UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Page 1
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` _________________
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________________
`
` FORD MOTOR COMPANY,
`
` Petitioner,
`
` -vs-
`
` PAICE, LLC & ABELL FOUNDATION, INC.,
`
` Patent Owner.
`
` _____________________
`
` U.S. Patent No. 7,237,634 to Severinsky, et al.
`
` IPR Case No: IPR2014-01416
`
` ____________________
`
` DEPOSITION OF GREGORY W. DAVIS, Ph.D.
`
`
`
` Taken at 1000 Town Center, 21st Floor,
`
` Southfield, Michigan,
`
` Commencing at 9:05 a.m.,
`
` Wednesday, June 3, 2015
`
`Reported by:
`Laura J. Steenbergh
`Job no: 14291A
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
` 1
`
`PAICE 2209
`Ford v. Paice & Abell
`IPR2015-00792
`
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` Southfield, Michigan
` Wednesday, June 3, 2015
` About 9:05 a.m. 09:05:47AM
` MR. LIVEDALEN: Good morning. 09:06:36AM
` THE WITNESS: Good morning. 09:06:38AM
` GREGORY DAVIS, PhD, 09:06:38AM
` having first been duly sworn, was examined and testified 09:06:38AM
` on his oath as follows: 09:06:38AM
`EXAMINATION BY MR. LIVEDALEN: 09:06:38AM
`Q. Can you please state your name for the record? 09:06:40AM
`A. Sure. Dr. Gregory W. Davis. 09:06:42AM
`Q. And you understand you've taken an oath this morning? 09:06:44AM
`A. Yes. 09:06:48AM
`Q. And I think by now you're familiar with all the 09:06:48AM
` deposition rules. Do you want me to go over any of 09:06:51AM
` those again? 09:06:54AM
`A. No. I think I'm in pretty good shape on those. 09:06:54AM
`Q. Okay. Great. 09:06:57AM
` All right. I'm going to hand you what we'll 09:06:58AM
` mark as Exhibit 1. 09:07:08AM
` DAVIS EXHIBIT 1 09:07:18AM
` U.S. Patent 5,842,534 09:07:18AM
` WAS MARKED BY THE REPORTER 09:07:18AM
` FOR IDENTIFICATION 09:07:18AM
` 09:07:18AM
`
`Page 5
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`BY MR. LIVEDALEN: 09:07:18AM
`Q. Can you please identify for the record what I've handed 09:07:22AM
` you as Exhibit 1? 09:07:36AM
`A. Yes. It's a U.S. Patent 5,842,534, to Andy Frank. 09:07:37AM
`Q. So you'd be okay if we called this the Frank reference? 09:07:45AM
`A. That would be fine. 09:07:48AM
`Q. Or Frank for short. 09:07:49AM
` Dr. Davis, why do you cite to this reference 09:07:52AM
` -- or let me strike that. 09:07:57AM
` Do you cite to this reference in your 09:07:58AM
` declaration for this matter? 09:08:01AM
`A. Yes, I believe I do. 09:08:02AM
`Q. And why did you do that? 09:08:04AM
`A. Well, I think if you refer to my report you'll see that 09:08:35AM
` I talk about that in several spots. And I was using the 09:08:41AM
` Andy Frank reference as a teaching that discloses using 09:08:47AM
` a setpoint to switch when to turn on or off the engine, 09:08:54AM
` and using a time delay in order to prevent unwanted 09:08:59AM
` engine starts. 09:09:06AM
`Q. So it's your testimony that Frank teaches using a time 09:09:06AM
` delay? 09:09:13AM
`A. Yes, it is. 09:09:13AM
`Q. Okay. And you referenced a setpoint, what type of -- 09:09:15AM
` what do you mean by a setpoint? 09:09:23AM
`A. The setpoint would be that point at which you would be 09:09:24AM
`
`2 (Pages 2 to 5)
`
` APPEARANCES:
`
` MR. JOHN RONDINI, ESQ.
` BROOKS KUSHMAN, P.C.
` 1000 Town Center, 22nd Floor
` Southfield, Michigan 48075
` (248) 358-4400
` jrondini@brookskushman.com
` Appearing on behalf of the Petitioner.
`
` MR. BRIAN LIVEDALEN, ESQ.
` FISH & RICHARDSON
` 1425 K Street NW, 11th Floor
` Washington, DC 20005
` (202) 783-5050
` livedalen@fr.com
` Appearing on behalf of the Patent Owner.
`
` * * * *
`
`Page 3
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` TABLE OF CONTENTS
`
`Witness Page
`GREGORY DAVIS, PhD
`EXAMINATION BY MR. LIVEDALEN: 4
`EXAMINATION BY MR. RONDINI: 55
`RE-EXAMINATION BY MR. LIVEDALEN: 59
`
` INDEX TO EXHIBITS
` (Exhibits attached to transcript)
`
`Exhibit Page
` DAVIS EXHIBIT 1 U.S. Patent 5,842,534 4
` DAVIS EXHIBIT 2 Declaration of Gregory Davis 6
` DAVIS EXHIBIT 3 Patent Trial Board Opinion 51
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` making a determination about, in this case, deciding 09:09:31AM
` whether to turn on or turn off the engine. 09:09:34AM
`Q. And is that -- what type of setpoint is that? 09:09:36AM
` MR. RONDINI: Objection, vague. 09:09:42AM
` THE WITNESS: I'm not sure I can answer, or -- 09:09:46AM
`BY MR. LIVEDALEN: 09:09:49AM
`Q. Is it a torque value, is it a speed value? 09:09:49AM
`A. Are you talking about Andy Frank's or the Frank 09:09:53AM
` reference? 09:09:57AM
`Q. Yeah. 09:09:58AM
`A. He's using kind of a speed and depth of discharge. 09:09:59AM
`Q. So the setpoint you're referring to is -- it's part 09:10:05AM
` speed and part depth of discharge, is that right? 09:10:12AM
`A. Yeah. I think we could get probably a better idea of 09:10:15AM
` that if we look at, for example, paragraph 368 of my 09:10:18AM
` report. 09:10:21AM
`Q. Let me -- before you go, why don't we just mark that as 09:10:23AM
` an exhibit since you're referring to that. 09:10:27AM
`A. Okay. 09:10:30AM
` DAVIS EXHIBIT 2 09:10:31AM
` Declaration of Gregory Davis 09:10:31AM
` WAS MARKED BY THE REPORTER 09:10:31AM
` FOR IDENTIFICATION 09:10:31AM
`BY MR. LIVEDALEN: 09:10:31AM
`Q. And, Dr. Davis, could you please identify Exhibit 2 for 09:10:50AM
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` and the off threshold curve prevents undesirable or 09:13:38AM
` excessive cycling of the ICE due to fluctuations in 09:13:42AM
` sense, speed and depth of discharge. And that's what 09:13:48AM
` he's disclosing in Figure 4. 09:13:51AM
` But then he goes on to say, As an alternative 09:13:53AM
` to separate on and off thresholds a single threshold 09:13:57AM
` could be used in combination with a time delay between 09:14:00AM
` the on and off modes to prevent frequent cycling. 09:14:03AM
` So he showed a band type of hysteresis in 09:14:06AM
` Figure 4, but he also contemplates the idea that you 09:14:11AM
` could do the same thing without a band and use a time 09:14:14AM
` delay. 09:14:18AM
`Q. Okay. Let's look back at Figure 4 here. And so do you 09:14:19AM
` see the section of Figure 4, it says between 0 percent 09:14:23AM
` and 50 percent battery depth of discharge? 09:14:28AM
`A. Yes, I do. 09:14:32AM
`Q. And in that area what is Frank using as the threshold 09:14:33AM
` for determining when to turn on the engine? 09:14:41AM
`A. He's using a series of speeds in that particular region 09:14:46AM
` from 0 to 50 percent depth of discharge. He appears to 09:14:52AM
` be turning on the engine at 113 kilometers per hour. 09:14:56AM
` But then he goes on in the other depth of discharge to 09:15:00AM
` change the setpoints progressively going down as we go 09:15:07AM
` to the right, let's say going down lower. So he drops 09:15:12AM
` down, for example, from 113 kilometers per hour at 50 09:15:16AM
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` the record? 09:10:55AM
`A. Exhibit 2 appears to be a copy of the -- my declaration 09:10:55AM
` in support of the IPR review. 09:11:33AM
`Q. Could you read the number? 09:11:38AM
`A. Yeah, I was going to say, a Ford designation of 1107 if 09:11:41AM
` you want, or if want the IPR case number is 09:11:45AM
` IPR2014-01416. 09:11:53AM
`Q. Yeah, that's great. Thanks. 09:11:54AM
` All right. So let's go back to Exhibit 1, 09:12:04AM
` Frank. And if you want to go to Figure 4. Does Figure 09:12:13AM
` 4 show the speed and battery depth of discharge 09:12:26AM
` thresholds that you're referring to? 09:12:33AM
`A. It shows a series of setpoints for making these 09:12:35AM
` decisions, and in this case they're using a hysteresis 09:12:39AM
` based on a band instead of a time. So if you look, for 09:12:48AM
` example, at my discussion I have in paragraph 368, he 09:12:51AM
` talks about really two alternatives. And this is a 09:12:55AM
` quote out of the patent at Column 7, line 66, through 09:12:59AM
` Column 8, line 11, and it says, After the ICE is turned 09:13:07AM
` on and vehicle is operating in a hybrid electric vehicle 09:13:12AM
` mode, or HEV mode, if the vehicle's speed/depth of 09:13:17AM
` discharge parameters fall below the off-threshold curve 09:13:23AM
` the ICE is decoupled and turned off. Then since the EM 09:13:26AM
` is still online, the vehicle again operates in a ZEV 09:13:30AM
` mode. The control band between the on threshold curve 09:13:35AM
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` percent, to -- well, kind of eyeballing it, at 75 09:15:20AM
` percent depth of discharge. It appears to be, I don't 09:15:29AM
` know, on the order of about 60 kilometers per hour. 09:15:32AM
`Q. Okay. Let's just focus on the 0 to 50 percent just to 09:15:35AM
` keep things simpler for now and we can move on to the 09:15:39AM
` other range in a moment. 09:15:43AM
` So looking at Figure 4, it's your opinion then 09:15:45AM
` that between 0 and 50 percent battery depth of discharge 09:15:50AM
` Frank turns the engine on and off based on the speed of 09:15:55AM
` the vehicle, right? 09:15:58AM
`A. Yes. He's using the depth of discharge and the speed of 09:15:58AM
` the vehicle to make a decision about whether to turn on 09:16:06AM
` the engine or turn off the engine. 09:16:11AM
`Q. Can you go to Column 3 for me, please, of Exhibit 1, 09:16:14AM
` which is Frank? And at line three it says, At speeds 09:16:36AM
` greater than approximately 113 kilometers per hour the 09:16:49AM
` vehicle operates in an HEV mode where the ICE is used as 09:16:52AM
` a primary source of power. 09:16:57AM
` Do you see that? 09:16:59AM
`A. Yes, I do. 09:16:59AM
`Q. Does that confirm your opinion that Frank turns the 09:17:00AM
` engine on and off based on the speed of the vehicle? 09:17:04AM
`A. Well, as I said before, first of all he disclosed two 09:17:07AM
` ways to do it. One way was based on using these bands, 09:17:12AM
` these hysteresis bands based on speed and depth of 09:17:16AM
`
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`3 (Pages 6 to 9)
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` discharge of the batteries. And then the other way is 09:17:22AM
` instead of using a hysteresis band he disclosed the idea 09:17:27AM
` of using time delays. 09:17:31AM
`Q. Let's not worry about the hysteresis aspect right now. 09:17:32AM
` Fundamentally I want to understand your opinion as far 09:17:37AM
` how Frank decides to turn the engine on and off. 09:17:39AM
` And so my question is, is the sentence I just 09:17:42AM
` read, and I'll read it again for you, Column 3, line 3, 09:17:45AM
` At speeds greater than approximately 113 kilometers per 09:17:48AM
` hour the vehicle operates in an HEV mode where the ICE 09:17:52AM
` is used as a primary source of power. 09:17:55AM
` Do you see that there? 09:17:59AM
`A. Yes, I do. 09:18:00AM
`Q. Does that indicate to you that, at least in certain 09:18:00AM
` regions, Frank turns the engine on and off purely based 09:18:04AM
` on speed? 09:18:09AM
`A. No. Because, again, when you look at Figure 4 you see 09:18:10AM
` it's more than just speed disclosed, it's speed and 09:18:14AM
` depth of discharge. In that particular region the 09:18:17AM
` design -- he made the design decision to cycle the 09:18:22AM
` engine based on constant values for the speed, but as he 09:18:26AM
` clearly discloses in other regions, he's varying the 09:18:34AM
` setpoint values for speed based on the depth of 09:18:37AM
` discharge. 09:18:40AM
`Q. Understood. But my question was, and I think you 09:18:41AM
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` bands, an on band or series of setpoints, and then an 09:19:58AM
` off band or series of setpoints. But, you know, later 09:20:02AM
` on, as I've already read in Column 7, he discloses that 09:20:06AM
` instead of using these hysteresis bands you could just 09:20:11AM
` use a time delay. 09:20:15AM
`Q. Okay. But are there any other factors that Frank 09:20:16AM
` discloses for determining when to turn the engine on and 09:20:27AM
` off other than vehicle speed and battery depth of 09:20:31AM
` discharge? 09:20:37AM
` MR. RONDINI: Objection, asked and answered. 09:20:37AM
` THE WITNESS: At least in this operation he's, 09:20:38AM
` again, he's showing that he's using a combination of 09:20:47AM
` speed setpoints that vary with the depth of discharge. 09:20:52AM
` In general everything that he discloses, I think I'd 09:20:58AM
` have to go back and refresh myself to see if there's 09:21:02AM
` other modes of operation. 09:21:05AM
`BY MR. LIVEDALEN: 09:21:09AM
`Q. Sitting here today, do you know of any other modes of 09:21:09AM
` operation that use any other control metric besides 09:21:11AM
` vehicle speed and battery depth of discharge? 09:21:16AM
` MR. RONDINI: Objection, vague. 09:21:19AM
` THE WITNESS: Again, Andy Frank is using 09:21:20AM
` speeds in the form of these hysteresis bands for on and 09:21:30AM
` off where the speed setpoints can vary as a function of 09:21:34AM
` the depth of discharge, as disclosed in Figure 4. But 09:21:38AM
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` answered it for me, but for some regions, right, so you 09:18:45AM
` just identified two regions, right, one region where the 09:18:48AM
` speed is held constant, one region where the speed is a 09:18:51AM
` function of the battery depth of discharge, is that 09:18:55AM
` right? 09:18:57AM
` MR. RONDINI: Objection, asked and answered. 09:18:57AM
` THE WITNESS: Again, it's kind of the same 09:19:00AM
` answer. You can't -- 09:19:02AM
`BY MR. LIVEDALEN: 09:19:03AM
`Q. I'm asking about the two regions, I'm not asking about 09:19:04AM
` turning on and off. I just want to understand. Are 09:19:09AM
` there two regions in Figure 4? 09:19:11AM
`A. Well, actually there's three regions if you want to try 09:19:12AM
` and separate it. I don't think one of ordinary skill 09:19:15AM
` would separate that into all those spots, but I think, 09:19:17AM
` again, you can't divorce the idea of his hysteresis 09:19:21AM
` bands' speed from a depth of discharge. Because you'd 09:19:26AM
` first have to know where the depth of discharge is 09:19:30AM
` located in order to determine the setpoint value for the 09:19:33AM
` speed. 09:19:37AM
`Q. Okay. So in your opinion then Frank turns the engine on 09:19:38AM
` and off based on speed and based on the depth of 09:19:45AM
` discharge of the battery? 09:19:48AM
`A. Again, but he does it in, you know, different ways. I 09:19:50AM
` mean, in Figure 4 he's disclosing the idea of hysteresis 09:19:54AM
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` then he goes on to disclose that he could use a single 09:21:42AM
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` be used, but then he would use that in addition to a 09:21:57AM
` time delay. So he's using a time delay as well. 09:22:00AM
`BY MR. LIVEDALEN: 09:22:03AM
`Q. Okay. So time, vehicle speed, and battery depth of 09:22:04AM
` discharge. Any others? 09:22:08AM
`A. In Frank? I'd say I think I'd have to -- I would have 09:22:09AM
` to study this some more. Because I don't -- I do know 09:22:22AM
` that he disclosed some information about, you know, if 09:22:32AM
` the batteries become completely depleted turning on the 09:22:37AM
` IC engine. For example, I think in Column 3, if we go 09:22:45AM
` down to around line 39, for example, if the batteries 09:22:56AM
` were completely depleted and the IC engine was running 09:23:02AM
` the batteries could be slightly charged by the IC 09:23:05AM
` engine, only to provide additional performance to get 09:23:11AM
` home or to a charging station. 09:23:13AM
` So, you know, he obviously has probably some 09:23:22AM
` other operations where he's turning on and off the IC 09:23:25AM
` engine as well. 09:23:32AM
`Q. That is also based on the battery though, right? 09:23:33AM
`A. Well, in that particular one it was if the batteries 09:23:36AM
` were completely depleted, yes. 09:23:39AM
`Q. Okay. Are you relying on Frank to teach load response 09:23:42AM
` of hysteresis? 09:24:01AM
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`A. Now, as I point out in my report, I'm using the idea 09:24:01AM
` disclosing in Frank about, you know, he discloses a 09:24:07AM
` couple of ways of putting a hysteresis in to prevent 09:24:10AM
` unwanted engine starts or cycling the engine. One way 09:24:14AM
` was using hysteresis bands, and the other way was using 09:24:17AM
` time delays. So I'm using the ideas of Frank in terms 09:24:22AM
` of in particular the idea of using a time delay to 09:24:24AM
` prevent unwanted engine starts. 09:24:27AM
`Q. Okay. And let's go to paragraph 368 of your report. It 09:24:29AM
` says, For example, Frank discloses using a hysteresis 09:24:36AM
` time delay switching between engine and motor modes in 09:24:39AM
` order to prevent unnecessary engine stops and restarts 09:24:43AM
` when the torque required to propel the vehicle was near 09:24:47AM
` the setpoint. 09:24:51AM
` So are you saying that the torque required to 09:24:53AM
` propel the vehicle, that's not found in Frank, right? 09:24:56AM
`A. Yeah. What I'm saying is, I'm using the idea from Frank 09:25:00AM
` is the hysteresis time delay. 09:25:03AM
`Q. Okay. So Frank does not teach using the torque required 09:25:07AM
` to propel the vehicle? 09:25:10AM
`A. He's using, again, as we've looked at, he's using the 09:25:11AM
` idea of setting his thresholds based on the speed and 09:25:17AM
` the depth of discharge in order -- those would be the 09:25:24AM
` setpoints that he was using in this instance. 09:25:30AM
`Q. And those setpoints are not torque setpoints, right? 09:25:32AM
`
`Page 15
`
`A. Well, they're certainly related to the torque, 09:25:36AM
` obviously. I mean, I think he recognized the idea that 09:25:41AM
` generally as the vehicle's going faster the 09:25:44AM
` instantaneous torque required for propulsion would be at 09:25:46AM
` a higher level. 09:25:50AM
`Q. And where does Frank say that? 09:25:52AM
`A. Therefore he would bring it in. 09:25:53AM
`Q. Where does Frank say that? 09:25:56AM
`A. It's been a while since I've looked at Frank. 09:25:58AM
`Q. When's the last time you've looked at Frank? 09:26:00AM
`A. Oh, I may have glanced at like that quotation in looking 09:26:04AM
` and reviewing this report for this deposition, but I 09:26:09AM
` haven't studied Frank since -- when did I do this? 09:26:12AM
` About a year ago I think. Yeah, August 29th of 2014. 09:26:18AM
`Q. So let me back up. 09:26:25AM
` What did you do today to prepare for -- or 09:26:27AM
` strike that. 09:26:30AM
` What did you do to prepare for today's 09:26:30AM
` deposition? 09:26:32AM
`A. I studied my reports that were going to be the subject 09:26:32AM
` matter of the deposition. 09:26:35AM
`Q. Did you meet with anyone? 09:26:42AM
`A. I met with Mr. Rondini. 09:26:43AM
`Q. When was that? 09:26:44AM
`A. Last Friday. 09:26:45AM
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`Q. Okay. Did you look at Frank during that meeting? 09:26:46AM
`A. I don't recall. I don't believe so, but I really don't 09:26:48AM
` recall. 09:26:56AM
`Q. Have you ever read Frank in its entirety? 09:26:56AM
`A. Yes, I'm sure I have when I was preparing this report. 09:26:59AM
`Q. Okay. That's fine. 09:27:02AM
` And you keep referring to Frank as Andy Frank. 09:27:07AM
` Do you know Andy Frank? 09:27:10AM
`A. Yes, I do. 09:27:10AM
`Q. Who is he? 09:27:11AM
`A. He was, when I was developing my own hybrid electric 09:27:12AM
` vehicles for the hybrid electric vehicle challenge and 09:27:18AM
` also for the future car challenge, Andy Frank was the 09:27:22AM
` faculty advisor -- I was the faculty advisor first at 09:27:26AM
` the United States Naval Academy, and then the faculty 09:27:31AM
` advisor at Lawrence Technological University, and he was 09:27:34AM
` the faculty advisor for UC Davis. 09:27:37AM
`Q. And what year was that? 09:27:41AM
`A. It was over a number of years. I don't know when I 09:27:42AM
` first met Andy, but I think it was probably in the 09:27:52AM
` 1992-1993 time frame through, I believe, into the 1997 09:27:59AM
` time frame. So over a number of years. 09:28:04AM
`Q. And during that time he was at UC Davis you said? 09:28:06AM
`A. Yes, he was. 09:28:08AM
`Q. Would he have been at UC Davis when he filed for this 09:28:09AM
`
`Page 17
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` patent? 09:28:14AM
` MR. RONDINI: Objection, vague. 09:28:15AM
` THE WITNESS: I believe so, but I don't know 09:28:16AM
` for sure. But I do believe so. 09:28:23AM
`BY MR. LIVEDALEN: 09:28:30AM
`Q. Okay. And so getting back to my earlier question, where 09:28:30AM
` in Frank does he disclose that speed is related to 09:28:38AM
` torque? 09:28:59AM
`A. Well, for example, if we look at Column 2, beginning at 09:31:53AM
` line 53, The IC engine in accordance with the present 09:32:09AM
` invention is typically very small (e.g. 0.016 kilowatts 09:32:16AM
` per vehicle kilogram) and is typically sized to power 09:32:25AM
` the vehicle for freeway cruise at speeds above 09:32:29AM
` approximately 113 kilometers per hour for a range of 690 09:32:33AM
` kilometers or more. However, in typical city driving 09:32:38AM
` conditions, driving with the IC engine alone produces 09:32:41AM
` less than desirable performance because of its small 09:32:46AM
` size. This is an important aspect of the invention, 09:32:50AM
` since it encourages the driver to periodically charge 09:32:53AM
` the vehicle batteries at home. Additionally the varying 09:32:57AM
` driving conditions inherent in city driving will cycle 09:33:01AM
` the engine and reduce efficiency. Emissions would 09:33:04AM
` increase and fuel efficiency would decrease. 09:33:07AM
` So one of ordinary skill in the art would 09:33:12AM
` understand when they look at that that he's sizing the 09:33:14AM
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`5 (Pages 14 to 17)
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`5
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` IC engine just large enough to meet the torque 09:33:17AM
` requirements when traveling approximately 113 kilometers 09:33:23AM
` per hour or above. And so that would put the engine in 09:33:28AM
` an efficient operating region, so it would be a larger 09:33:33AM
` load on the engine. Then he realized though in city 09:33:37AM
` mode that the engine would be operating at times in 09:33:41AM
` low-load conditions in which it's not operating very 09:33:45AM
` efficiently. 09:33:49AM
`Q. So Frank decides to size the engine such that it powers 09:33:50AM
` the vehicle at speeds above approximately 113 kilometers 09:34:23AM
` per hour, is that right? 09:34:27AM
`A. He sizes it so that it can power the vehicle at he calls 09:34:29AM
` it the freeway cruise at speeds above approximately 113 09:34:34AM
` kilometers per hour. 09:34:38AM
`Q. Okay. 09:34:39AM
`A. And so he sizes it in that way so that it will be 09:34:40AM
` operating in its efficient region under those 09:34:43AM
` conditions. 09:34:46AM
`Q. Okay. But as we saw in Figure 4, the control strategies 09:34:46AM
` to turn the engine on and off is based on the speed of 09:34:54AM
` the vehicle and the battery depth of discharge, right? 09:34:57AM
`A. And in addition to the speed of the