`
`NEIL HANNEMANN
`
`April 7, 2015
`
`Prepared for you by
`
`Bingham Farms/Southfield • Grand Rapids
`Ann Arbor • Detroit • Flint • Jackson • Lansing • Mt. Clemens • Saginaw
`
`1
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`PAICE 2211
`Ford v. Paice & Abell
`IPR2015-00792
`
`
`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 7, 2015April 7, 2015
`
`
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`Page 1Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` FORD MOTOR COMPANY, :
` Petitioner, :
` v. : IPR Case No:
` PAICE LLC & ABELL FOUNDATION, : IPR2014-00571
` INC., :
` Patent Owner. :
` :
`- - - - - - - - - - - - - - - - -x
`
` Oral Deposition of NEIL HANNEMANN
` Washington, DC
` Tuesday, April 7, 2015
` 9:58 a.m.
`
`Job No.: 79874
`Pages: 1 - 145
`Reported By: Rebecca Stonestreet, RPR, CRR
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`NEIL HANNEMANNNEIL HANNEMANN
`
`April 7, 2015April 7, 2015
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`Page 112Page 112
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`other commands?
` A That's correct.
` Q It says: "Acceleration, direction,
`deceleration." Right?
` A Yes.
` Q And then it's got those five data input --
`data inputs, rather, that are going into the
`microprocessor controller in that cover page figure.
`Right?
` A That's correct.
` Q So do you agree, then, that in this '970
`patent, the microprocessor is going to determine how much
`torque the motor provides, or the engine provides at any
`given time?
` MR. LIVEDALEN: Objection. Vague.
` A Well, this describes that it performs that
`function, but it doesn't describe how it's doing it.
` Q Do you agree that when the microprocessor in
`the '970 patent is determining how much torque the motor
`and/or the engine should be generating, it's doing so
`based on what the microprocessor concludes is required at
`that point in time?
` MR. LIVEDALEN: Objection. Vague, calls for
`speculation.
` A Well, yeah, the microprocessor -- basically,
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`NEIL HANNEMANNNEIL HANNEMANN
`
`April 7, 2015April 7, 2015
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`Page 113Page 113
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`you're asking if the microprocessor would perform as it's
`intended to, as it's programmed to. And yeah, however
`it's programmed is what it will do.
` Q So however it's programmed, to determine the
`amount of torque required from the motor and/or the
`engine, that's how it's going to make that determination
`when it's driving down the road. Correct?
` MR. LIVEDALEN: Same objection.
` A Right. There's many ways that it could do
`that, and what's missing in the '970 patent is any
`reference of using the road load to make that
`determination.
` Q In the '970 patent, when a microprocessor
`determines how much torque is required from the motor end
`or the engine, do you agree it does it instantaneously,
`or in real time?
` MR. LIVEDALEN: Objection. Vague, foundation.
` A You know, I don't recall if I ever read in
`here if they disclosed it was real time or not. So I
`guess I just don't know that.
` Q Would a person of skill in the art know that
`when a microprocessor is determining how much torque is
`required, they generally do it based on instantaneous
`conditions?
` MR. LIVEDALEN: Objection. Vague, foundation,
`
`4
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