`
` IN THE UNITED STATES DISTRICT COURT
`
` FOR THE DISTRICT OF MARYLAND
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` BALTIMORE DIVISION
`
`PAICE LLC and
`
`THE ABELL FOUNDATION, INC.,
`
` Plaintiffs,
`
` Case: 1:14cv00492-WDQ
`
`vs.
`
`FORD MOTOR COMPANY,
`
` Defendant.
`
`______________________________/
`
` DEPOSITION OF JEFFREY L. STEIN
`
` Southfield, Michigan
`
` January 12, 2015
`
`Reported by:
`
`Anne E. Vosburgh, CSR, RPR, CRR
`
`Job no: 13175
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
` 1
`
`PAICE 2214
`Ford v. Paice & Abell
`IPR2015-00792
`
`
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`Page 2
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`Page 4
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` APPEARANCES, CONTINUED:
`
`FOR THE DEFENDANT:
`
` LATHAM & WATKINS, LLP
` BY: AARON PEREZ-DAPLE, ESQ.
` 330 North Wabash Avenue
` Suite 2800
` Chicago, Illinois 60611
` 312.876.7602
` aaron.perez-daple@lw.com
`
` ALSO PRESENT:
` Frances M. Keenan, Paice LLC
`
`Page 5
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` INDEX TO EXAMINATIONS
` WITNESS: JEFFREY L. STEIN
`
` EXAMINATION BY MR. CORDELL:.................. 7
`
` INDEX TO EXHIBITS
`EXHIBIT DESCRIPTION PAGE
`Exhibit 1 Declaration of Dr. Jeffrey Stein 12
` in Support of Petition for Inter
` Partes Review; Appendix A, CV
` and Appendix B, List of
` Materials; Bates FMC 1002.
`Exhibit 2 US Patent 5,343,970 Filed 154
` September 6, 1994, Severinsky
`Exhibit 3 SAE Paper 950493, The Effects of 174
` APU Characteristics, by
` Catherine Anderson and Erin
` Pettit; Bates FMC 1006, 9 pages
`Exhibit 4 US Patent 4,707,984, November 251
` 24, 1987 Katsuno; Bates FMC 1008
`
` (Exhibits attached.)
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`DEPOSITION OF JEFFREY L.STEIN, taken on January 12,
`5
`2015 by the Plaintiffs, at the Law Offices of
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`Brooks Kushman, 1000 Town Center, Southfield,
`7 Michigan, before Anne E. Vosburgh, Certified
`8
`Shorthand Reporter, Registered Professional
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`Reporter, Certified Realtime Reporter, and Notary
`10
`Public in and for the State of Michigan, County of
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`Oakland.
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` A P P E A R A N C E S:
`
`FOR THE PLAINTIFF:
`
` FISH & RICHARDSON
` BY: RUFFIN B. CORDELL, ESQ.
` PETER GUARNIERI, ESQ.
` 1425 K Street NW, 11th Floor
` Washington DC 20005
` 202.783.5070
` cordell@fr.com
` guarnieri@fr.com
`
`FOR THE DEFENDANT:
`
` BROOKS KUSHMAN, PC
` BY: FRANK A. ANGILERI, ESQ.
` SANGEETA G. SHAH, ESQ.
` ANDREW B. TURNER, ESQ.
` 1000 Town Center, Floor 22
` Southfield, Michigan 48075
` 248.358.4400
` fangileri@brookskushman.com
` sshah@brookskushman.com
` aturner@brookskushman.com
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` P R O C E E D I N G S
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` Southfield, Michigan
` January 12, 2015
`9:25 a.m.
`
` MR. CORDELL: Ruffin Cordell and 09:25:45
` Pete Guarnieri from Fish & Richardson on 09:25:46
` behalf of Paice. 09:25:49
` MR. ANGILERI: Frank Angileri, 09:25:52
` Brooks Kushman, for Ford. 09:25:53
` MS. SHAH: Sangeeta Shah for Ford. 09:25:57
` MR. TURNER: Andrew Turner for 09:26:01
` Ford. 09:26:05
` MR. PEREZ-DAPLE: Aaron 09:26:06
` Perez-Daple, Latham & Watkins, for Ford. 09:26:06
` MR. ANGILERI: And just for the 09:26:11
` record, Mr. Perez has not entered an 09:26:11
` appearance but he is present, obviously. 09:26:14
` 09:26:16
` J E F F R E Y S T E I N,
` Having taken an oath to testify
` truthfully, was examined and
` testified as follows.
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`Page 7
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` JEFFREY STEIN
` EXAMINATION 09:26:16
` BY MR. CORDELL: 09:26:16
` Q Good morning, Dr. Stein. 09:26:17
` A Good morning. 09:26:19
` Q Thank you for joining us on a chilly 09:26:21
` morning. 09:26:24
` Can you give us your full name and 09:26:24
` address for the record. 09:26:26
` A Certainly. Jeffrey L. Stein, 3055 09:26:27
` Whisperwood Drive, Ann Arbor, Michigan 48105. 09:26:30
` Q And you understand that you're under 09:26:35
` oath? 09:26:36
` A Yes. 09:26:42
` Q And you're testifying as if you were 09:26:42
` in a court of law? 09:26:43
` A Yes. 09:26:45
` Q Or before the patent office? 09:26:45
` A Yes. 09:26:47
` Q And have you been deposed before? 09:26:48
` A Yes. 09:26:51
` Q How many times? 09:26:53
` A I don't know exactly, but several 09:26:53
` times. 09:26:54
` Q You understand the rules pretty well? 09:26:55
`
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` A If you think it's wise to repeat 09:26:58
` them, I'm certainly willing to listen. 09:27:00
` Q Sure. 09:27:03
` Let me give you a little bit of a 09:27:03
` refresher. If I ask you a question and you 09:27:06
` give me an answer, I'm going to assume you 09:27:08
` understood my question. So if you don't, 09:27:11
` please tell me. 09:27:11
` If you need to take a break, wave 09:27:12
` your hand, say something, talk to Mr. Angileri, 09:27:14
` something. This is not an endurance test by 09:27:21
` any stretch. 09:27:26
` A Okay. Thank you. 09:27:26
` MR. ANGILERI: Objection, form. 09:27:27
` BY MR. CORDELL: 09:27:29
` Q So with that understanding, is there 09:27:29
` any reason today why you can't testify fully 09:27:30
` and truthfully? 09:27:32
` A None that I can think of. 09:27:33
` Q You're a professor at the University 09:27:40
` of Michigan, correct? 09:27:41
` A Yes. 09:27:43
` Q What do you teach? 09:27:44
` A Mechanical engineering is the 09:27:46
`
`Page 9
`
` JEFFREY STEIN
` department in which I teach. 09:27:48
` Q What kinds of courses do you teach? 09:27:49
` A I teach courses in mechanical design, 09:27:52
` mechatronics, systems and controls, dynamics, 09:27:57
` machine control. 09:28:01
` Q So dynamics sounds like an undergrad 09:28:10
` class; is that correct? 09:28:12
` A Well, we have both undergraduate and 09:28:14
` graduate courses in almost all of those topics. 09:28:17
` Q Tell me how many of your courses that 09:28:19
` you're currently teaching are undergrad 09:28:20
` classes? 09:28:23
` A I teach approximately even numbers of 09:28:24
` undergraduate and graduate classes. 09:28:26
` Q So four? 09:28:30
` A This past term I taught two 09:28:31
` undergraduate classes and one graduate class. 09:28:34
` Q And what are you teaching -- are you 09:28:37
` between terms right now? 09:28:40
` A Our new term just started last week. 09:28:41
` Q And what are you teaching this 09:28:45
` semester, or term? 09:28:48
` A I don't have any formal classroom 09:28:50
` teaching this term. 09:28:51
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` Q Are you supervising any grad 09:28:55
` students? 09:28:57
` A Yes. 09:29:00
` Q Generally, how many grad students do 09:29:01
` you supervise in any particular term? 09:29:03
` A Well, that number does fluctuate. 09:29:20
` Approximately six at the moment. Maybe as high 09:29:21
` as a dozen. 09:29:25
` Q Can you describe the process for your 09:29:28
` supervision of a grad student attending the 09:29:31
` University of Michigan? What generally do you 09:29:34
` do? 09:29:37
` A Could you repeat the question, 09:29:44
` please? 09:29:45
` Q What does it mean to supervise a grad 09:29:45
` student? 09:29:47
` A There are different roles as a mentor 09:29:50
` for different types of graduate students. So 09:29:56
` that's why I'm hesitating a bit on your 09:29:59
` question. I'm not sure which graduate student 09:30:00
` in which role are you -- 09:30:03
` Q Well, a graduate student that's 09:30:05
` pursuing a master's, what kinds of things do 09:30:07
` you do with that person? 09:30:10
`
`Page 11
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` JEFFREY STEIN
` A So that person would tend to require 09:30:16
` some counseling about course choices, some 09:30:18
` discussion about research options that they 09:30:28
` might consider, some options -- or discussion 09:30:30
` about companies they might work with in 09:30:37
` different kinds of industries, different kinds 09:30:39
` of areas that -- the courses that they're doing 09:30:41
` work in might lead to. 09:30:45
` And there are also those master's 09:30:54
` students who I actually specifically end up 09:30:58
` engaged in a research project with, which -- 09:31:00
` and then, of course, there's considerable 09:31:03
` discussion about the content of the research 09:31:06
` that we're doing together. 09:31:09
` Q Do you write papers with your 09:31:14
` students? 09:31:15
` A Yes. 09:31:16
` Q How often? 09:31:18
` A Well, we have my CV. There's 09:31:19
` hundreds of publications there. So divide the 09:31:21
` number of years by the number of publications, 09:31:24
` vice versa, you'll get a number. 09:31:28
` Q Somewhere around eight to ten a year, 09:31:30
` if my math is right? 09:31:33
`
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` A Some number like that. 09:31:34
` MR. CORDELL: Let me go ahead and 09:31:36
` mark as Exhibit 1 your declaration in 09:31:37
` this case. 09:31:39
` The declaration that I have in 09:31:48
` front of me for United States Patent 09:31:48
` 88,214,097, IPR Case No. IPR2014-00570. 09:31:49
` In this case it's marked as FMC-1002. 09:31:56
` (Marked Deposition Exhibit 1; 09:32:13
` Declaration of Dr. Jeffrey L. Stein 09:32:13
` in Support of Petition for Inter 09:32:13
` Partes Review; Appendix A, CV; and 09:32:13
` Appendix B, List of Materials 09:32:13
` Considered. Bates FMC 1002.) 09:32:13
` BY MR. CORDELL: 09:32:15
` Q Mr. Stein, let me hand you your, and 09:32:15
` attached to the back is your CV, correct? 09:32:17
` A Yes. I found it. 09:32:51
` Q And you have hundreds of papers 09:32:53
` listed here, right? 09:32:58
` A Yes. 09:33:01
` Q I actually counted them up in your 09:33:19
` declaration. In paragraph 10, you said you've 09:33:23
` authored over 65 journal articles, 13 of which 09:33:27
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`Page 13
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` JEFFREY STEIN
` are related to hybrid electric vehicles; is 09:33:31
` that right? 09:33:39
` A Yes. I see that paragraph. 09:33:59
` Q Is that accurate? 09:34:00
` A I've authored 65 journal articles -- 09:34:02
` over 65 journal articles, including at least 13 09:34:03
` articles that are related to hybrid electric 09:34:08
` vehicles. 09:34:12
` And I've also contributed over 115 09:34:13
` referee conference papers, including at least 09:34:14
` 18 papers that are related to hybrid electric 09:34:16
` vehicles. 09:34:20
` Q So not quite 200, but almost; is that 09:34:21
` right? 09:34:24
` A That would be fair. In the CV that's 09:34:35
` attached, there are a few more that are not 09:34:38
` included. 09:34:41
` Q Let's go back to the CV and Appendix 09:34:41
` A. And just picking the first few, you have 09:34:44
` articles directed to things like "Influence of 09:34:48
` Fifth Wheel Location on Truck Ride Quality," 09:34:52
` and "Stance Phase Control of Above-Knee 09:34:54
` Prosthesis: Knee Control Versus SACH Foot 09:34:58
` Design," and "Evaluation of DC Servo Machine 09:34:58
`
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` JEFFREY STEIN
` Tool Feed Drives as Force Sensors." 09:35:01
` How do you select topics for these 09:35:07
` papers? 09:35:10
` A That's an interesting question, a 09:35:32
` complicated question, I think. 09:35:36
` But just generally speaking, papers 09:35:37
` are generated as a result of -- of results you 09:35:39
` get from your research work. You decide where 09:35:43
` the new contributions are and you write a paper 09:35:47
` on the contribution. 09:35:50
` Q So maybe my question should be 09:35:52
` different then. 09:35:54
` How do you decide the direction or 09:35:55
` focus of your research work? 09:35:58
` A That's also an interesting question, 09:36:09
` a complicated question. It's a question that 09:36:11
` all faculty members have to think long and hard 09:36:14
` about. 09:36:20
` But you -- it's a combination of a 09:36:27
` number of factors, things that you have some 09:36:32
` inherent interest in; things that are important 09:36:37
` to local industry and the country and the 09:36:40
` world, in terms of problems that need to be 09:36:44
` solved. 09:36:48
`
`Page 15
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` JEFFREY STEIN
` There are also issues that are 09:36:49
` related to what the national funding agencies 09:37:00
` are thinking are important topics. They 09:37:04
` release call for proposals in particular areas, 09:37:07
` so that also drives it. 09:37:12
` There are many, many things that 09:37:16
` drive the different kinds of decisions that are 09:37:18
` made by faculty members to work in different 09:37:20
` areas and different topics. 09:37:26
` Q So sometimes do your students suggest 09:37:29
` areas of interests that you then pursue as a 09:37:31
` topic of research? 09:37:35
` A Certainly all students bring to the 09:37:47
` table their own personal interests, both 09:37:49
` intellectually and in terms of industry that 09:37:52
` they're interested in working in, and 09:37:54
` applications they're interested in working on. 09:37:56
` That ends up blending in with the 09:37:59
` needs of the research lab, my lab in this case; 09:38:03
` or if I'm working with other faculty members, 09:38:06
` then these might be group efforts that 09:38:10
` represent a confluence of interest in a 09:38:16
` confluence of funding agencies. 09:38:20
` Q When it comes time to write a paper, 09:38:23
`
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` do you generally try to write up the new 09:38:26
` developments as a particular traunch of 09:38:31
` research? 09:38:35
` A Can you rephrase that question? 09:38:36
` Q I'll try again. 09:38:39
` So you mentioned a few minutes ago 09:38:39
` that when you write a paper, you try to present 09:38:42
` whatever new developments you've come up with. 09:38:44
` And I would like you to try to describe that 09:38:48
` for me a little bit. 09:38:50
` MR. ANGILERI: Objection, 09:38:52
` foundation. 09:38:53
` BY MR. CORDELL: 09:38:54
` Q Let me try it this way, Dr. Stein: 09:38:54
` Why do you write a paper? 09:38:56
` A As part of the scientific process, 09:39:11
` the idea is to inform the rest of your 09:39:13
` colleagues in particular, but the world more 09:39:17
` generally, of new discoveries that you have 09:39:20
` made so that everybody can benefit from the 09:39:25
` knowledge. 09:39:27
` It helps inform other researchers. 09:39:27
` It helps industry be able to, you know, utilize 09:39:30
` in discoveries in what they are doing. 09:39:34
`
`Page 17
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` JEFFREY STEIN
` It is to everybody's benefit to take 09:39:41
` the research results, the new results that you 09:39:47
` have, and to explain it and provide it in a 09:39:49
` form that's available to everybody. 09:39:55
` Q And when you say "to take the new 09:39:57
` research results that you have," I take it the 09:40:00
` point of the paper is not to repeat what you've 09:40:01
` said before? 09:40:04
` MR. ANGILERI: Objection, form. 09:40:06
` THE WITNESS: So I guess I would 09:40:15
` ask you to rephrase that question, 09:40:15
` please. 09:40:20
` BY MR. CORDELL: 09:40:21
` Q Why? 09:40:21
` A Because it's unclear to me. 09:40:22
` Q What's unclear? 09:40:23
` A Well, if I had a clear understanding 09:40:24
` of what was confusing me, I wouldn't have to 09:40:26
` ask you. 09:40:28
` Q Well, unfortunately, though, that's 09:40:28
` the only way I know how to clean it up is -- 09:40:30
` A Well, just take a random stab at it 09:40:33
` and I'll tell you the next time it comes back. 09:40:36
` Q I don't know. Maybe with this we can 09:40:39
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` try, but ... 09:40:43
` Do you ever write, publish, a 09:40:45
` research paper to repeat the results that you 09:40:51
` had previously published just for that purpose? 09:40:54
` A So in -- I guess one of the things I 09:41:14
` have to ask you to clear up is there are 09:41:16
` different venues for publication. And there 09:41:20
` are different rules around publishing things in 09:41:23
` different venues, slightly different venues. 09:41:27
` So it's hard to give you a completely blanket 09:41:29
` answer to your question. 09:41:37
` Q So sometimes you take something 09:41:38
` that's published in a non-referee journal and 09:41:40
` you might take it to a referee journal and have 09:41:43
` it published there; is that fair? 09:41:45
` A Well, that's one possible scenario, 09:41:48
` although I don't have any publications listed 09:41:51
` here except for a few reports at the very, very 09:41:55
` end that are quite old, actually. All of the 09:41:58
` papers here have been refereed. 09:41:59
` Q Let me ask it this way: Dr. Stein, 09:42:07
` do you ever -- I mean, it would be wrong for a 09:42:07
` new graduate student to come on board and claim 09:42:13
` as his or her own work something that a prior 09:42:16
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` JEFFREY STEIN
` graduate student had done, fair? 09:42:19
` A So I'm not sure exactly what you're 09:42:36
` trying to drive at here. The purpose of each 09:42:39
` paper, in general, is to archive -- amongst 09:42:45
` other things is to archive new findings, new 09:42:53
` results. 09:42:57
` That doesn't mean there isn't some 09:42:59
` material that's common from that paper A with 09:43:00
` some paper B that may be in the same area. 09:43:05
` So there may be some similar 09:43:08
` material. 09:43:10
` Q Well, there's foundational material, 09:43:13
` fair? 09:43:16
` A Background material. There could be 09:43:17
` a considerable overlap. But there should be 09:43:25
` some new material, some new results, some new 09:43:29
` perspective, some new findings in the paper 09:43:32
` that you've -- that you're writing. 09:43:36
` Q There's a level of filtering that 09:43:41
` goes on in the sense that you don't -- you 09:43:45
` don't publish every nuance that you discovered, 09:43:47
` correct? 09:43:53
` MR. ANGILERI: Objection, 09:43:54
` foundation. 09:43:55
`
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` JEFFREY STEIN
` THE WITNESS: I mean, you publish 09:43:59
` new information, new results that you 09:44:01
` have. I don't know what you mean by 09:44:05
` "nuance." 09:44:10
` BY MR. CORDELL: 09:44:11
` Q Well, you can't publish a new paper 09:44:11
` every week, right? 09:44:14
` A There's nothing that prevents one 09:44:16
` from doing that. 09:44:17
` Q Well, physically you can't, right? 09:44:18
` You have to teach; you have to live and do 09:44:21
` other things. 09:44:24
` A It certainly takes a finite amount of 09:44:26
` effort to produce a paper, and it takes a 09:44:29
` finite amount of time. 09:44:31
` Q Let me just ask you, within your 09:44:32
` work, how do you make a decision about whether 09:44:36
` a particular discovery is significant enough to 09:44:39
` merit a new paper? 09:44:42
` A I mean, that's a -- an important 09:44:55
` question that you're asking that is also a 09:45:01
` complicated question that I don't think there's 09:45:03
` just one answer for, but I'll try to answer 09:45:06
` your question, generally speaking. 09:45:09
`
`Page 21
`
` JEFFREY STEIN
` It's one that my colleagues and I 09:45:14
` talk about. And it's actually what the referee 09:45:16
` process is also about, is to decide whether 09:45:18
` there's something new in the paper that is 09:45:23
` being -- that somebody provides to a journal, 09:45:27
` like -- the journal editor or associate editor 09:45:35
` passes the paper out to reviewers who review 09:45:39
` the paper. 09:45:41
` There's this process for trying to 09:45:42
` determine whether there is significant new 09:45:44
` content in the paper, amongst other things. 09:45:46
` Q But that's one of the criteria you 09:45:49
` use to decide whether to publish a new paper, 09:45:51
` significant new content? 09:45:54
` A It's certainly one of the 09:46:19
` requirements for scientific papers, the 09:46:22
` journals that I publish in, is that the paper 09:46:27
` has to have new -- has to have new results. 09:46:31
` It's not the only thing. 09:46:35
` Q So let's took at an example of one of 09:46:41
` these -- I'll try to pick one that's a little 09:46:43
` more recent. 09:46:45
` It looks like entry 57 on Appendix A 09:46:46
` of your CV deals with "Optimal Control of Film 09:46:51
`
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`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`6 (Pages 18 to 21)
`
`6
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`
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`Page 22
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`Page 24
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` JEFFREY STEIN
` Growth in Lithium Ion Battery Packs via" -- 09:47:00
` A Which page are you on, please? 09:47:10
` Q It's page 203 of the document, 1125 09:47:11
` of your CV. 09:47:13
` A Okay. And which publication number? 09:47:19
` Q 57. 09:47:23
` A 57. Okay. I see that particular 09:47:24
` citation, yes. 09:47:39
` Q First, can you describe for us the 09:47:40
` research that led to this paper? 09:47:43
` A That's difficult to articulate 09:48:08
` precisely. 09:48:11
` My work -- this is part of a work 09:48:15
` that's come out of my general interest in 09:48:19
` automotive, more generally, and hybrid electric 09:48:27
` vehicles, more specifically. One of electric 09:48:30
` vehicles was part of that, as well. So part of 09:48:37
` the whole electrification of the 09:48:40
` transportation. 09:48:43
` And the use of batteries is clearly 09:48:54
` one of the key components in the development of 09:48:56
` hybrid electric vehicles and electric vehicles 09:48:58
` and the electrification of vehicles, more 09:49:01
` generally. 09:49:04
`
`Page 23
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` JEFFREY STEIN
` And so understanding how batteries 09:49:05
` behave, how batteries deteriorate. In this 09:49:15
` context it's important, so it's in that general 09:49:19
` framework. 09:49:21
` Q Well, you collaborate here with a 09:49:22
` group of people, Moura, Forman, Bashash, and 09:49:24
` Fathy; is that right? 09:49:26
` A Fathy. 09:49:26
` Q Fathy. 09:49:32
` How did you come to coll