`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` FORD MOTOR COMPANY, )
` )
` Petitioner, )
` )
` vs. ) Case Number
` ) IPR2014-01415
` PAICE LLC and ABELL )
` FOUNDATION, INC., )
` )
` Patent Owner. )
`
` DEPOSITION OF JEFFREY L. STEIN, Ph.D.
`
` Southfield, Michigan
`
` Friday, May 29, 2015
`
`Reported by:
`
`RACHEL F. GARD, CSR, RPR, CLR, CRR
`
`REF NO. 14261B
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`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`FORD 1245
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`Page 2
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`Page 4
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` I N D E X
`1
`2 WITNESS PAGE
`JEFFREY L. STEIN, Ph.D.
`3
` Cross-examination by Mr. Guarnieri 5
`4
`
` E X H I B I T S
`STEIN EXHIBIT PAGE
` Exhibit 7 Declaration of Dr. Jeffrey 5
` L. Stein in Support of
` Second Petition for Inter
` Partes Review
`
` Exhibit 8 U.S. Patent No. 8,214,097 14
`
` Exhibit 9 U.S. Patent No. 5,343,970 14
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` Exhibit 10 Toyota Technical Review, 73
` Volume 47, No. 2,
` April 1998
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`56
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` May 29, 2015
` 1:06 p.m.
`
` Deposition of JEFFREY L. STEIN, Ph.D., at
`the offices of Brooks Kushman, P.C., 1000 Town
`Center, Suite 2200, Southfield, Michigan,
`pursuant to notice before Rachel F. Gard,
`Certified Shorthand Reporter, Registered
`Professional Reporter, Certified LiveNote
`Reporter, Certified Realtime Reporter.
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`1 A P P E A R A N C E S:
` BROOKS KUSHMAN, PC
`2
` Attorneys for Petitioner
`3
` 1000 Town Center
`4
` 22nd Floor
`5
` Southfield, Michigan 48075
`6
` Phone: 248.358.4400
`7
` Email: aturner@brookskushman.com
`8
` fangileri@brookskushman.com
`9
` BY: ANDREW B. TURNER, ESQ.
`10
` FRANK ANGILERI, ESQ.
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` FISH & RICHARDSON
` Attorneys for Patent Owner
` 1425 K Street, NW
` 11th Floor
` Washington, DC 20005
` Phone: 202.783.5070
` Email: guarnieri@fr.com
` BY: W. PETER GUARNIERI, ESQ.
`
`Page 3
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`Page 5
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`1
` (Witness previously sworn.)
`2 WHEREUPON:
`3
` JEFFREY L. STEIN, Ph.D.,
`4
`called as a witness herein, having been
`5
`previously duly sworn, was examined and
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`testified as follows:
`7
` CROSS-EXAMINATION
`8
`BY MR. GUARNIERI: 01:06
`9
` Q. Dr. Stein, you're still sworn in 01:06
`10
`today from the morning. 01:06
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` A. I agree to be. 01:06
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` Q. We're going to ask you questions now 01:06
`13
`on IPR2014-04015. 01:06
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` MR. GUARNIERI: Why don't we mark 01:06
`15
` our first exhibit. 01:06
`16
` (Stein Exhibit Number 7 marked for 01:06
`17
` identification.) 01:06
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`BY MR. GUARNIERI: 01:07
`19
` Q. It should be now Exhibit 7. 01:07
`20
` A. Yes. 01:07
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` Q. And can you identify what Exhibit 7 01:07
`22
`is? 01:07
`23
` A. Declaration of Dr. Jeffrey L. Stein 01:07
`24
`in Support of Second Petition for Inter Partes 01:07
`25
`Review under a bunch of numbers, and this is 01:07
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`2 (Pages 2 to 5)
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`FORD 1245
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`Page 6
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`Page 8
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`for IPR Case Number IPR2014-01415. 01:07
` Q. And the patent subject of this IPR 01:07
`is 8,214,097. You recognize that as the '097 01:08
`patent, right? 01:08
` A. Correct. 01:08
` Q. And can you confirm that that's your 01:08
`signature on Page 320 of your declaration, 01:08
`which for the record is Ford Exhibit 1102? 01:08
` A. Yes. I'm not a handwriting expert, 01:08
`by the way, but it looks like my signature. 01:08
` Q. I hope you signed it and not someone 01:08
`else, sir. 01:08
` A. I certainly signed it. 01:08
` Q. Good. 01:08
` Dr. Stein, when was this declaration 01:08
`executed? 01:08
` A. When did I sign it? 01:08
` Q. When did you sign this declaration? 01:09
` A. August 29th, 2014. 01:09
` Q. So between August 29th, 2014 and 01:09
`today, have any of your opinions expressed in 01:09
`Exhibit 7 changed that you're aware of sitting 01:09
`here today? 01:09
` A. I'm not aware of any opinions 01:09
`expressed in this declaration that I wrote on 01:09
`Page 7
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`and signed on August 29, 2014 that aren't also 01:09
`true today or that I would stand behind today. 01:09
` Q. And then on Pages, I believe it's 01:10
`322 to 349, this is the resume that you 01:10
`submitted along with your declaration; is that 01:10
`correct? I believe it's Appendix A. 01:10
` A. Yes. That's my CV, or one of my 01:10
`CV -- or one form of my CV, I should say. 01:10
` Q. So this declaration looks like it 01:10
`was last updated in January of 2014. Has 01:10
`anything changed on the resume relevant to this 01:10
`IPR? 01:10
` A. Well, certainly my CV has changed 01:10
`since then. I have additional publications 01:11
`that probably are not listed here. I'm happy 01:11
`to give you an updated CV, if you'd like it. 01:11
`There may be an award that's not on here; I'm 01:11
`not sure. But there's certainly possibilities 01:11
`of some things that have changed to it. 01:11
` Q. If you look on Page 347, you have a 01:11
`list of cases that you've -- testimony history 01:11
`for the past 5 years, are there any additional 01:11
`cases that you have testified in in the past 01:11
`roughly year and few months? 01:11
` A. Of course there's this matter, which 01:12
`
`1
`isn't listed here, right? 01:12
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` Q. Aside from these matters. 01:12
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` A. So in what form of testimony? Does 01:12
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`it matter? 01:12
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` Q. Well, we'll take them one at a time. 01:12
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`Have you testified in any District Court cases 01:12
`7
`in the last year that aren't listed on here? 01:12
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` A. I don't believe so. 01:13
`9
` Q. Have you been deposed in any 01:13
`10
`additional matters in the last year that aren't 01:13
`11
`listed here? 01:13
`12
` A. No. I don't believe so. It would 01:13
`13
`be helpful to have my records in front of me, 01:13
`14
`but I don't think so from memory. 01:13
`15
` Q. Have you submitted any declarations 01:13
`16
`in any other IPRs in the last year other than 01:13
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`the PAICE/Ford IPR? 01:13
`18
` A. Yes. 01:13
`19
` Q. And what would those be -- That 01:13
`20
`aren't listed on your resume? 01:13
`21
` A. Yes. 01:13
`22
` Q. And what would those be? Do you 01:13
`23
`remember the names of the IPRs or the names of 01:13
`24
`the company you were retained by in each one? 01:13
`25 Why don't we start with that. 01:13
`
`Page 9
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` A. I don't remember the formal case 01:14
`1
`caption or, you know, the parties caption off 01:14
`2
`the top of my head. I'd have to look it up. 01:14
`3
`I'm glad to provide it to you, but I don't ... 01:14
`4
` Q. Well, why don't we -- How about 01:14
`5
`this? How many IPRs have you worked on, 01:14
`6
`submitted declarations in, in the past year 01:14
`7
`that are not listed on your CV? 01:14
`8
` A. So two IPRs with the same client, if 01:14
`9
`you will. 01:14
`10
` Q. And which client is that? 01:14
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` A. Well, that's -- I'm not sure the 01:14
`12
`precise way that the client would want to be 01:15
`13
`described. But I can say that loosely 01:15
`14
`speaking, it's Chrysler. Chrysler is owned by 01:15
`15
`Fiat, and it's some formal name that I don't 01:15
`16
`remember off the top of my head. 01:15
`17
` Q. I understand. Do you recall which 01:15
`18
`law firm you're working with in those few 01:15
`19
`20 matters? 01:15
` A. I think the law firm's name is 01:15
`21
`22 Venerable. Does that sound familiar? 01:15
` Q. Venable perhaps? 01:15
`23
` A. Venable, thank you. 01:15
`24
` Q. So other than those two IPRs, have 01:15
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`3 (Pages 6 to 9)
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`FORD 1245
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`you submitted declarations or expert reports of 01:15
`some kind in any other proceedings in the past 01:15
`year that are not listed on your CV? 01:15
` A. Yes. 01:16
` Q. So what else? 01:16
` A. So I've submitted a declaration or 01:16
`report/declaration, I don't remember which 01:16
`formal title the document had, under a 01:16
`different case than the IPR matter I just 01:16
`described. 01:16
` Q. What is that case? 01:16
` A. That case was called, captioned 01:16
`Claire versus Chrysler. 01:16
` Q. And were you also working for 01:16
`Chrysler in that matter as well? 01:16
` A. Yes. 01:16
` Q. Do you know if that matter was 01:16
`related to the IPRs that you were working on? 01:16
` A. It's not. 01:16
` Q. Okay. So other than the IPRs and 01:16
`the report or declaration -- sorry, actually 01:16
`let me -- a quick followup, this Claire versus 01:16
`Chrysler, is this a District Court case? 01:17
` A. I don't remember. 01:17
` Q. So other than this Claire versus 01:17
`Page 11
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`the areas that are in the fields or in the 01:18
`1
`concepts that are presented in the '097 patent. 01:19
`2
` Q. Why don't we turn to Paragraph 39 of 01:19
`3
`your declaration. Based on the definition of 01:19
`4
`the relevant field for purposes of the '097 01:19
`5
`patent that you give in Paragraph 39 of 01:19
`6
`Exhibit 7, are you an expert according to your 01:19
`7
`lay understanding of the term "expert" in that 01:20
`8
`relevant field? 01:20
`9
` MR. TURNER: Objection. Form. 01:20
`10
` Vague. 01:20
`11
`BY THE WITNESS: 01:20
`12
` A. I mean I stand by the paragraph that 01:20
`13
`is written here. 01:20
`14
` Q. Yes, I'm not asking you about the 01:20
`15
`basis of the paragraph, sir. I'm asking you to 01:20
`16
`use the definition that you've given in the 01:20
`17
`paragraph. And based on that definition of the 01:20
`18
`relevant field for purposes of the '097 patent, 01:21
`19
`I'm asking you, are you an expert in the 01:21
`20
`relevant field? 01:21
`21
` A. So the wording I use here is that: 01:21
`22
`23 Methods and apparatuses for controlling and 01:21
`operating a hybrid electric vehicle and methods 01:21
`24
`for improving fuel economy and reducing 01:21
`25
`Page 13
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`1
`Chrysler matter and the two IPRs that we just 01:17
`2
`discussed, are there any other reports or 01:17
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`declarations that you've submitted in the last 01:17
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`year that are not listed on your CV, other than 01:17
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`the PAICE matters, of course? 01:17
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` A. I don't believe so. But again, I 01:17
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`like to leave open the possibility of checking 01:17
`8 my records to see if I just am forgetting to 01:17
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`include one. 01:17
`10
` Q. Sitting here today, you just don't 01:17
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`recall any others? 01:17
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` A. Correct. 01:17
`13
` Q. Dr. Stein, do you consider yourself 01:17
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`to be an expert in the relevant field for the 01:17
`15
`'097 patent? 01:18
`16
` A. Well, I'm not sure if you're asking 01:18
`17 me to make a legal determination, which is what 01:18
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`it sounds like. 01:18
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` Q. Your lay understanding of what the 01:18
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`term "expert" means. 01:18
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` A. So I believe that I'm an expert in 01:18
`22 mechanical engineering as applied to automotive 01:18
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`engineering, and more specifically I have 01:18
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`expertise in hybrid electric vehicle design and 01:18
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`control. So I believe that I have expertise in 01:18
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`emissions. And I believe that I have expertise 01:21
`in these areas from my lay understanding of 01:22
`what the word "expert" means. 01:22
` Q. Does that include designing hybrid 01:22
`powertrain control strategies and the related 01:22
`architecture? 01:22
` MR. TURNER: Objection. Vague. 01:22
`BY THE WITNESS: 01:22
` A. You're reading what I have written 01:22
`in the second -- the next paragraph, 01:22
`Paragraph 40, that I have extensive experience 01:22
`in the relevant field including experience 01:22
`related to hybrid powertrain control strategies 01:22
`and related architecture. Based on my 01:22
`experiences, I have established an 01:23
`understanding of the relevant field. I believe 01:23
`that's a true statement. 01:23
` Q. That wasn't quite my question. My 01:23
`question was: Do you have experience designing 01:23
`hybrid powertrain control strategies and the 01:23
`related control architecture? Your declaration 01:23
`says you have experience relating to it. I'd 01:23
`just like to know whether you've designed a 01:23
`hybrid powertrain and control strategy? 01:23
` A. I mean, the answer -- Excuse me. So 01:23
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`FORD 1245
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`what do you mean, you know -- So the answer is 01:23
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`yes, I have been involved in working with my 01:23
`3
`students in research on the design and control 01:23
`4
`of hybrid electric vehicles, and we've looked 01:23
`5
`at some unique control strategies for hybrid 01:24
`6
`electric vehicles. 01:24
`7
` Q. Great. Thank you. Let's mark a few 01:24
`8 more exhibits. 01:24
`9
` (Stein Exhibit Number 8 marked for 01:24
`10
` identification.) 01:24
`11
` (Stein Exhibit Number 9 marked for 01:24
`12
` identification.) 01:24
`13
`BY MR. GUARNIERI: 01:25
`14
` Q. So, Dr. Stein, the court reporter 01:25
`15
`has just placed in front of you what has been 01:25
`16 marked first as Exhibit 8, which is Ford 01:25
`17
`Exhibit 1101, U.S. Patent No. 8,214,097. 01:25
`18
` Do you recognize this exhibit? 01:25
`19
` A. Yes, I do. 01:25
`20
` Q. And do you recognize this as the 01:25
`21
`'097 patent that's the subject of this IPR? 01:25
`22
` A. Yes. 01:25
`23
` Q. And then if you look at Exhibit 9 01:25
`24
`that's marked as Ford Exhibit 1104, it's U.S. 01:25
`25
`Patent No. 5,343,970, and do you recognize this 01:25
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` Q. So if the words exist in the patent, 01:27
`do you recognize that the '970 patent teaches a 01:27
`low-speed mode of operation? 01:27
` A. It has a mode of operation which it 01:27
`utilizes when the vehicle is operating where 01:27
`the output torque required to propel the 01:27
`vehicle is relatively small, which is typical 01:27
`of around town or in traffic or what this 01:27
`patent sometimes calls the low-speed mode. 01:27
`It's just a label or a proxy for the operation 01:28
`of the vehicle when the torque output required 01:28
`to propel the vehicle is low. 01:28
` Q. What do you mean by label or proxy? 01:28
` A. So the '970 describes the hybrid 01:28
`vehicle as operating in different modes, and it 01:28
`describes these modes in terms of the output 01:28
`torque required to propel the vehicle, which 01:28
`I've outlined in my declaration. And the -- 01:28
`So, for example, it has a mode called highway 01:29
`cruising mode. That's a label or proxy for 01:29
`when the torque values are at a certain amount 01:29
`where the engine is in its efficient range of 01:29
`operation and is used alone to propel the 01:29
`vehicle. So -- 01:29
` Q. Dr. Stein, in answering my question, 01:29
`Page 17
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`exhibit? 01:25
` A. Yes, I do. 01:25
` Q. And is this the Severinsky '970 01:25
`patent that you referred to? 01:25
` A. In my declaration, yes. 01:25
` Q. And while we're talking today, if I 01:25
`refer to Severinsky, you'll understand that I'm 01:25
`referring to this patent or converse, the '970 01:26
`patent, either one? How about this? Let me 01:26
`strike that and ask: What would you prefer to 01:26
`refer to this patent as? 01:26
` A. The '970. 01:26
` Q. All right. We'll call this the '970 01:26
`patent. Sometimes it's a little confusing with 01:26
`the '097 and '970. I just want to make sure 01:26
`we've got our numbers straight. 01:26
` A. Sure. 01:26
` Q. So, Dr. Stein, why don't you put 01:26
`Exhibit 9, the '970 patent, in front of you. 01:26
`And are you familiar with the '970 patent's 01:26
`low-speed mode? 01:26
` A. So I've reviewed the '970 patent, 01:26
`and I understand that the words low speed, 01:26
`perhaps low-speed mode perhaps exist in this 01:27
`patent. Is that what you're asking me? 01:27
`
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`you've used the exact same phrase. What do you 01:29
`2 mean by label or proxy? 01:29
`3
` A. It's a set of words or name that is 01:29
`4 meant to be a shorthand notation for referring 01:29
`5
`the reader to a specific mode of operation. So 01:30
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`the, quote/unquote, low-speed mode refers to a 01:30
`7 mode which the torque is relatively smaller and 01:30
`8
`where the motor alone is used to propel the 01:30
`9
`vehicle without the engine, so that's kind of a 01:30
`10
`long set of words to use. 01:30
`11
` The patent uses this label or proxy, 01:30
`12
`if you will. Rather than using it with a long 01:30
`13
`set of words, it uses a shorthand notation and 01:30
`14
`calls this a low-speed mode because with these 01:30
`15
`low torques, the vehicle is generally traveling 01:30
`16
`in something we might call, you know, lower 01:30
`17
`speeds. 01:30
`18
` Q. So looking at the '970 patent, can 01:30
`19
`you identify for me where '970 discloses 01:30
`20
`operating in low-speed mode based on the output 01:31
`21
`torque required to propel the vehicle? 01:31
`22
` A. Well -- So I refer you to my 01:31
`23
`declaration, Paragraph 194, which is under the 01:33
`24
`heading 1.7. It's claim 1.7: Operating the at 01:33
`25
`least one electric motor to provide torque to 01:33
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`the hybrid vehicle when the torque required to 01:33
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`operate the vehicle is less than capital S, 01:34
`2
`capital P. What I'll normally say is SP. 01:34
`3
` And then I say in Paragraph 194: 01:34
`4
`5 With reference to Figure 3, Severinsky '970 01:34
`discloses that the microprocessor 48 controls 01:34
`6
`the motor 20 to ensure that the appropriate 01:34
`7
`torque is delivered to the wheels 34. 01:34
`8
` And then there's a quote: Thus, as 01:34
`9
`discussed in connection with Figure 3, 01:34
`10
`11 microprocessor 48 is provided with all 01:34
`information relevant to the performance of the 01:34
`12
`system and appropriately controls the torque 01:34
`13
`transfer unit 28, internal combustion engine 01:34
`14
`40, switching unit 28, and electric motor 20 to 01:34
`15
`ensure the appropriate torque is delivered to 01:34
`16
`the wheels 34 of the vehicle. And that quote 01:34
`17
`is from '970, Column 12, Line 64 through Column 01:34
`18
`13, Line 2. 01:35
`19
` Q. All right. So let me stop right 01:35
`20
`there, and let's talk about that quote. 01:35
`21
` Now, Severinsky is saying here that 01:35
`22
`the electric motor is controlled to ensure that 01:35
`23
`appropriate torque is delivered to the wheels 01:35
`24
`of the vehicle. Isn't that the case for any 01:35
`25
`
` There's no details there about what 01:36
`1
`actual information is provided to the 01:36
`2
`3 microprocessor here, right? 01:36
` A. Well, not in that paragraph. But 01:37
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`there's figures and other details that show 01:37
`5
`6 what kind of information the microprocessor is 01:37
`provided. It says Figure 3, and here's 01:37
`7
`Figure 3. 01:37
`8
` Q. That's fine. I just want to talk 01:37
`9
`about this paragraph for a second. 01:37
`10
` Let's move on to the fact that the 01:37
`11
`12 microprocessor controls the electric motor. 01:37
` A. Now, the -- 01:37
`13
` Q. The fact that the microprocessor 01:37
`14
`controls the electric motor to ensure that 01:37
`15
`appropriate torque is delivered to the wheels 01:37
`16
`of the vehicle. Now, all that is saying is the 01:37
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`18 microprocessor is telling the electric motor to 01:37
`provide torque to the wheels of the vehicle, 01:37
`19
`right? 01:37
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` A. I think you cut me off. And I was 01:37
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`saying that Figure 3 is part of that paragraph. 01:37
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`It says as discussed in connection with 01:37
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`Figure 3. That's the first part of the quote. 01:37
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`25 And Figure 3 does show a variety of details 01:37
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`Page 19
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`Page 21
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`1
`vehicle, hybrid or not, that is using an 01:35
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`electric motor, to provide torque to the wheels 01:35
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`regardless of what the control system is? 01:35
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` A. Can you repeat your question, 01:35
`5
`please? 01:35
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` Q. Sure. This paragraph that you're 01:35
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`quoting in Paragraph 194 of Exhibit 7, the 01:35
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`characterization of how the electric motor 01:36
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`works in this paragraph is going to be true for 01:36
`10
`any vehicle that is using electric motor for 01:36
`11
`propulsion? 01:36
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` A. I think you're mischaracterizing or 01:36
`13
`not understanding the paragraph. The paragraph 01:36
`14
`is talking about the microprocessor and talking 01:36
`15
`about all the information that it is using and 01:36
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`how it controls a bunch of different things, 01:36
`17
`including the electric motor, to ensure that 01:36
`18
`the appropriate level of torque is delivered to 01:36
`19
`the wheels of the vehicle. 01:36
`20
` Q. So first off, the paragraph is 01:36
`21
`talking about the microprocessor and talking 01:36
`22
`about all the information that it is using. 01:36
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`The only statement it says here is 01:36
`24 microprocessor is provided with all relevant 01:36
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`information. 01:36
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`about what is provided to the controller, okay. 01:37
`2
` Q. And so when it controls the electric 01:37
`3 motor, to ensure that appropriate torque is 01:37
`4
`delivered to the wheels of the vehicle, isn't 01:37
`5
`that statement about controlling the electric 01:38
`6 motor true about any vehicle that uses an 01:38
`7
`electric motor for propulsion? Isn't it always 01:38
`8
`going to be the case that an electric motor 01:38
`9
`used for propulsion has to ensure that the 01:38
`10
`appropriate torque is delivered to the wheels 01:38
`11
`of the vehicle? 01:38
`12
` MR. TURNER: Objection. Vague. 01:38
`13
`BY THE WITNESS: 01:38
`14
` A. I don't really understand your 01:38
`15
`question. This paragraph doesn't just talk 01:38
`16
`about the electric motor, but it does talk 01:38
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`about the microprocessor determining how to 01:38
`18
`control these different elements that are 01:38
`19
`discussed in the paragraph such that the 01:38
`20
`appropriate torque is delivered to the wheels 01:38
`21
`of the vehicle. 01:38
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` And if we would continue on to the 01:38
`23
`next paragraph, we can specifically talk about 01:38
`24
`this low-speed mode that you were talking about 01:38
`25
`before and where I was describing that this 01:38
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`TransPerfect Legal Solutions
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`
`6 (Pages 18 to 21)
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`FORD 1245
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`Page 22
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`Page 24
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`torque was provided in that mode of operation 01:38
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`by the electric motor alone. 01:38
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` So in Paragraph 195, Severinsky '970 01:39
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`discloses that the electric motor is operated 01:39
`4
`to provide all of the torque needed to move the 01:39
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`hybrid vehicle in a capital low, capital speed, 01:39
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`capital mode. The first letters are 01:39
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`capitalized. 01:39
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` And then the quote is Figure 4, 01:39
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`10 which is provided in my declaration, 01:39
`illustrates the operation in slow speed 01:39
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`circumstances -- for example, in city traffic 01:39
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`or reversing. As noted, the parallel hybrid 01:39
`13
`vehicle drive system according to the present 01:39
`14
`invention includes an electric motor 20 powered 01:39
`15
`by energy stored in a relatively large, 01:39
`16
`high-voltage battery pack 22. Energy flows 01:39
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`from battery 22 to motor 20 as indicated by 01:39
`18
`dot-dash line shown at 24. The electric motor 01:39
`19
`20 provides torque shown as dashed Line 25, 01:40
`20
`transmitted from the motor output shaft 26 01:40
`21
`through a torque transfer unit 28 and a drive 01:40
`22
`shaft 30 to a conventional differential 32 and 01:40
`23
`then two wheels 34 of the vehicle. 01:40
`24
` Thus Figure 4 indicates the throw of 01:40
`25
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`some of the prior art that I've looked at that 01:41
`when you're in the low speed of operation, low 01:42
`torques are required. And it's during that set 01:42
`of circumstances that the torque alone is used 01:42
`to operate the vehicle. 01:42
` And Severinsky '970 is saying that 01:42
`his particular invention utilizes the motor 01:42
`alone and -- when the torque levels are small 01:42
`and describes this circumstance as the 01:42
`low-speed mode. And that's why I said 01:42
`low-speed mode is a proxy or a label for this 01:42
`whole paragraph, if you will. So we don't have 01:42
`to reread the paragraph every time, this is 01:42
`what we mean by the low-speed mode, and I can 01:42
`read this paragraph again under 195 and the 01:42
`quote. 01:42
` Q. Can you point to me where in 195 01:42
`Severinsky says that th