?
`
` A. No.
`
` Q. Did you address all of the topics that your counsel
`
`sent to you that they wanted to be addressed in a declaration?
`
` A. I did.
`
` Q. Okay. And when was the last time that you reviewed
`
`this declaration?
`
` A. Yesterday.
`
` Q. And, again, you said that you did not identify any
`
`errors in this?
`
` A. No.
`
` Q. Okay. I'd like to direct your attention to Paragraph
`
`No. 11.
`
` A. Um-hmm.
`
` Q. It states that you are listed as a co-inventor on five
`
`patent applications?
`
` A. Um-hmm.
`
` Q. Do you know how many of those applications have issued
`
`as patents?
`
` A. Let's see. I think three of them pertain to the time
`
`I worked for either Shell or Degussa, which case they were
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`issued, I think there is one from the University of Kentucky,
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`which is about to be issued but hasn't yet officially been
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`issued, and I think there's probably one which is still
`
`pending.
`
` Q. Okay. I'd like to direct your attention to Page 21.
`
`And the page numbers are in the lower right-hand corner.
`
` A. Um-hmm.
`
` Q. And at the bottom there's a listing of five patents/
`
`patent applications over the last 10 years.
`
` A. Um-hmm.
`
` Q. Do you see that?
`
` A. Yes.
`
` Q. Okay. Is this a complete and accurate listing of your
`
`applications as of today?
`
` A. I believe so, yes.
`
` Q. Okay. I notice that --
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` A. There was -- I should point out, there was one other
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`application which was abandoned.
`
` Q. Okay. Now, I notice of the five listed patents/
`
`patent applications there's only one US patent that's listed.
`
`Correct?
`
` A. One issued US patent, yes.
`
` Q. Yes. So is that the only issued US patent on which
`
`you are listed as a co-inventor?
`
` A. Off the top of my head, I do not know.
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`
` Q. Okay. I'd like to turn to your c.v. which starts at
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`Page 20
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`Page 15 of this document.
`
` A. Um-hmm.
`
` Q. Okay. Under the second heading, "Professional
`
`Appointments," in the years 2000 through 2002, it says that you
`
`were an R&D chemist manager in the automotive catalyst
`
`division?
`
` A. Um-hmm.
`
` Q. Has most of your experience in NOx abatement been in
`
`the context of automobiles?
`
` A. I would say the majority of it has been in the context
`
`of automobiles.
`
` Q. And within the context of automobiles, is most in the
`
`diesel engine field or the gasoline engine field?
`
` A. Most has been within the diesel field.
`
` Q. Okay. Now, I'd like to direct your attention to now
`
`"professional activities," the third heading.
`
` A. Um-hmm.
`
` Q. And in the year 2002, it says, "Manufacturers of
`
`Emissions Control Association (MECA) Representative on diesel
`
`issues and sulfur fuel effects at the American Petroleum
`
`Institute." What does this mean?
`
` A. So there was a meeting between MECA and the A.P.I. to
`
`discuss forthcoming legislation concerning fuel sulfur levels
`
`in the US and MECA selected or MECA asked for a representative
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`from each of the main catalyst companies to attend that meeting
`
`and essentially explain to the American Petroleum Institute why
`
`this legislation was necessary in the view of MECA to enable
`
`the efficient functioning of automotive catalysts for diesel
`
`applications and, in addition to that, we answered questions
`
`posed by the A.P.I.
`
` Q. What is MECA?
`
` A. MECA is the Manufacturers of Emission Controls
`
`Association, so it's basically an industry body containing
`
`representatives from the main automotive -- well, not just
`
`automotive, but emission control catalyst manufacturers.
`
` Q. Did you keep track of the legislation that impacted
`
`diesel engine emissions?
`
` A. With respect to fuel sulfur emissions or with respect
`
`to EPA-issued emissions concerning mandated levels of
`
`pollutants?
`
` Q. The latter, the EPA mandated emissions.
`
` A. Yes, I did.
`
` Q. Okay. And did that include the standards relating to
`
`particulate matter?
`
` A. Yes, to a broad degree. I wasn't expressly involved
`
`in diesel particulate filter technology, but I did follow the
`
`area.
`
` Q. Do you know which section of the Code of Federal
`
`Regulations the EPA sets forth its requirements for particulate
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`matter emissions or NOx emissions or any other mandated
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`emission requirements?
`
` A. They are -- well, they're issued as on-road emission
`
`regulations. But in terms of which part of the code? No.
`
` Q. Now, do on-road emissions standards differ for the
`
`emissions standards for stationary power plants?
`
` A. Yes, they do.
`
` Q. How so?
`
` A. To my knowledge, they have always been regulated
`
`separately.
`
` Q. And would anybody involved in either diesel engines or
`
`stationary power plants know that?
`
` A. I would think so.
`
` Q. Okay. Can you turn to the next page? Under "2011" it
`
`says, "Session chair mobile/stationary emission control." Do
`
`you see that?
`
` A. Um-hmm. Yes.
`
` (DISCUSSION HELD OFF THE RECORD)
`
`BY MR. MEYER:
`
` Q. Okay. What happened there? What was the subject of
`
`this meeting, if you recall?
`
` A. So the North American Catalysis Society meeting is the
`
`largest meeting of catalyst researchers in North America, held
`
`every two years. The meeting is divided up into a number of
`
`parallel sessions. One of these sessions dealt with catalysis
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`Page 23
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`for emission control as applied to both mobile and stationary
`
`applications, and I was asked to chair one of the sessions.
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` Q. So can a catalyst that is used in a stationary power
`
`plant also be used in a mobile source such as a diesel-engine-
`
`powered car?
`
` A. In certain cases, yes.
`
` Q. Okay. Which cases?
`
` A. If I think about, for example, NOx control, there are
`
`several catalyst technologies which have transferred from
`
`mobile -- sorry -- from stationary applications to mobile
`
`applications, also oxidation catalysts, for example; so there
`
`are a number of examples of such technologies.
`
` Q. How about the other way, from mobile sources to
`
`stationary sources? Any technology go from mobile sources to
`
`stationary sources?
`
` A. Not so much. It depends how one defines
`
`"technology." I do know of, for example, catalysts which have
`
`been developed for principally automotive applications which
`
`have been tested for stationary applications, but in terms of
`
`wholesale transfer of technology from mobile to stationary
`
`applications, I can't think of any.
`
` Q. Okay. I'd like to refer to the next page, Page 17.
`
`There's the heading, is it -- is that "refereed papers"?
`
` A. Um-hmm.
`
` Q. What does that term mean, "refereed"?
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` A. It means peer reviewed.
`
` Q. Peer review. Okay. And all the listed papers you
`
`were included as either an author or a co-author?
`
` A. Correct.
`
` Q. Okay. I'd like you to turn to Page 20, paper number
`
`18. The title of the paper is "NOx storage reduction
`
`characteristics of Ba-based lean NOx trap catalysts subjected
`
`to simulated road aging." Do you see that?
`
` A. I do.
`
` Q. And you're listed as a co-author?
`
` A. Um-hmm. Correct.
`
` Q. Okay. What is this article about?
`
` A. So this article concerns an attempt to gain
`
`understanding of the mechanisms responsible for the
`
`deterioration of catalyst performance during use.
`
` Q. Okay. I see the word "simulated" in the title.
`
` A. Correct.
`
` Q. Okay. So now I'd like to ask you, was the -- the
`
`catalysts that were tested, were they computer simulations of a
`
`catalyst or were actual NOx, Ba-based lean NOx trap catalysts,
`
`actual catalysts tested?
`
` A. Actual catalysts were tested.
`
` Q. Okay. Where did you get those catalysts?
`
` A. We prepared them.
`
` Q. Okay. Who is "we"?
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` A. My research group.
`
` Q. Okay. How did you prepare those?
`
` A. So we took an alumina powder and we impregnated that
`
`with barium acetate, we calcined it, we then impregnated that
`
`powder with a source of platinum. We then took the resulting
`
`powder after calcination and mixed it with a ceria powder.
`
` THE WITNESS: Ceria.
`
`BY MR. MEYER:
`
` Q. I'm sorry. Maybe you should spell "ceria" for her.
`
` THE WITNESS: C-E-R-I-A. Actually, I need to
`
` back up, because I made a mistake there. So we took a
`
` powder comprising barium impregnated onto alumina
`
` after calcination, we mixed that with a ceria powder,
`
` we impregnated that with platinum. We also took an
`
` alumina powder which we had impregnated with platinum
`
` and rhodium, we then added that to the
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