Declaration of William E. Todd
`IPR2015-00650
`
`UNITED STATES PATENT & TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`OWENS CORNING,
`Petitioner
`
`FAST FELT CORPORATION,
`Patent Owner
`
`Case IPR2015-00650
`U.S. Patent No. 8,137,757
`
`DECLARATION OF WILLIAM E. TODD REGARDING
`U.S. PATENT 8,137,757
`
`MAlL STOP "PATENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-145
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`Page 1 of 64
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`FAST FELT 2003, pg. 1
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`Declaration of William E. Todd
`IPR2015-00650
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`I, William E. Todd, do hereby declare and state, that all statements made herein of my own
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`knowledge are true and that all statements made on information and belief are believed to be
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`true; and further that these statements were made with the knowledge trhat willful false
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`statements and the like so made are punishable by fine or imprisonment, or both, under Section
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`1001 of Title 18 of the United States Code.
`
`Dated: November 20, 2015
`
`William E. Todd
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`FAST FELT 2003, pg. 2
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`Declaration of William E. Todd
`IPR2015-00650
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`1.
`
`TABLE OF CONTENTS
`
`INTRODUCTION ................................................................................................ 5
`A.
`Engagement .................................................................................................... 5
`B.
`Background and Qualifications ...................................................................... 5
`Compensation and Prior Testimony ............................................................. 10
`C.
`Information Considered ................................................................................ 10
`D.
`II. PATENTABILITY ............................................................................................. 11
`
`A. My Understanding of the Legal Standards for Patentability,
`Obviousness .................................................................................................. 11
`
`B. The Person of Ordinary Skill in the Art ....................................................... 13
`
`III.DESCRIPTION OF THE BACKGROUND TECHNOLOGY .......................... 22
`
`A. The Standard Method of Manufacturing a Roofing or Building
`Cover Material is to Heavily Saturate an Extended Length of
`Substrate with a Weather or Water Proofing Material,
`Specifically with an Asphaltic Material ....................................................... 22
`
`B. Nail Tabs Are An Alternative to Tin or Plastic Caps For
`Fastening Roofing Or Building Cover Materials Securely To A
`Structure ....................................................................................................... 25
`
`PATENT-IN-I S SUE
`IV. THE
`............................................................................................................................. 7
`
`A. General Overview Of The ’757 Patent ......................................................... 27
`
`B. Roofing or Building Cover Material ............................................................ 28
`
`C. Hindsight Bias .............................................................................................. 29
`
`V. NO MOTIVATION TO COMBINE PRIOR ART REFERENCES HEFELE,
`EATON, OR BAYER WITH LASSITER ......................................................... 34
`A. Paper is not a roofing or building cover material ......................................... 34
`B. Non-Contact Deposition to Contact Lamination .......................................... 37
`C. Asphalt Oil Contamination ........................................................................... 39
`D. Patent No. 5,101,759 to Hefele .................................................................... 41
`E. U.S. Patent No. 6,875,710 to Eaton (Ex. 1005) ........................................... 51
`F. U.S. Patent No. 5,597,618 to Bayer (Ex. 1007) ........................................... 56
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`Declaration of William E. Todd
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`VI ........................................................................................................ CONCLUSION
`............................................................................................................................. 3
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`Page 4 of 64
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`Declaration of William E. Todd
`IPR2015-00650
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`I. INTRODUCTION
`
`Engagement
`
`I have been retained by counsel for Patent Owner Fast Felt Corporation
`
`("Fast Felt") as an expert witness in the above-captioned proceedings. I have
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`been asked to render an opinion regarding the validity of claims 1, 2, 4, 6,
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`and 7 of U.S. Patent No. 8,137,757 (the "’757 Patent") (Ex. 1001). I will
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`refer to this patent as the "Patent-In-Issue."
`
`Background and Qualifications
`
`My background and experience includes more than 27 years of direct
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`employment in the roof covering materials industry, for a single company,
`
`Atlas Roofing Corporation. Atlas Roofing Corporation is a large asphalt
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`roofing manufacturer of asphalt based underlayment materials, asphalt roof
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`shingles, commercial rigid foam insulations, residential rigid foam products
`
`and specialty web sheet materials. My term of employment included
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`management of product design, product development, product testing,
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`production supervision, and corporate representation to the industry. My
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`responsibilities have included development of all product installation
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`Declaration of William E. Todd
`IPR2015-00650
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`o
`
`o
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`procedures, packaging designs, compliance to appropriate Building Codes
`
`and Industry Standards as well as meeting customer expectations.
`
`I hold a Bachelor Degree in Industrial Education from Northeast Missouri
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`State University, 1969 (now Truman State University), MA in Education,
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`1973 from the same institution, as well as post MA study at The University
`
`of Missouri and Northeast Missouri State University.
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`I have significant, hands on experience building houses, roofing houses, as
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`well as managing the same operations. I understand the requirements of
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`design for roof covering materials regarding installation, weather resistance
`
`and long term performance. My direct, hands on experience, in concert with
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`my extensive involvement in the myriad of processes involved in product
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`design, production, product testing and installation procedures uniquely
`
`qualify me as an expert in the art of manufacturing asphalt roof covering
`
`materials.
`
`o
`
`As the Corporate Representative, I continuously attended industry trade
`
`association meetings, on behalf of Atlas Roofing Corporation. This service
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`included attending ASTM (American Society for Testing and
`
`Measurements) and Asphalt Roofing Manufacturers Association (ARMA)
`
`meetings and conferences. I have been an active, participating member of
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`Declaration of William E. Todd
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`various committees, including the ARMA Steep Slope Technical Committee
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`for 10 + years. As a lead in that committee, I was a major contributor to the
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`latest revision of the Residential Asphalt Roofing Manual, Copyright 2014,
`
`the official asphalt roofing industry reference for general use by residential
`
`contractors and all interested parties.
`
`I have been an invited presenter at various trade conventions for educational
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`seminars on roof underlayment, shingle performance and installation
`
`International Roofing Expo (IRE), Florida Roofing and Sheet Metal (FRSA)
`
`and Roofing Consultants Institute (RCI).
`
`I retired as the Director of Product Management for the Atlas Roofing
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`Corporation effective as of May 31, 2014 after 27+ years of exemplary
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`service to the success of the company.
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`My Atlas Roofing Corporation management responsibilities included
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`working closely with plant Production Management, Quality Control and
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`production line personnel to design and develop new asphalt saturated
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`underlayment materials, synthetic underlayment, and high performance
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`asphalt shingles.
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`Per my original concept, product design and management throughout the
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`product development process, a commercially successful saturated felt
`
`o
`
`°
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`Declaration of William E. Todd
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`underlayment product was produced utilizing a unique hybrid dry felt
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`containing a high content of glass fibers and is 100% asphalt saturated for an
`
`economic advantage and utilizing recycle content (trade name - Gorilla
`
`Guard).
`
`10.
`
`I have spent hundreds of hours in production facilities working in concert
`
`with production personnel to develop new products, witnessing regular
`
`production runs, witnessing Quality Control procedures and providing
`
`insight as to possible product improvement. This significant amount of time
`
`spent in the production line area demonstrated the propensity for asphalt oils
`
`to migrate to the surrounding machinery and disrupt plant operations. One of
`
`the ongoing challenges for asphalt shingles production and in situ
`
`performance is proper deposition of sealant materials to provide wind
`
`resistance for both short term and long term performance. I have been
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`involved with production and quality management in developing proprietary
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`SBS (Styrene Butadiene Styrene) polymer modified asphalt sealants which
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`can be applied at full line speeds, in discrete locations while providing the
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`required wind sealant (to provide wind resistant capacity) for asphalt
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`shingles.
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`11.
`
`I am the primary inventor named on a US Patent of a unique design for an
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`asphalt roof ridge cap product i.e. (trade name Pro-Cut) (Todd et.al US
`
`D574,972 S) and listed on US Patent 5,433,050, - "Vented Insulation Panel
`
`With Foamed Spacer Members" i.e. ( trade name Vented-R) - both roof and
`
`roof covering related. This was my unique concept and product design,
`
`developed with collaboration from production personnel in a manufacturing
`
`plant.
`
`12.
`
`A major part of my corporate responsibilities has been the management of
`
`all asphalt finished product testing to assure full product performance
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`compliance to local, state and national Building Codes. This responsibility
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`involved the witnessing of the test sample preparation, actual test procedures
`
`and protocols at certified, independent testing agencies such as Underwriters
`
`Laboratory, Factory Mutual, PRI, ERD, etc. My involvement with product
`
`testing has provided me with significant insight and firsthand knowledge of
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`roof covering product requirements of performance as to wind resistance,
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`fastener pull through, tear resistance, installation requirements and in situ
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`performance on the roof.
`
`13.
`
`My curriculum vitae is attached as Appendix A.
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`Declaration of William E. Todd
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`Compensation and Prior Testimony
`
`I am being compensated at a rate of $150 per hour for my work in
`
`connection with this matter, such as my study and review of the Patent-In-
`
`Issue, related prior art, and other materials. I am also being reimbursed for
`
`reasonable and customary expenses associated with my work in this
`
`proceeding. My compensation is not contingent on the outcome of this
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`proceeding or the specifics of my testimony.
`
`Information Considered
`
`My opinions are based on my approximately 30 years of education, research,
`
`and experience in the field of roofing and building cover materials, primarily
`
`the manufacture of asphalt roofing and building cover materials, as well as
`
`my investigation and study of the relevant materials. In forming my
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`opinions, I have considered the materials referred to herein and listed in
`
`Appendix B.
`
`16.
`
`I may rely upon these materials and/or additional materials to rebut
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`arguments raised by the Petitioner. Further, I may also consider additional
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`documents and information in forming any necessary opinions, including
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`documents that I may not yet have reviewed and documents that have not yet
`
`been provided to me.
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`17. My analysis of the materials relating to this proceeding is ongoing, and I will
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`continue to review any new material as it is provided. This declaration
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`represents only those opinions I have formed to date. I reserve the right to
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`revise, supplement, and/or amend my opinions based on new information
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`and on my continuing analysis of the materials referred to herein and listed
`
`in Appendix A.
`
`II.
`
`PATENTABILITY
`
`My Understanding
`Obviousness
`
`of the Legal Standards for Patentability,
`
`18.
`
`In expressing my opinions and considering the subject matter of the claims
`
`of the Patent-In-Issue, I am relying upon certain basic legal principles that
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`counsel have explained to me.
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`19.
`
`I have been informed and understand that claims are construed from the
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`perspective of a person of ordinary skill in the art at the time of the claimed
`
`invention, and that, during inter partes review, claims are to be given their
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`broadest reasonable construction consistent with the specification.
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`20.
`
`I have also been informed and understand that the subject matter of a patent
`
`claim is obvious if the differences between the subject matter of the claim
`
`and the prior art are such that the subject matter as a whole would have been
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`obvious at the time the invention was made to a person of ordinary skill in
`
`the art to which the subject matter pertains. I have also been informed that
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`the framework for determining obviousness involves considering the
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`following factors: (i) the scope and content of the prior art; (ii) the
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`differences between the prior art and the claimed subject matter; (iii) the
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`level of ordinary skill in the art; and (iv) any objective indicia of non-
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`obviousness. I understand that the claimed subject matter would have been
`
`obvious to a person of ordinary skill in the art if, for example, it resulted
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`from the combination of known elements according to known methods to
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`yield predictable results, the simple substitution of one known element for
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`another to obtain predictable results, use of a known technique to improve
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`similar devices in the same way or applying a known technique to a known
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`device ready for improvement to yield predictable results. I have also been
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`informed that the analysis of obviousness may include recourse to logic,
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`judgment, and common sense available to the person of ordinary skill in the
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`art that does not necessarily require explication in any reference. I also
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`understand that routine experimentation in order to optimize a result-
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`effective variable would also be obvious to a person of ordinary skill.
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`21.
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`In addition, I understand that the obviousness inquiry should not be
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`performed with the benefit of hindsight, but should be considered through
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`the eyes of a person of ordinary skill in the relevant art at the time of the
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`claimed invention.
`
`The Person of Ordinary Skill in the Art
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`It is my opinion, based on my extensive experience in the roofing industry
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`that the proper field of endeavor of the ’757 patent is the field of
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`manufacturing roofing or building cover materials with integrated nail tabs.
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`I believe that the person of ordinary skill in this art has a bachelor’s degree,
`
`and potentially some advanced schooling, in chemistry, engineering (such as
`
`chemical, civil, or mechanical engineering), materials science, physical
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`science, or a related discipline, and a minimum of 3-5 years of additional
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`training and experience in the field of manufacturing asphalt roofing and
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`building cover materials, specifically including underlayments, other roll
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`roofing products and asphalt shingles.
`
`23.
`
`Making discontinuous roofing and building cover materials from extended
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`lengths of substrate materials is a decades old process. Industry participants
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`employ substantially the same processes. The knowledge and actual
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`working experience gained from years of working with and around
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`equipment producing heavily asphalt saturated products from a continuous
`
`web system is a necessary skill to understand and articulately discuss the
`
`issues involved in the ’757 Patent.
`
`24.
`
`One ordinarily skilled in the art of roofing manufacturing would certainly be
`
`familiar with the primary purpose of a roof, namely to shed water and
`
`otherwise weather-proof a structure. The materials used to create a roofing
`
`or building cover material are critical to achieving this primary purpose.
`
`Roofing and building cover materials must be water or weather proof as
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`these materials are typically the only line of defense against adverse weather
`
`conditions. Asphalt coating or saturation is commonly used to achieve the
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`water and/or weather proofing aspect of roofing materials. A person of
`
`ordinary skill in this art would be well aware of this.
`
`25.
`
`The installation of roofing or building cover materials also informs the
`
`manufacturing process. A person of ordinary skill in the making of roofing
`
`or building cover materials would have a thorough understanding of the
`
`common installation processes associated with roofing or building cover
`
`materials. This would certainly include the installation of asphalt saturated
`
`roofing underlayment and asphalt saturated shingles commonly used in
`
`pitched residential roofing. A person of ordinary skill in this art would be
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`aware that tin caps and cap nails are common means of reinforcing roofing
`
`and building cover materials during installation. This person would also be
`
`aware that nail tabs identify where a nail should be place and provide
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`reinforcement to stop or slow nail head pullout and pull-through. One
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`skilled in this art would also have a reasonable familiarity with the
`
`installation of rolled roofing products and "hot mopping" more commonly
`
`employed during the installation of commercial, flat roof structures.
`
`26.
`
`Roofing or building cover materials are relatively fragile prior to installation.
`
`The typical installation of a residential pitched roof involves fastening an
`
`asphalt saturated underlayment to a wooden roof deck and securing asphalt
`
`saturated shingles on top of the underlayment. Due to the fragile nature of
`
`asphalt saturated products some manner of reinforcement is commonly used
`
`to help fasten the underlayment to the roof deck. Tin caps or plastic caps are
`
`often used to distribute the force created by the head of a roofing nail over a
`
`larger area and secure the roofing cover material to the roof deck. The
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`materials used to extend this surface area are located between the head of the
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`nail and the roofing or building cover material and comprise materials which
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`function to slow or stop the head of a nail from pulling through. Similar
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`methods such as cap nails, individual plastic tabs, and whole sheet
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`reinforcements have also been used to help fasten the roof covering to the
`
`structure of the building.
`
`27.
`
`My experience from actual hands on applications, personally managing and
`
`witnessing product performance testing, as well as onsite inspections of
`
`failed products from weather related roof damage has proven to me that
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`substantial reinforcement to the fastening areas is necessary to maintain roof
`
`coverings on the roof deck when extreme weather strikes. A person of
`
`ordinary skill in the making of roofing or building cover materials would be
`
`familiar with these processes and the need to reinforce common roofing
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`products.
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`28.
`
`The destructive effects of abnormal elevation changes in the reasonably
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`planar surface of the fast moving web is a critical element that needs to be
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`understood by one skilled in the art. The equipment designed to remove
`
`excess coating can tear and break a web, thereby making it economically
`
`unfeasible to run. This would be known by one skilled in the art.
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`29.
`
`The high temperatures transmitted to process equipment from the high
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`thermal mass of the heavily coated web, which is coated with asphalt stored
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`above 450°F, is an important element for one skilled in the art to understand.
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`Oftentimes, these manufacturing lines run for days at a time without, or with
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`minimal, stops. Resident high temperatures remain present in the process
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`rolls and other manufacturing line equipment and can soften, melt and
`
`degrade polymer. Roll equipment in contact with the asphalt or the polymer
`
`during processing, including, but not limited to the asphalt coating,
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`saturation or polymer deposition processes, can cause problems, which is
`
`well understood by one of ordinary skill in the art. For example, in the case
`
`of making nail tabs the ordinarily skilled artisan reading Lassiter ’409 would
`
`understand that using rollers to deposit tabs on roofing or building cover
`
`material could melt the tab material itself, scrape off the tabs, or cause other
`
`problems.
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`30. Additionally, the asphalt used during the manufacture of roofing and
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`building cover materials with nail tabs can readily transmit oils or other
`
`asphalt contaminates to the equipment used to make the product. This
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`contamination can even be spread to equipment that does not directly contact
`
`asphalt coated substrates through the process of indirect transfer. Virtually
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`all roofing manufacturing plants run continuously day and night. Due to the
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`nature of these continuous operations, even minor contamination issues can
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`quickly escalate with no clear opportunity for maintenance.
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`31.
`
`Having hundreds of hours of direct experience within manufacturing
`
`facilities utilizing asphalt products has consistently demonstrated to me that
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`the 450f (+) heated, and liquid, asphalt emits light oils and vapors into the
`
`atmosphere to the extent that virtually all exposed mechanical surfaces
`
`within many feet will become contaminated with asphalt residue. The
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`maintenance of the manufacturing equipment is an ongoing challenge due to
`
`the contamination. The ordinary artisan in the field of roofing would be
`
`familiar with the nature of asphalt oil contamination.
`
`32.
`
`A common methodology to keep process rolls clean is to employ kerosene
`
`as the primary cleaning agent for the asphalt processing equipment, which is
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`another particular element to be understood by one skilled in the art because
`
`of its potentially adverse effects to the polymer deposited. Process
`
`equipment employed in the making of roofing and building cover materials
`
`would be understood by one skilled in its art.
`
`33.
`
`The thicknesses and volumes of materials employed in making roofing and
`
`building cover materials vary substantially. Roof covering substrates are
`
`carriers of a heavy asphalt coating, a weather or water proof coating, which
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`is coated on both sides of the substrate carrier or saturated through the
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`substrate. This coating is 100% to 150% of the weight of the substrate
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`carrier in the finished product.
`
`34.
`
`The substrate carries the asphalt to the roof deck and, along with a fastening
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`system, holds the asphalt weather/water proofing to the roof deck to cover
`
`and protect the building. The thickness and volumes of materials used, and
`
`the processes which deposit or apply them, uniquely define this field of
`
`industry and would be understood by one skilled in its art.
`
`35.
`
`In considering the patentability of the ’757 Patent claims 1, 2, 4, 6 and 7, I
`
`have used the perspective of a person of ordinary skill in the art of making
`
`roofing or building cover material with integrated nail tabs. I have used the
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`perspective of this ordinary artisan at the time of the earliest possible filing
`
`date of the subject matter at issue, i.e., May 29, 2003, which I understand to
`
`be the filing date of the earliest provisional patent application in the family
`
`of patent applications that resulted in the Patent-In-Issue.
`
`36.
`
`I believe that it is important to note that the Petitioner, Owens Corning, has
`
`employed an expert in 8 other IPR Petitions against a single roofing industry
`
`participant. This Petitioner’s expert opined on nail reinforcement of roofing
`
`materials and used similar wording to describe a person skilled in the art as I
`
`have used above.
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`37.
`
`I have reviewed the ’757 Patent and believe that printing and graphics is not
`
`the correct art of the ’757 Patent. The preamble of both independent claims
`
`of the ’757 Patent expressly claim a "method of making a roofing or
`
`building cover material." [Ex. 1001, Claim 1 and 7]. These claims as well
`
`as the specification of the patent are clearly directed to the making of roofing
`
`and building cover materials with nail tabs and Claim 1 includes
`
`incorporating asphalt as a weather protectant. [Ex. 1001, Col. 7:50-54].
`
`Additionally, the problem solved by the development of integrated nail tabs
`
`is a long standing issue in the installation of roofing and building cover
`
`materials.
`
`38.
`
`I do not believe someone with little or no understanding of the manufacture
`
`of roofing products could properly analyze the ’757 Patent. Anyone with
`
`solely an understanding of printing and graphic arts would not understand
`
`the issues addressed by the ’757 patent. An individual with only an
`
`understanding of printing and graphic arts would certainly not be a
`
`considered an ordinarily skilled artisan in the context of the ’757 patent.
`
`39.
`
`I have consulted with Dr. Mark Bohan, an expert in the printing and graphic
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`arts, and he agrees with me that someone of ordinary skill in the context of
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`the ’757 patent would require experience in and/or understanding of the
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`Declaration of William E. Todd
`IPR2015-00650
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`making of roofing and building cover materials. As an expert in the printing
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`and graphic arts, Dr. Bohan understands, and I independently agree, that
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`printing is not the correct art in which to analyze the claims of the ’757
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`Patent.
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`40.
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`I do not believe that a person solely skilled in the art of printing and graphics
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`could understand the processing problems in the asphalt roofing products
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`industry. This belief has been confirmed by Petitioner’s expert, Dr.
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`Levenson when he stated that roofing and building cover materials were not
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`part of his business. [Ex. 2005, p. 80].
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`41.
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`In my opinion, it is beyond reason to attribute any weight to a person solely
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`skilled in the art of printing and graphics. This would include the person of
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`ordinary skill as described by Petitioner’s expert in this IPR Petition when
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`he stated the "scope and content of the prior art indicates one of ordinary
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`skill would be familiar with various methods of printing polymer on various
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`substrates and for various purposes ... The prior art ... also indicates one of
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`ordinary skill would be aware that various methods of printing polymer are
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`interchangeable and provide for predictable results." [Ex. 1014, ¶¶12-13].
`
`Dr. Levenson’s description of one of ordinary skill entirely ignores the vast
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`IPR2015-00650
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`majority of the ’757 Patent, namely the making of roofing and building
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`cover materials with reinforcing nail tabs.
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`42.
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`With proper weight attributed to my many years in the asphalt roofing
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`products industry and my discussions with Dr. Mark Bohan, I believe that no
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`person or entity has transferred a defined image which would provide any
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`measureable reinforcement from a printing plate to an asphalt saturated
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`substrate in a successful commercial process. There appears to be no
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`obvious "printability" qualities to a heavily asphalt coated surface structure.
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`III. DESCRIPTION OF THE BACKGROUND TECHNOLOGY
`
`The Standard Method of Manufacturing a Roofing or Building Cover
`Material is to Heavily Saturate an Extended Length of Substrate with a
`Weather or Water Proofing Material, Specifically with an Asphaltic
`Material
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`43.
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`For decades, the predominant roofing cover material for wood frame
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`construction has utilized asphalt roofing products. Asphalt serves as the
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`basic weather or water proofing element. In the, roughly, first half of a
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`manufacturing line, the manufacture of these asphalt roofing and building
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`cover materials is completed using generally similar processes and
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`equipment. Different substrates, asphaltic materials, methods of saturation
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`or coating, etc. may vary, but the basic manufacturing processes and
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`equipment are similar.
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`44.
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`For example, to highlight the similarities, a heavily asphalt saturated
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`substrate may become an underlayment. This underlayment may, in turn,
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`become a roll roofing product with rock granules deposited onto hot, soft
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`and tacky asphalt in the line area described below. A web that could be a
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`roll roofing product may subsequently be cut into discontinuous pieces, such
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`as individual shingles, after the web is cooled. Typically, the web, after
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`cooling, is cut into rolls to make the first roofing cover material layer, e.g.,
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`the underlayment. Usually each roll is rounded with a dimension of, for
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`example, 3-feet wide by 70 to 200 feet long. At a jobsite, an underlayment
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`roll is unwound, cut and affixed directly to the roof deck.
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`45.
`
`When making shingles, the heavily asphalt coated substrate web will usually
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`have rock granules deposited onto it. The granules are deposited onto, and
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`pressed into, the heavy asphalt coating before it completely cools and
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`usually while the asphalt coating is hot, soft and tacky. Once cooled, the
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`granule-topped and asphalt coated substrate web may then be cut into
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`individual shingles. Each shingle is roughly 1-foot wide by 3-feet long. The
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`shingles will be installed as the second and top, weather-facing layer on the
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`building’s roof.
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`IPR2015-00650
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`46.
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`The production process begins with the unwind stand, where large
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`(approximately 7-foot diameter and 1-yard to 1-meter wide) rolls of
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`substrate material, typically a dry felt or fiberglass mat, supply the
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`manufacturing line. The large rolls of material are fed through a splicing
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`table and into a dry looper to facilitate continuous production runs.
`
`47.
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`From the dry looper, the web passes through a saturation and/or coating area
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`which contains a liquid asphaltic material, maintained at a high temperature
`
`for its application on to the continuous web moving through this area. For
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`saturation, the web is dipped into an asphalt tank filled with hot molten
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`saturating asphalt heated to approximately 450-500 degrees F. The web is
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`dipped into the tank approximately 10-fee