`
`NEIL HANNEMANN
`
`April 8, 2015
`
`Prepared for you by
`
`Bingham Farms/Southfield • Grand Rapids
`Ann Arbor • Detroit • Flint • Jackson • Lansing • Mt. Clemens • Saginaw
`
`FORD 1244
`
`
`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 8, 2015April 8, 2015
`
`Page 1
`
`Page 3
`
` A P P E A R A N C E S
`
`ON BEHALF OF PETITIONER:
` FRANK A. ANGILERI, ESQUIRE
` JOHN P. RONDINI, ESQUIRE
` ANDREW B. TURNER, ESQUIRE
` BROOKS KUSHMAN, PC
` 1000 Town Center
` 22nd Floor
` Southfield, MI 48075
` (248) 226-2913
`
`ON BEHALF OF THE PATENT OWNER:
` W. PETER GUARNIERI, ESQUIRE
` LINDA LIU KORDZIEL, ESQUIRE
` FISH & RICHARDSON
` 1425 K Street, NW
` 11th Floor
` Washington, DC 20005
` (202) 783-5070
`
`ALSO PRESENT:
` Frances Keenan, Paice LLC
`
`Page 4
`
` C O N T E N T S
`
`EXAMINATION OF NEIL HANNEMANN PAGE
`
` By Mr. Angileri 5
`
`1
`
`2 3 4
`
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`
`2 3
`
`4
`
`5
`
` 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, : IPR2014-00570
`
` INC., :
`
` Patent Owner. :
`
` :
`
`- - - - - - - - - - - - - - - - -x
`
` Oral Deposition of NEIL HANNEMANN
`
` Washington, DC
`
` Wednesday, April 8, 2015
`
` 12:55 p.m.
`
`Job No.: 78384
`
`Pages: 1 - 87
`
`Reported By: Rebecca Stonestreet, RPR, CRR
`
` Oral Deposition of NEIL HANNEMANN, held at the
`
`offices of:
`
`Page 2
`
`1
`
`2
`
`3 4 5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`1
`
`2
`
` FISH & RICHARDSON, PC
`
` By Mr. Guarnieri 83
`
` E X H I B I T S
`
` (Retained by Counsel.)
`
`HANNEMANN EXHIBIT PAGE
`
` 1 Declaration of Neil Hannemann 5
`
` 2 U.S. Patent No. 8,214,097 5
`
` 3 U.S. Patent No. 5,343,970 5
`
` 4 "The Effects of APU Characteristics on the
`
` Design of Hybrid Control Strategies for
`
` Hybrid Electric Vehicles" 5
`
` 5 Curriculum Vitae 70
`
` 6 Supplemental Declaration 80
`
`6 7 8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` 1425 K Street, NW
`
` 11th Floor
`
` Washington, DC 20005
`
` (202) 783-5070
`
` Pursuant to notice, before
`
`Rebecca Stonestreet, Registered Professional Reporter,
`
`Certified Realtime Reporter, and Notary Public in and for
`
`the District of Columbia, who officiated in administering
`
`the oath to the witness.
`
`3 4 5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`
`
`Pages 1 to 4Pages 1 to 4
`
`FORD 1244
`
`
`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 8, 2015April 8, 2015
`
`Page 5
`
`Page 7
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
` P R O C E E D I N G S
`
` (HANNEMANN Exhibits 1 through 4 were marked
`
`for identification and retained by counsel.)
`
` (NEIL HANNEMANN, having been duly sworn, testified as
`
` follows:)
`
` EXAMINATION BY COUNSEL FOR PETITIONER
`
`BY MR. ANGILERI:
`
` Q Can you state your name for the record,
`
`please?
`
` A Neil Hannemann.
`
` Q Mr. Hannemann, the reporter has marked, as
`
`Exhibits 1 through 4, documents that I expect we'll get
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`review the declaration, the prior art, and the patent.
`
` Q When did you come here last week to meet with
`
`counsel?
`
` A On Wednesday.
`
` Q How long were you here?
`
` A Probably about most of the day, the normal
`
`workday.
`
` Q Did you leave at the end of the day?
`
` A Yes.
`
` Q Where did you go? Did you go back home?
`
` A No, no, I stayed in Washington. I met for
`
`three days last week. I arrived here Wednesday and met
`
`13 Wednesday, Thursday, Friday.
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`into today.
`
` What is Exhibit 1?
`
` A Exhibit 1 is the declaration that I prepared
`
`in this matter.
`
` Q And this matter is IPR 2014-00570?
`
` A That's correct.
`
` Q Concerning -- strike that.
`
` What's Exhibit 2?
`
` A Exhibit 2 is U.S. Patent 8,214,097.
`
` Q And that's the patent that's at issue in this
`
`IPR?
`
` A That's correct.
`
` Q We sometimes call it the '097 patent?
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` Q With counsel?
`
` A Yes.
`
` Q Did you prepare at all on Monday?
`
` A Yes, I did.
`
` Q Did you -- were you on any flights on Monday?
`
` A Yeah, I flew back here Monday.
`
` Q From where?
`
` A I was actually in Texas.
`
` Q So you were in Washington, D.C., Wednesday,
`
`Thursday, Friday of last week meeting with counsel for
`
`Paice?
`
` A Yes.
`
`Page 8
`
`Page 6
`
` A That's correct.
`
` Q What is Exhibit 3?
`
` A It's Patent Number 5,343,970.
`
` Q Sometimes we call that the '970 patent?
`
` A That's correct.
`
` Q That's part of the prior art that's at issue
`
`in this IPR?
`
` A Yes, it is.
`
` Q What is Exhibit 4?
`
` A It's an SAE paper, 950493, titled "The Effects
`
`of APU Characteristics on the Design of Hybrid Control
`
`Strategies for Hybrid Electric Vehicles."
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
` Q And then you left Washington, D.C.?
`
` A Yes.
`
` Q And then you came back on Monday?
`
` A That's correct.
`
` Q Who did you meet with on Wednesday, Thursday
`
`and Friday last week?
`
` A Well, at various times Mr. Guarnieri,
`
`Mr. Marcus, and Ms. Kordziel.
`
` MR. GUARNIERI: For the record I think he's
`
`referring to Mr. Livedalen, Brian.
`
` THE WITNESS: Oh, sorry.
`
` Q How did you prepare the declaration that's
`
`been marked as Exhibit 1?
`
` Q One of the named authors is a person named
`
`Catherine Anderson. Correct?
`
` A That's correct.
`
` Q And as a result, we sometimes refer to this as
`
`the Anderson paper or just Anderson?
`
` A Yes.
`
` Q What did you do to prepare for this deposition
`
`and the depositions that you've had yesterday and today?
`
` A Well, I --
`
` MR. GUARNIERI: And I'll just caution him not
`
`to get into any privileged communications.
`
` But you can answer.
`
` A I came here last week to meet with counsel and
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` A Quite a while ago, I reviewed all the material
`
`that was the prior art and the patent and had -- I came
`
`here to Washington to meet with counsel and discuss all
`
`the elements, the technical matters.
`
` And then I worked with counsel to, you know,
`
`draft up various portions of this, or add or work through
`
`a draft until arriving at this product.
`
` Q Did counsel prepare first drafts of any
`
`portions of Exhibit 1?
`
` A Yeah, there were some portions that they
`
`drafted up initially.
`
` Q Do you know which portions?
`
`
`
`Pages 5 to 8Pages 5 to 8
`
`FORD 1244
`
`
`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 8, 2015April 8, 2015
`
`Page 9
`
`Page 11
`
` A You know, I might be able to pick some out.
`
`I'm not sure I would be getting all of them correct.
`
` Q Which portions of Section 8 did counsel
`
`prepare the first draft of?
`
` A That's one where I'm not sure which section
`
`started with counsel or myself.
`
` Q Can you identify any section that you prepared
`
`the first draft of?
`
` A Yeah. My memory is probably not that good to
`
`go back and define it to that level of detail.
`
` Q The other declarations that we marked in 571
`
`and 579 depositions that were yesterday and today -- do
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`declarations?
`
` A I really don't have any idea, as I sit here.
`
` Q Do you know how much time you spent on all six
`
`of those proceedings combined?
`
` A Not really.
`
` Q Do you know how much you've billed Paice for
`
`these six proceedings?
`
` A I would have invoices, but I don't have those
`
`with me.
`
` Q Can you estimate to within $100,000 of how
`
`much you've billed Paice?
`
` A Sure. I think it's pretty safe to say it's
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`you recall those declarations?
`
` A Yes.
`
` Q Were they prepared in a similar manner as the
`
`manner you just described --
`
` A Yeah.
`
` Q -- in Exhibit 1?
`
` A Yeah, in a similar manner.
`
` Q And for those two declarations, can you recall
`
`any section that you prepared the first draft of?
`
` A Some of the sections and probably the more
`
`technical sections are probably ones that I prepared.
`
`And, certainly, my background is something that I
`
`started.
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`less than $100,000.
`
` Q Is it less than $50,000?
`
` A It's really hard to say without checking, but
`
`it's likely that it is.
`
` Q Is it less than $25,000?
`
` A Probably not.
`
` Q Can you look at Exhibit 3, please?
`
` A (Witness complies.)
`
` Q Exhibit 3 is the '970 patent. Correct?
`
` A Yes.
`
` Q The '970 patent describes a parallel system.
`
`Is that correct?
`
` A Yes, it does.
`
`Page 12
`
`Page 10
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
` Q Is there anything specifically that you can
`
`identify as preparing the first draft of other than your
`
`background?
`
` A Specifically in this declaration, or are you
`
`talking the other ones also?
`
` Q Any of the three.
`
` A Any of them. I just don't remember which ones
`
`I started or somebody else may have started.
`
` Q How much time did you spend preparing or
`
`working on -- strike that.
`
` How much time did you spend -- strike that.
`
` How much time have you spent in these three
`
`proceedings, 570, 571 and 579?
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
` Q Does the '970 patent have a mode where only
`
`the motor is used to propel the vehicle?
`
` A Yes, it does.
`
` Q And does it have a mode where only the engine
`
`is used to propel the vehicle?
`
` A Yes, it does.
`
` Q Does it have a mode where the engine and the
`
`motor are both used to propel the vehicle?
`
` A Yes, it does.
`
` Q When the motor is used to propel the vehicle,
`
`is the engine disconnected from the wheels through a
`
`clutch?
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` A I don't think I've really tracked my time for
`
`each proceeding, so that's hard to say.
`
` Q What about the three proceedings combined?
`
` A Well, these have overlapped with three other
`
`proceedings that are ongoing now, so it would be hard to
`
`really break that out.
`
` Q Can you tell me how much time you've spent on
`
`the -- strike that.
`
` How many proceedings have you worked on for
`
`Paice thus far?
`
` A The six that I've prepared declarations for.
`
` Q How much time have you spent on those six
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` MR. GUARNIERI: I'm going to object to the
`
`extent it calls for speculation.
`
` A Figure 3 shows a clutch, and up through
`
`Figure 9 shows a clutch. So at least the ones disclosed
`
`in those figures appear to use a clutch to disconnect the
`
`engine.
`
` Q Is it true that in order to run in the
`
`motor-only mode for the '970 patent, you actually have to
`
`disconnect the engine from the wheels?
`
` A Are you speaking generically or in the scope
`
`of this patent?
`
` Q In the '970 patent.
`
` A I don't recall seeing any language where it
`
`
`
`Pages 9 to 12Pages 9 to 12
`
`FORD 1244
`
`
`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 8, 2015April 8, 2015
`
`Page 13
`
`Page 15
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`specifically requires the clutch be disconnected.
`
` Q If the clutch doesn't disconnect the engine,
`
`would you agree, then, that the engine would always have
`
`to be running?
`
` A Unless there's some mechanism within what they
`
`1
`
`2
`
`3
`
`4
`
`5
`
`total power required. So they're both providing less.
`
` Q Do you agree that the '970 patent can enter an
`
`acceleration hill-climbing mode before it reaches the
`
`engine's MTO or minimum torque output?
`
` A Yeah. According to the '970, it enters that
`
`describe as a torque transfer unit that could allow the
`
`6 mode based on vehicle speed.
`
`unit to --
`
` THE REPORTER: A torque trans?
`
` THE WITNESS: Torque transfer unit.
`
` Q Do you agree that for the -- to run in a
`
`motor-only mode, somehow -- strike that.
`
` Do you agree that for the '970 to run in the
`
` Q And that can -- I don't agree with you there,
`
`but you agree that can happen before the engine reaches
`
`its maximum torque output or MTO?
`
` MR. GUARNIERI: Objection. Form.
`
` A Yeah. And I guess the word "reaching" implies
`
`that the engine is already on. So if the engine is not
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`motor-only mode and not -- strike that.
`
` Do you agree that for the '970 patent to run
`
`in the motor-only mode, it somehow has to disconnect the
`
`engine from the wheels in order to do that?
`
` A I would think that's a reasonable thing to do.
`
`I just don't see where it specifically states that.
`
` Q Do you think that's how a person of ordinary
`
`skill in the art would understand the '970 patent?
`
` A I think in the presence of the clutch, that's
`
`how someone would understand it operated.
`
` Q So just to be clear, a person of skill in the
`
`art would understand that when the '970 patent is running
`
`in motor-only mode, it's using the clutch to disconnect
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`already on, it's not going to reach any torque.
`
` Q Are you saying that the '970 can enter
`
`acceleration hill-climbing mode by starting with the
`
`motor and then adding the engine?
`
` A I think that's one way it can enter that mode,
`
`yes.
`
` Q And obviously in that case you are using both
`
`the motor and the engine in a situation where the engine
`
`has not yet hit its maximum torque output. Correct?
`
` A Yeah. I think that there's points in the
`
`high-speed acceleration/hill-climbing mode where the
`
`engine is not at its maximum torque.
`
` Q And you're using the motor and the engine at
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Page 16
`
`Page 14
`
`the engine from the wheels. Do you agree with that
`
`statement?
`
` A Yes, I do.
`
` Q Do you agree that an object of the invention
`
`of the '970 patent is reducing emissions?
`
` A I think that's an aspirational goal, to reduce
`
`emissions, yes.
`
` Q In fact, if you look at Column 5, Lines 24 to
`
`30, isn't that the first stated object of the invention
`
`in the '970 patent?
`
` A Yes.
`
` Q Do you agree that in the acceleration
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`those times. Right?
`
` A Yes.
`
` Q Do hybrid vehicles use AC motors or DC motors?
`
` A I would say most of them use AC motors
`
`currently. There have been some that have used DC motors
`
`in the past.
`
` Q In the past, were DC motors a better fit?
`
` MR. GUARNIERI: Objection. Vague.
`
` A Yeah. It depends on the design goals and the
`
`design criteria.
`
` Q Which is a better -- which is better to use?
`
`AC motors or DC motors?
`
` MR. GUARNIERI: Same objection. Vague.
`
`hill-climbing mode of the '970 patent, the motor is used
`
`to supplement the engine?
`
` MR. GUARNIERI: Objection. Assumes facts not
`
`in evidence and calls for speculation.
`
` A Yeah, I agree in the high-speed
`
`acceleration/hill-climbing mode, both the internal
`
`combustion engine and the electric motor provide torque
`
`to the road wheels.
`
` Q Do you agree, then, that in that situation,
`
`the engine is providing less than the amount of torque
`
`required to operate the vehicle?
`
` A Yeah. You have torque coming from both the
`
`engine and the motor, so neither one is providing the
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` A Yeah. It depends on what's important in your
`
`design. If it's performance, weight, cost, all those
`
`issues can drive a different design decision.
`
` Q Is a person of ordinary skill in the art going
`
`to consider those design criteria, that you just
`
`mentioned, when making a choice between AC and DC motors?
`
` A Yeah. I think every choice designing a car
`
`has cost, weight, and performance implications.
`
` Q So would a person of ordinary skill in the art
`
`consider the factors you identified in choosing between
`
`AC and DC motors?
`
` A Those are some of the factors they would
`
`
`
`Pages 13 to 16Pages 13 to 16
`
`FORD 1244
`
`
`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 8, 2015April 8, 2015
`
`Page 17
`
`Page 19
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`consider, yes.
`
` Q Any others that come to mind?
`
` A In a broad sense that's -- those are the main
`
`criteria.
`
` Q The Anderson reference, which is Exhibit 4 --
`
`and you can certainly consult it if you want -- talks
`
`about transients. Do you see that?
`
` A Yes.
`
` Q What are the transients that Anderson is
`
`speaking about?
`
` MR. GUARNIERI: Object to the extent that
`
`calls for speculation.
`
`the bookends of a series strategy, at least for
`
`controlling the engine.
`
` Q So that contemplates sort of a modified
`
`follower strategy, where sometimes you follow demand and
`
`sometimes you don't. Do you agree with that?
`
` MR. GUARNIERI: Object to the extent that
`
`calls for speculation.
`
` A I think somebody that's skilled in the art
`
`would realize you could -- you could blend these for a
`
`specific strategy.
`
` Q What would a nonextreme follower mode look
`
`like? Strike that.
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` A Yeah. Transients can be -- transient is a
`
` What would be one example of a nonextreme
`
`generic term that can relate to any kind of a changing
`
`condition. I think someone of skill in the art would
`
`realize that Anderson is speaking about an engine speed
`
`transient.
`
` Q Anderson talks about an LLD. Do you remember
`
`that?
`
` A Yes.
`
` Q Do you agree that's a battery?
`
` A Not always. But I think in her context she's
`
`always referring it back to a battery, but one of the
`
`vehicles that I worked on had a flywheel as an LLD.
`
` So it can be many other devices. That's why
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`follower mode that a person of skill in the art would
`
`understand?
`
` MR. GUARNIERI: Objection. Vague.
`
` Q Circa 1988.
`
` MR. GUARNIERI: Same objection.
`
` A Well, I think that one thing that we may have
`
`been thinking about is how to use these types of
`
`strategies when you have a plug-in vehicle. And in that
`
`case you might modify this strategy so that you -- to a
`
`degree, deplete the state of charge through operation so
`
`you can take advantage of plugging the vehicle in.
`
`That's one area, one example I could conceive of
`
`Page 20
`
`Page 18
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`she uses the generic term. But I think every specific
`
`reference to that in her paper is referring to a battery.
`
` Q Do you agree that if you use a motor to
`
`supplement an engine, you're going to put a strain on the
`
`battery --
`
` MR. GUARNIERI: Objection.
`
` Q -- by cycling the battery?
`
` MR. GUARNIERI: Objection. Vague.
`
` A Yeah. The word "strain" to me means something
`
`that may be outside of its normal duty cycle. So hybrid
`
`electric vehicle or any vehicle that uses a battery is
`
`designed for a certain duty cycle. And if you work
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`modifying the strategy.
`
` Q So in that example, you said it's a plug-in
`
`hybrid?
`
` A If your design goal or if your vehicle design
`
`criteria included a plug-in strategy, then it's likely
`
`you would modify the -- this control strategy.
`
` Q When you use the term "plug-in," what do you
`
`mean?
`
` A Well, everything Anderson is discussing is
`
`trying to maintain a given fixed state of charge in the
`
`battery. If you realize that you have the capability to
`
`plug the vehicle in, then you can deplete the charge, and
`
`when you plug the vehicle in. You can take the energy
`
`within that duty cycle, then you're not per se straining
`
`the battery. You're operating it as intended.
`
` Q Do you agree that Anderson identifies what she
`
`calls two distinct extremes in the spectrum of control
`
`strategies?
`
` A In the context she's talking about is for a
`
`series hybrid. She has extreme control strategy that she
`
`calls the thermostat and one that she calls the follower
`
`strategy.
`
` Q And she says that neither of those extremes is
`
`normally used in the real world. Right?
`
` A Yeah. She says realistically you may use
`
`something in between, but she feels that those are, say,
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`from the wall socket rather than generating all the
`
`battery charge energy from the engine.
`
` Q Okay. And in your answer you said that if
`
`you're talking about a plug-in, your words were, "It's
`
`likely you would modify this control strategy."
`
` Which control strategy are you referring to in
`
`that answer?
`
` A Well, the control strategy that Anderson
`
`discusses for a series hybrid, which is bookended by the
`
`thermostat and follower modes.
`
` Q What do you mean by "bookended"? Is it a
`
`follower strategy or a thermostat strategy that you're
`
`
`
`Pages 17 to 20Pages 17 to 20
`
`FORD 1244
`
`
`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 8, 2015April 8, 2015
`
`Page 21
`
`Page 23
`
`modifying?
`
` A Well, I think it would be -- I think they're
`
`both different strategies. It would just be a third
`
`strategy.
`
` Q What would be the third strategy?
`
` A I could conceive having a strategy for the
`
`concept of using a plug-in vehicle.
`
` Q And are you saying that this plug-in strategy
`
`that you're describing is a modification of a follower
`
`extreme, or is it a modification of a thermostat extreme?
`
` MR. GUARNIERI: Objection. Vague.
`
` A I mean, I think it would be a third strategy
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
` A Yeah. A constant state of charge, but there
`
`is a range for switching it on and off. So there is some
`
`hysteresis built into the system.
`
` Q Because Anderson says that you turn on the
`
`engine when the state of charge of the battery is below a
`
`certain lower threshold, and you turn off the engine when
`
`the state of charge exceeds an upper threshold. Correct?
`
` A That's correct.
`
` Q So the state of charge of the battery in the
`
`extreme thermostat strategy varies between this lower
`
`threshold and upper threshold?
`
` A That's correct.
`
`that's somewhere in between the two.
`
` Q How so?
`
` A Well, as I said, both of these strategies
`
`strive to maintain a certain state of charge. The third
`
`strategy would have some kind of a depletion to the
`
`charge. I guess you could do that with either one. You
`
`could start with one or the other and modify it to arrive
`
`at that.
`
` Q Explain, for the record, the thermostat
`
`strategy, the thermostat extreme strategy. Strike that.
`
` Explain for the record the extreme thermostat
`
`strategy.
`
` MR. GUARNIERI: Object to the form of the
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` Q What about the extreme follower strategy? How
`
`does that work?
`
` MR. GUARNIERI: Object to the form of the
`
`question.
`
` A That strategy is the controller -- or the
`
`strategy itself commands the APU to follow the actual
`
`real torque whenever possible.
`
` Q And the APU is the engine. Right?
`
` A Yes.
`
` Q Which of these two extremes has more engine
`
`transients?
`
` MR. GUARNIERI: Objection. Vague.
`
` A That would depend on the upper and lower
`
`Page 24
`
`Page 22
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`question as vague.
`
` A And you said the extreme thermostat strategy?
`
` Q Yes.
`
` A Okay. I'm just looking to find Anderson's
`
`explanation, to be most accurate.
`
` Okay. She describes the thermostat as the --
`
`the thermostat algorithm is used to command an APU, which
`
`is what she's referring to as an engine -- what she's --
`
`auxiliary power unit, so her engine. You turn the
`
`auxiliary power unit on to a constant power level when
`
`the state of charge of the load-limiting device is below
`
`a certain lower threshold.
`
` Q Where are you reading?
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`threshold of the thermostat. If those were set very
`
`close, that would create more transition.
`
` So the thermostat algorithm could have a wide
`
`variety of trance audience based on how the designers
`
`choose to calibrate the system.
`
` Q If the upper and lower thresholds and the
`
`therm motors are not set very close, then you agree that
`
`the follower extreme is going to have more transients
`
`than the thermostat extreme?
`
` MR. GUARNIERI: Same objection.
`
` A I would say it would have more engine speed
`
`transients.
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` A I'm on page 5 of 9 of the Anderson paper. I
`
`believe it's -- 67 is another page number on it.
`
` Q So please, again, describe the extreme
`
`thermostat strategy.
`
` A All right. The reference to a thermostat is
`
`how a thermostat works in the home. But, basically, when
`
`the stated charge drops to a certain level, the auxiliary
`
`power unit is turned on to a constant power level, and
`
`then it switches off again when the state of charge
`
`exceeds an upper threshold.
`
` Q So the thermostat strategy does not strive to
`
`maintain a constant state of charge. Correct?
`
` Q What are those engine speed transients caused
`
`by?
`
` A Well, engine speed would increase as a result
`
`of opening the throttle in the engine. And it could also
`
`result from closing the throttle because a decrease in
`
`RPM is also an engine speed transient.
`
` Q In the case of an increase, why is the engine
`
`speed -- strike that.
`
` In the case of an increase, why is the
`
`controller opening throttle in the engine?
`
` A Well, it wouldn't necessarily be a controller.
`
`It could be the operator opening the throttle.
`
` Q Okay. So let's --
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`
`
`Pages 21 to 24Pages 21 to 24
`
`FORD 1244
`
`
`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 8, 2015April 8, 2015
`
`Page 25
`
`Page 27
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
` A But --
`
` Q Just -- since you said that --
`
` MR. GUARNIERI: Do you want him to answer, let
`
`him finish?
`
` MR. ANGILERI: Not really. I'm going to
`
`clarify so he doesn't waste our time.
`
` Q Let's assume that this -- that we're talking
`
`about a vehicle that's operated by a controller. Can you
`
`accept that assumption?
`
` A I can, although I think Anderson doesn't
`
`specify a controller. But if you want to move more
`
`generically, that's fine.
`
`acceleration, and it's pretty transparent to most drivers
`
`whether they're getting power or torque or what's going
`
`on.
`
` Q Do you agree that in order to accelerate the
`
`vehicle, the vehicle is going to have to provide
`
`additional torque at the wheels?
`
` MR. GUARNIERI: Objection. Vague.
`
` A I mean, I think you can talk about that in
`
`aspects of power or torque.
`
` Q So whether the driver knows it or not, they're
`
`effectively requesting additional power and torque at the
`
`wheels in order to accelerate the vehicle when they push
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` Q Let's do that. Because engine controllers
`
`the pedal down. Do you agree with that?
`
`were common at the time of Anderson, or at least they
`
`were known to a person of skill in the art at the time of
`
`Anderson. Correct?
`
` A Well, engine controllers that -- so you're
`
`talking about an engine controller that controls the
`
`throttle?
`
` Q Yes.
`
` A Yeah. And they weren't in widespread usage,
`
`but they were known on a prototype basis.
`
` Q Okay. So let's go back to my question.
`
` In the case of an engine speed increase for
`
`the follower, extreme follower method -- strike that.
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` A Right. And it's power that they're
`
`requesting, because depending on the engine RPM, the
`
`torque can be, you know, varied or limited.
`
` Q At the wheel, they're asking for power and
`
`torque. Do you agree?
`
` A I would say the driver is really asking for
`
`power, and you can resolve that into torque and speed the
`
`same way that Bumby does his calculations.
`
` Q If there's no transmission or there's no
`
`change in the gear in a transmission, then when the
`
`driver pushes the pedal down, the driver is effectively
`
`asking for more power and more torque. Do you agree with
`
`Page 28
`
`Page 26
`
` In the case of an engine speed increase for
`
`the follower method, why is the controller opening the
`
`throttle in the engine?
`
` MR. GUARNIERI: I'm going to object as vague.
`
` A Well, that would also be in response to the
`
`driver command.
`
` Q What kind of command?
`
` A Accelerator pedal. The operator -- the
`
`follower strategy is very similar to how a conventional
`
`vehicle operates, since it's trying to respond to the
`
`actual wheel power, which comes from a -- you know, the
`
`operator command.
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`that?
`
` A Well, I can envision a situation where the
`
`flat torque curve; somebody may increase the accelerator
`
`pedal position and the torque remains the same over a
`
`time period, but the engine speed is increasing. So the
`
`power is going up, but the torque is staying the same.
`
` So it's really more of a power-based demand.
`
` Q And what if you're not at the point on the
`
`torque curve where the torque flattens out? If you're on
`
`the point of the torque curve where the torque is
`
`increasing, then would you agree that when the driver
`
`tips in with the accelerator pedal and tries to
`
`accelerate the vehicle, the driver is requesting more
`
` Q The operator is depressing the pedal?
`
` A Pressing or releasing the pedal, yes.
`
` Q In the case of an increase in speed, he's
`
`probably pressing the pedal. Right?
`
` A Yes.
`
` Q And the driver is asking for more torque from
`
`the engine. Right?
`
` A Or power. I would say generally the driver is
`
`after power because there's a speed element to the
`
`engine.
`
` Q At a given speed, the driver is going to be
`
`asking for both, more power and more torque?
`
` A The driver in reality is just requesting
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`torque at the wheel?
`
` MR. GUARNIERI: Objection. Vague and object
`
`to the form.
`
` A Yeah. The torque is a result of the driver
`
`command, but it's a coincidence if it goes up or down or
`
`stays the same.
`
` But in all considerations, when somebody
`
`applies the accelerator, they're going to get, you know,
`
`increasing power regardless of the torque going up and
`
`down.
`
` Q At the moment in time when