`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` FORD MOTOR COMPANY, )
` )
` Petitioner, )
` )
` vs. ) Case Number
` ) IPR2014-00875
` 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. 14261A
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` 1
`
`PAICE 2203
`Ford v. Paice et al.
`IPR2015-00792
`
`
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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 1 U.S. Patent No. 5,586,613 9
` to Ehsani
`
` Exhibit 2 Deposition transcript of 14
` Jeffrey L. Stein from
` March 3rd, 2015
`
` Exhibit 3 Prior art reference, 36
` Vittone
`
` Exhibit 4 Declaration of Dr. Jeffrey 38
` L. Stein in Support of
` Petitioner's Reply to
` Patent Owner's Response
`
` Exhibit 5 U.S. Patent No. 7,559,388 60
`
` Exhibit 6 Declaration of Dr. Jeffrey 78
` L. Stein in Support of
` Petition for Inter Partes
` Review
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`56
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` May 29, 2015
` 9:04 a.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
`
`Page 5
`
`1
` (Witness sworn.)
`2
` MR. GUARNIERI: For the record, this 09:04
`3
` is Pete Guarnieri for Fish & Richardson for 09:04
`4
` PAICE and the Abell Foundation. 09:04
`5
` MR. TURNER: This is Andrew Turner 09:04
`6
` with Brooks Kushman for Ford, and with me 09:04
`7
` is Frank Angileri also for Ford. 09:04
`8 WHEREUPON:
`9
` JEFFREY L. STEIN, Ph.D.,
`10
`called as a witness herein, having been first
`11
`duly sworn, was examined and testified as
`12
`follows:
`13
` CROSS-EXAMINATION
`14
`BY MR. GUARNIERI: 09:04
`15
` Q. Good morning, Dr. Stein. 09:04
`16
` A. Good morning. 09:04
`17
` Q. Could you state your full name and 09:04
`18
`business address for the record. 09:04
`19
` A. Jeffrey L. Stein. University of 09:04
`20 Michigan, Department of Mechanical Engineering. 09:04
`21
` Q. And, Dr. Stein, this is the third 09:04
`22
`time I believe that you've been deposed in 09:04
`23
`these PAICE/Ford IPR matters; is that correct? 09:04
`24
` A. I haven't kept count. 09:04
`25
` Q. Feels like more than that? 09:04
`
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` Well, you're familiar with the rules 09:04
`1
`of the proceedings, familiar with how this 09:04
`2
`deposition process works; am I correct on that? 09:05
`3
` A. I am familiar with how things have 09:05
`4
`been going so far, yes, in this -- in these 09:05
`5
`related depositions. 09:05
`6
` Q. So you understand that you've taken 09:05
`7
`an oath; and you're obligated to testify 09:05
`8
`truthfully and accurately just as if you were 09:05
`9
`in a court, right? 09:05
`10
` A. Correct. 09:05
`11
` Q. All right. Are there any reasons 09:05
`12
`today you wouldn't be able to provide accurate, 09:05
`13
`fully accurate testimony, any special 09:05
`14
`conditions, medical conditions, anything of 09:05
`15
`that nature that we should know about? 09:05
`16
` A. No. 09:05
`17
` Q. What did you do to prepare for your 09:05
`18
`deposition today? 09:05
`19
` A. I reviewed my declaration, the '097, 09:05
`20
`21 what I call '097 IPR 2. And I also reviewed, 09:06
`you know, the materials that are relevant to 09:06
`22
`that declaration. And I also reviewed the '388 09:06
`23
`reply declaration and materials related to 09:06
`24
`that. 09:06
`25
`
`1
`declarations you've submitted across all the 09:08
`2
`various PAICE/Ford IPRs? 09:08
`3
` A. Could you repeat the question, 09:08
`4
`please? 09:08
`5
` Q. Sure. Do you know sitting here 09:08
`6
`today approximately how many declarations 09:08
`7
`you've submitted for all the PAICE/Ford IPRs? 09:08
`8
`10, 15, 20? 09:09
`9
` A. I mean, I'd have to look at my 09:09
`10
`records to count up the number. But there's 09:09
`11
`some number, you know, in the area of 10-ish. 09:09
`12
` Q. And for all of those, whatever that 09:09
`13
`number is, roughly how much time have you spent 09:09
`14
`working on those declarations? 09:09
`15
` A. I mean, I don't know how to answer 09:09
`16
`that question without going back and looking at 09:09
`17 my records. I've been working on this case. I 09:09
`18
`was retained, as you know, over a year ago. I 09:09
`19
`don't remember the exact date off the top of my 09:09
`20
`head. And I've worked on declarations over 09:09
`21
`that period of time. 09:09
`22
` Q. How about this: Roughly how much 09:10
`23 money have you billed for your work on these 09:10
`24
`IPRs? 09:10
`25
` A. I don't know the answer to that 09:10
`
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` Q. And approximately how much time 09:06
`would you say you spent preparing? 09:06
` A. How much time I spent preparing for? 09:06
` Q. This deposition. 09:06
` A. I mean, I'd have to look at my 09:06
`records to see how much time. But -- So I 09:06
`don't know any kind of hour content, then. But 09:06
`I've been spending the last week or so since 09:06
`I've understood that the deposition was going 09:07
`to be scheduled for today getting ready. 09:07
` Q. More or less than 40 hours? 09:07
` A. I guess I just don't really know 09:07
`what that number would be; but, you know, I 09:07
`can't imagine 40 is a long ways off from it. 09:07
` Q. Fair enough. And who did you talk 09:07
`to while you were preparing for today's 09:07
`deposition? 09:07
` A. I -- Who did I talk with about the 09:07
`deposition specifically? 09:07
` Q. Correct. 09:07
` A. So I spoke with the -- Mr. Turner 09:07
`and Mr. Angileri, Ms. Shah, and Mr. Kushman. I 09:08
`believe that's it. 09:08
` Q. Dr. Stein, do you have -- do you 09:08
`know sitting here today approximately how many 09:08
`
`question without looking at my invoices. 09:10
`1
` Q. More or less than $100,000? 09:10
`2
` A. I would say that over the total, 09:10
`3
`billing has been probably in excess of 09:10
`4
`$100,000. 09:10
`5
` Q. More than $500,000? 09:10
`6
` A. I don't believe so. 09:10
`7
` Q. Somewhere between 100- and $500,000? 09:11
`8
` A. Again, without looking at my 09:11
`9
`records, I can't be more specific than that. 09:11
`10
` (Stein Exhibit Number 1 marked for 09:11
`11
` identification.) 09:11
`12
`BY MR. GUARNIERI: 09:11
`13
` Q. This is -- The court reporter has 09:11
`14
`just handed you what's been marked as 09:11
`15
`Exhibit 1. It's Ford Exhibit 1003. This is 09:11
`16
`17 U.S. Patent No. 5,586,613 to Ehsani, 09:11
`E H S A N I. 09:11
`18
` A. Can I ask you a question? So we're 09:11
`19
`going to be focusing on my reply dec, the '388 09:12
`20
`reply dec? 09:12
`21
` Q. I think we're going to start with 09:12
`22
`IPR2014-875, which is your reply declaration. 09:12
`23
`24 You seem to have brought some binders today. 09:12
`25 What are in those binders? 09:12
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` A. One is my '388 binder, which has my 09:12
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`'388 reply declaration in it as well as my 09:12
`2
`original declaration and some of the prior art 09:12
`3
`references. 09:12
`4
` Q. And the second binder? 09:12
`5
` A. Is related to the '097 declaration 09:12
`6
`and prior art references. 09:12
`7
` Q. Okay. You can feel free to refer to 09:12
`8
`those throughout the day. We'll mark exhibits 09:12
`9
`as we go. 09:12
`10
` MR. GUARNIERI: I'd ask that I be 09:12
`11
` allowed to just check those maybe on a 09:12
`12
` break sometime. 09:12
`13
` MR. TURNER: That's fine. 09:12
`14
`BY MR. GUARNIERI: 09:12
`15
` Q. Okay. Well, looking at Exhibit 1 09:12
`16
`that's in front of you, do you recognize this 09:12
`17
`reference, Dr. Stein? 09:12
`18
` A. Yes, I do. It looks like the Ehsani 09:13
`19
`that I used in my declaration, referred to in 09:13
`20
`21 my declaration. 09:13
` Q. And, Dr. Stein, in the Ehsani 09:13
`22
`control system, Ehsani tries to operate -- 09:13
`23
`always operate the engine in an efficient 09:13
`24
`25 manner and region; is that correct? 09:13
`Page 11
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`the case that when the engine is operated, 09:17
`1
`Ehsani tries to operate the engine in an 09:17
`2
`efficient manner and efficient region so he's 09:17
`3
`trying to operate the engine at a constant 09:17
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`power, right? 09:17
`5
` A. I agree with the idea that the 09:17
`6
`engine has a region in its power speed curve 09:17
`7
`8 where it can be more efficient, and that's also 09:17
`true in its torque speed curve and that Ehsani 09:18
`9
`is trying to take advantage of that in his 09:18
`10
`invention that he is describing in the '613 by 09:18
`11
`at times operating the engine at a kind of 09:18
`12
`average -- at a constant power output. 09:18
`13
` Q. Dr. Stein, do you agree that when 09:18
`14
`the engine is operated, Ehsani tries to operate 09:18
`15
`the engine in an efficient manner and efficient 09:18
`16
`region, so Ehsani is trying to define to 09:18
`17
`operate the engine at a constant power? 09:18
`18
` A. I thought I just answered that 09:18
`19
`question. 09:18
`20
` Q. You didn't, Dr. Stein. Do you agree 09:19
`21
`22 with my statement or do you not? 09:19
` A. I agree with my answer. If you'd 09:19
`23
`like me to repeat it ... 09:19
`24
` Q. Maybe this might help. Do you 09:19
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` A. So what do you mean by a control 09:13
`system? 09:14
` Q. Well, do you agree that Ehsani 09:14
`discloses a control system to control a hybrid 09:14
`electric vehicle? 09:14
` A. I agree that he talks about the 09:14
`control of the hybrid electric vehicle. And so 09:14
`I just want to be specific about which 09:14
`controller you're talking about or which 09:14
`control concept when we're using that word 09:14
`because there can be multiple things that are 09:14
`being controlled. 09:14
` Q. So when Ehsani talks about the 09:14
`control of the hybrid electric vehicle, it's 09:14
`the case that when the engine is operated, 09:14
`Ehsani tries to operate the engine in an 09:14
`efficient manner and efficient region, so he's 09:14
`trying to operate the engine at a constant 09:14
`power, right? 09:14
` MR. TURNER: Objection. Vague. 09:15
`BY THE WITNESS: 09:17
` A. Okay. Could you repeat your 09:17
`question again, please, now? 09:17
` Q. So when Ehsani talks about the 09:17
`control of the hybrid electric vehicle, it's 09:17
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`recall testifying on March 3rd, 2015, you were 09:19
`1
`asked: Does the engine run at a constant power 09:19
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`in Ehsani? 09:19
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` You answered: When the engine is 09:19
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`operated, he tries to operate the engine in an 09:19
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`efficient manner and efficient region, so he's 09:19
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`trying to define to operate engine at a 09:19
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`constant power, but the engine isn't always 09:19
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`run. 09:19
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` Do you recall giving that testimony? 09:19
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` A. It sounds -- I'd have to look at 09:19
`11
`transcript. I don't -- It sounds familiar, but 09:19
`12
`I'd have to look at transcript to see if that's 09:19
`13
`a precise representation of what I said. 09:19
`14
` Q. Do you have any reason to doubt that 09:19
`15
`that's what you testified to? 09:19
`16
` A. I just haven't -- don't see the 09:19
`17
`transcript. I have to look at it to know those 09:19
`18
`are the exact words. I don't have a 09:20
`19
`photographic recall of what I said. 09:20
`20
` Q. Well, let me ask the question again. 09:20
`21
`Do you now disagree or agree with your prior 09:20
`22
`testimony that I'm representing to you was: 09:20
`23
`24 When the engine is operating, he tries to 09:20
`operate the engine in an efficient manner and 09:20
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`efficient region, so he's trying to define to 09:20
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`operate the engine at a constant power, but the 09:20
`2
`engine isn't always run? 09:20
`3
` MR. TURNER: Objection. Compound. 09:20
`4
`BY THE WITNESS: 09:20
`5
` A. Can I read my transcript or 09:20
`6
`statement? 09:20
`7
` Q. Sure. 09:20
`8
` MR. GUARNIERI: Why don't we mark 09:20
`9
` this. 09:21
`10
` (Stein Exhibit Number 2 marked for 09:21
`11
` identification.) 09:21
`12
`BY MR. GUARNIERI: 09:21
`13
` Q. Dr. Stein, the court reporter has 09:21
`14
`handed you what's been marked as Exhibit 2, 09:21
`15
`16 which is the deposition transcript of Jeffrey 09:21
`L. Stein from March 3rd, 2015. 09:21
`17
` A. That's correct. 09:21
`18
` Q. And if you'll look on Page 69 of the 09:21
`19
`transcript, starting at Line 23, and why don't 09:21
`20
`you read the question and answer into the 09:21
`21
`record that starts on Line 23. 09:21
`22
` A. Does the engine run at a constant 09:21
`23
`power in Ehsani? 09:21
`24
` ANSWER: When the engine is 09:21
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`techniques may be used without departing from 09:29
`the intended scope herein. 09:29
` So I think that the general nature 09:29
`of his idea is to run the engine at a constant 09:29
`power. That's one of the things that he 09:29
`describes and to run the engine in a more 09:29
`efficient rather than less efficient region. 09:30
` Q. And you also say in that testimony 09:30
`that the engine isn't always run in Ehsani's 09:30
`control system. Is that still accurate? 09:30
` A. The possibility exists for turning 09:30
`off the engine. As I just said, other control 09:30
`techniques can be used without departing from 09:30
`the intended scope therein, so the engine could 09:30
`be turned off. 09:30
` Q. So how does Ehsani teach when to 09:30
`turn the engine on and when to turn the engine 09:30
`off? 09:30
` A. I don't know that he specifically 09:30
`provides that particular detail within his 09:30
`reference. I'd have to look back to see. 09:30
` Q. You have Ehsani in front of you. 09:30
`Feel free to take a look at it and let me know 09:31
`if you can identify where Ehsani teaches when 09:31
`to turn the engine on and when to turn the 09:31
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`operated, he tries to operate the engine in an 09:21
`efficient manner and efficient region so he's 09:21
`trying to define to operate the engine at a 09:21
`constant power, but the engine isn't always 09:22
`run, period. 09:22
` Q. Is that testimony still accurate, 09:22
`sir? 09:22
` A. I have to see what the context was 09:22
`for that answer. 09:22
` So could you just, to get us going 09:22
`again -- I'm trying to understand what your 09:28
`question is. And just to be clear, could you 09:28
`just repeat your question? 09:28
` Q. So you've had a chance to read your 09:28
`testimony from your March 3rd, 2015 deposition 09:28
`at Page 69, Lines 23 to Page 70, Line 4, my 09:28
`question was: Is that testimony still accurate 09:28
`today, sir? 09:28
` A. I think it's an accurate statement 09:28
`about the general nature of Ehsani's invention 09:29
`that he's trying to operate his engine in an 09:29
`efficient manner, and one of his ideas is to 09:29
`run the engine at a constant power. He does 09:29
`say in the context of his invention in 09:29
`Column 7 of Line 10, 11, 12, other control 09:29
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`engine off. 09:31
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` A. So Ehsani does provide in some of 09:39
`2
`his embodiments a clutch for being able to 09:40
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`disengage the engine, and he also describes 09:40
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`that other control techniques may be used 09:40
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`without departing from the scope. 09:40
`6
` And so I think what I was referring 09:40
`7
`to in my deposition transcript, that the engine 09:40
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`isn't necessarily always run, is in the context 09:40
`9
`of this ability to decouple the engine from the 09:40
`10
`drive wheels and to -- and when it's decoupled, 09:40
`11
`you could, if the batteries, for example, were 09:40
`12
`fully charged, you could -- you would not need 09:40
`13
`to run the engine during those times. There 09:40
`14
`15 may be other, you know, situations where that 09:40
`16 might be appropriate as well. That's just one 09:40
`that comes to my mind at the moment. 09:40
`17
` Q. Now, in the examples you just 09:41
`18
`described in your prior answer, does Ehsani 09:41
`19
`describe the control algorithm that would be 09:41
`20
`used to, for example, decouple the engine from 09:41
`21
`the drive wheels and propel the vehicle using 09:41
`22
`the motor with charge from the battery? 09:41
`23
` A. So are you asking me does Ehsani 09:41
`24
`specifically call out an electric motor mode 09:41
`25
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`1 where he's just driving the vehicle with the 09:41
`electric motor? 09:41
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` Q. I'm asking you whether or not Ehsani 09:41
`3
`describes a control algorithm or control 09:41
`4
`strategy for switching between running the 09:42
`5
`engine at constant power, which you agreed 09:42
`6
`earlier is one of the things Ehsani discloses, 09:42
`7
`and switching to running only on the electric 09:42
`8
`9 motor where the engine is decoupled using the 09:42
`clutch that you just described in your prior 09:42
`10
`answer? 09:42
`11
` A. He does describe decoupling the 09:42
`12
`engine with the clutch. I can refer you to the 09:42
`13
`point where he does describe that. 09:42
`14
` Q. So I appreciate that. And what I'd 09:42
`15
`like to know is: Does he describe a control 09:42
`16
`algorithm or control strategy for telling a 09:42
`17
`person of skill in the art when during normal 09:42
`18
`operation or when in operation of the car you 09:42
`19
`20 would do that? 09:42
` MR. TURNER: Objection. Relevance. 09:42
`21
`BY THE WITNESS: 09:42
`22
` A. It seems to me that your question is 09:42
`23
`beyond the scope of my review for this 09:44
`24
`particular declaration in the sense that claims 09:44
`25
`Page 19
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`that I was concerned with don't involve mode 09:44
`1
`selection as an issue. So I haven't studied 09:44
`2
`that specific issue as it relates to the Ehsani 09:44
`3
`reference. I don't believe that's something 09:44
`4
`that's discussed in my declaration. If you can 09:44
`5
`show me, then we can certainly discuss it. 09:44
`6
` Q. So, Dr. Stein, you realize you're 09:44
`7
`not allowed to cue off of Mr. Turner's 09:44
`8
`objections? It appears he just objected on 09:44
`9
`relevance. And after studying your 09:44
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`declaration, you answered that "it seems to me 09:44
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`that your question is beyond the scope of my 09:44
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`review." 09:44
`13
` Did you just cue off of Mr. Turner's 09:44
`14
`objection? 09:44
`15
` A. I listened to your question, and I 09:44
`16
`understood that the question was outside of 09:45
`17
`18 what I had reviewed. 09:45
` Q. Let me ask you this: Did you review 09:45
`19
`the entire Ehsani reference? 09:45
`20
` A. I reviewed the Ehsani reference, 09:45
`21
`yes. 09:45
`22
` Q. Did you consider the entire Ehsani 09:45
`23
`reference? 09:45
`24
` A. I've considered the Ehsani reference 09:45
`25
`
`as a whole, yes. 09:45
`1
` Q. In your review and consideration of 09:45
`2
`the Ehsani reference as a whole, did Ehsani 09:45
`3
`disclose anywhere a strategy for switching 09:45
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`between operating on the motor and operating on 09:45
`5
`the engine? 09:45
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` A. He does discuss -- So ask that 09:45
`7
`question again. Please repeat your question. 09:45
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` Q. In your reviewing and consideration 09:45
`9
`of the Ehsani reference as a whole, did Ehsani 09:45
`10
`disclose anywhere a strategy for switching 09:45
`11
`between operating on the motor and operating on 09:45
`12
`the engine? 09:45
`13
` A. I mean, generally speaking, he talks 09:45
`14
`about the control of hybrid vehicles; and he 09:46
`15
`does talk about having, generally speaking, 09:46
`16
`several different modes of operation, which are 09:46
`17
`described in my declaration. 09:46
`18
` Q. Well, that wasn't my question, sir. 09:46
`19
`20 Yes or no, in reviewing and considering the 09:46
`Ehsani references as a whole, did Ehsani 09:46
`21
`disclose anywhere a strategy for switching 09:46
`22
`between operating on the motor and operating on 09:46
`23
`the engine? 09:46
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` A. I think that I answered that 09:46
`25
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`Page 21
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`question in the sense that he provides a 09:46
`description of at least two modes of operation 09:46
`of his electric hybrid -- hybrid electric 09:46
`vehicle, and he describes generally this issue 09:47
`of what he calls mode 1 and mode 2. What the 09:47
`conditions are that relate to those two modes 09:47
`is something that he talks about. 09:47
` Q. Dr. Stein, do you agree that the 09:47
`control system in Ehsani must have to set the 09:48
`engine's output torque? 09:48
` A. I don't understand that question. 09:48
` Q. Sure. In order for an engine to 09:48
`produce torque in a hybrid electric vehicle, 09:48
`you agree that the engine has to be commanded 09:48
`in some way to produce torque, correct? 09:48
` MR. TURNER: Objection. Vague. 09:48
`BY THE WITNESS: 09:48
` A. So do you want to -- I'm having 09:48
`difficulty with your question because it seems 09:49
`to be unclear. 09:49
` But in particular, let's talk 09:49
`about -- To help with getting ourselves clear 09:49
`about what you're asking so I can answer it, 09:49
`perhaps we should talk about just an engine in 09:49
`general such as if we were talking with my 09:49
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`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`6 (Pages 18 to 21)
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`Page 24
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`students and talking about how engines work. 09:49
`Fair enough? 09:49
` Q. Fair enough. 09:49
` A. So in that context, if you want an 09:49
`engine to produce power, then you have to 09:49
`provide it with fuel and spark. 09:49
` Q. And if you say you want to provide 09:49
`it with fuel and spark, that's the result of a 09:49
`command to the engine by some form of control 09:49
`system; is that correct? Still in the context 09:49
`of just talking about an engine as if we were 09:49
`discussing this with your students. 09:50
` A. Well, in a typical, say, commercial 09:50
`engine and from a vehicle, whether a hybrid 09:50
`vehicle or a conventional vehicle, in this day 09:50
`and age, we have an engine controller which 09:50
`helps manage how the engine operates. But 09:50
`strictly speaking, you don't have to have a 09:50
`controller of that nature to provide fuel and 09:50
`spark to the engine. In the old days, we 09:50
`didn't have engine controllers in the sense of 09:50
`having a computer-based system on top of the 09:50
`engine. 09:50
` Q. So in a system with an engine 09:50
`controller that you've just referred to in your 09:50
`
`traction motors in hybrid vehicles, is there a 09:52
`1
`controller, and generally speaking in hybrid 09:53
`2
`vehicles, that would command the motor to 09:53
`3
`produce a certain power output? 09:53
`4
` A. I mean, there are a variety of ways 09:53
`5
`in which you can control electric motors. You 09:53
`6
`can operate them in torque control, in speed 09:53
`7
`control. There are different control concepts 09:53
`8
`that can be applied to the control of, in 09:53
`9
`general, electric machines or electric motors. 09:53
`10
`Be they DC or AC, it doesn't matter. 09:53
`11
` Q. Dr. Stein, I guess my question is 09:53
`12
`about the end result of this control. So the 09:54
`13
`end result of controlling the traction motor, 09:54
`14
`the motor that's propelling the vehicle in a 09:54
`15
`hybrid electric vehicle, the end result is to 09:54
`16
`command that motor to output power that's 09:54
`17
`delivered to the wheels; is that fair? That's 09:54
`18
`19 what the motor does, right? 09:54
` MR. TURNER: Objection. Compound. 09:54
`20
`BY THE WITNESS: 09:54
`21
` A. So why don't we break down your 09:54
`22
`question so that it's -- there's one simple 09:54
`23
`question there. 09:54
`24
` Q. Yeah, so the end result of 09:54
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`Page 23
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`Page 25
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`prior answer, that engine controller will set 09:50
`1
`the engine's power output which, in turn, 09:51
`2
`that's setting the engine's output, torque, and 09:51
`3
`speed; is th