UNITED STATES PATENT AND TRADEMARK OFFICE
`
` _________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________________
`
`Page 1
`
` FORD MOTOR COMPANY,
`
` Petitioner,
`
` -vs-
`
` PAICE, LLC & ABELL FOUNDATION, INC.,
`
` Patent Owner.
`
` _____________________
`
` U.S. Patent Nos. 7,237,634 and 7,104,347
`
` IPR Case Nos. IPR2015-00722; IPR2015-00784;
`
` IPR2015-00787; IPR2015-00790; IPR2015-00791;
`
` IPR2015-00794 and IPR2015-00795
`
` ____________________
`
`
`
` Deposition of GREGORY DAVIS, PhD
`
` Wednesday, January 13, 2016
`
` Southfield, Michigan
`
`
`
`Reported by:
`
`Laura J. Steenbergh, CSR-3707, RPR, CRR, RMR
`
`Job no: 15629
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
` 1
`
`PAICE 2408
`Ford v. Paice & Abell
`IPR2015-00794
`
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` Southfield, Michigan
` Wednesday, January 13, 2016
` About 9:20 a.m. 09:19:13AM
` MR. LIVEDALEN: Good morning, Dr. Davis. 09:19:13AM
` THE WITNESS: Good morning. 09:23:01AM
` GREGORY DAVIS, PhD, 09:23:01AM
` having first been duly sworn, was examined and testified 09:23:01AM
` on his oath as follows: 09:23:01AM
`EXAMINATION BY MR. LIVEDALEN: 09:23:01AM
`Q. Could you please state your name for record? 09:23:01AM
`A. Sure. It's Dr. Gregory W. Davis. 09:23:03AM
`Q. And you understand that you've taken an oath today? 09:23:06AM
`A. Yes. 09:23:08AM
`Q. And you intend to tell the truth? 09:23:09AM
`A. Yes. 09:23:10AM
`Q. And so some administrative matters. Your counsel, or 09:23:10AM
` John, and I spoke about dividing these up into basically 09:23:14AM
` three tiers. So this first one's going to concern U.S. 09:23:18AM
` Patent 7,237,634, so we'll call this the '634 patent. 09:23:25AM
`A. Okay. 09:23:29AM
`Q. You're familiar with that, I believe? 09:23:29AM
`A. Yes. 09:23:31AM
`Q. And we're going to divide these up further and just 09:23:31AM
` address the declarations that you opined on with regard 09:23:35AM
` to the Ibaraki reference. And that is, for the record, 09:23:38AM
`
`Page 5
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` U.S. Patent Number 5,789,882. 09:23:45AM
`A. Okay. 09:23:49AM
`Q. And so the numbers are 2015-00722, 2015-00784, 09:23:50AM
` 2015-00787, 2015-00790, and 2015-00791. 09:24:03AM
` MR. RONDINI: And just for the record, I know 09:24:09AM
` we spoke off the record about this, I just wanted to put 09:24:11AM
` on the record that you are aware that you did not Notice 09:24:14AM
` the '722, even though that is one of '634. 09:24:18AM
` MR. LIVEDALEN: Well, I'll have to go confirm 09:24:21AM
` that, but I think we talked about it and it didn't seem 09:24:23AM
` like an issue. 09:24:26AM
` MR. RONDINI: No. 09:24:27AM
` MR. LIVEDALEN: Okay, great. 09:24:27AM
`BY MR. LIVEDALEN: 09:24:28AM
`Q. And so, Dr. Davis, I know that's a lot of numbers, and I 09:24:28AM
` think John would have told me if I got one wrong, so 09:24:32AM
` we'll proceed, if that's okay with you? 09:24:34AM
`A. Yeah, that's fine. 09:24:36AM
`Q. Okay. Sure. 09:24:37AM
` So, Dr. Davis, I'll represent to you that one 09:24:43AM
` or more of these matters also deals with a reference on 09:24:47AM
` the Frank reference. Do you recall that one we talked 09:24:51AM
` about a few months ago? 09:24:56AM
`A. Yes, I do recall Frank. I think it was like a year ago. 09:24:58AM
`Q. Yeah. So that patent number is 6,116,363. Do you 09:25:02AM
`
`2 (Pages 2 to 5)
`
` APPEARANCES:
` MR. JOHN RONDINI, ESQ.
` MR. ANDREW B. TURNER, ESQ.
` Brooks Kushman, P.C.
` 1000 Town Center, 22nd Floor
` Southfield, Michigan 48075
` (248) 358-4400
` jrondini@brookskushman.com
` aturner@brookskushman.com
` Appearing on behalf of the Petitioner.
`
` MR. BRIAN LIVEDALEN, ESQ.
` Fish & Richardson, P.C.
` 1425 K Street NW, 11th Floor
` Washington, DC 20005
` (202) 783-5050
` livedalen@fr.com
` Appearing on behalf of the Patent Owner.
`
` ALSO PRESENT: Ms. Frances Keenan - Paice, LLC
`
` * * * *
`
`Page 3
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` TABLE OF CONTENTS
`
`Witness Page
`GREGORY DAVIS, PhD
`EXAMINATION BY MR. LIVEDALEN: 4
`
` INDEX TO EXHIBITS
` (Exhibits attached to transcript)
`
`Exhibit Page
` DAVIS EXHIBIT 1 U.S. Patent Number 6,116,363 6
` DAVIS EXHIBIT 2 Declaration in IPR 2015-00784 9
` DAVIS EXHIBIT 3 U.S. Patent Number 7,237,634 18
` DAVIS EXHIBIT 4 Declaration in IPR 2015-00790 41
` DAVIS EXHIBIT 5 U.S. Patent Number 5,789,882 45
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` recall that reference? Do you want me to give it to 09:25:07AM
` you? 09:25:15AM
`A. Let me just take a look. I think I brought a copy. 09:25:15AM
` 6,116,363, yes, I have. 09:25:18AM
`Q. And do you recall, how does the Frank reference select 09:25:25AM
` operating modes? 09:25:28AM
` MR. RONDINI: Objection to form. 09:25:30AM
`BY MR. LIVEDALEN: 09:25:34AM
`Q. Do you recall? 09:25:35AM
`A. Well, I've got a lot of material here. Perhaps it would 09:25:35AM
` go easier if you could direct me to a spot in one of 09:25:39AM
` these pile of declarations here that I could take a look 09:25:45AM
` at. 09:25:49AM
`Q. Well, why don't we just mark Frank as an exhibit. 09:25:49AM
` DAVIS EXHIBIT 1 09:26:07AM
` U.S. Patent Number 6,116,363 09:26:07AM
` WAS MARKED BY THE REPORTER 09:26:07AM
` FOR IDENTIFICATION 09:26:07AM
`BY MR. LIVEDALEN: 09:26:07AM
`Q. So for the record, Exhibit 1 is U.S. Patent Number 09:26:09AM
` 6,116,363, Exhibit 3 to Frank. Does that look right to 09:26:14AM
` you, Dr. Davis? 09:26:22AM
`A. Yes. 09:26:24AM
`Q. And if you look at Figure 4, does that refresh your 09:26:33AM
` recollection as far as what criteria Frank is using to 09:26:48AM
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` 168, where you can see a side-by-side comparison between 09:32:27AM
` the Figure 4 from Frank and Figure 11 from the Ibaraki 09:32:30AM
` '882, and you can see the three general modes of 09:32:38AM
` operation. Again, the one highlighted in kind of an 09:32:41AM
` orange-ish pink color is the motor drive mode. In green 09:32:48AM
` is engine drive mode, and in blue is the combination 09:32:52AM
` engine-motor drive mode. And, again, if you look at 09:32:57AM
` Figure 11 from Ibaraki you can see that the 09:33:00AM
` determination as to which mode to operate in is based on 09:33:05AM
` the instantaneous torque to propel the vehicle and the 09:33:07AM
` vehicle's speed, whereas in Frank he used a different 09:33:11AM
` control scheme in order to determine which mode he 09:33:14AM
` wanted to go into. In Frank he used the vehicle speed, 09:33:16AM
` and the discharge of the battery, or the state of charge 09:33:21AM
` of the batteries to help make the decision. 09:33:25AM
` MR. RONDINI: Just real quick, did we want to 09:33:28AM
` mark this as an exhibit? 09:33:31AM
` MR. LIVEDALEN: Yeah, why don't we go ahead an 09:33:32AM
` do that. Do you want to mark his personal copy, or -- 09:33:33AM
` MR. RONDINI: Do you want to -- 09:33:38AM
` THE WITNESS: This is fine. I don't know that 09:33:39AM
` I have anything in here. 09:33:40AM
` MR. RONDINI: That's fine then. 09:33:42AM
`
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` select operating modes? 09:26:51AM
`A. Yes, I think I did talk about that in my declarations. 09:26:53AM
` Let's see if I can find that. 09:27:38AM
`Q. Which declaration are you looking at? 09:30:45AM
`A. I'm looking at the IPR case number 2015-00784. 09:30:48AM
`Q. Okay. Maybe -- does paragraph 384 help at all? 09:30:58AM
`A. I actually just turned to that page. 09:31:03AM
`Q. All right. We're on the same page. 09:31:05AM
`A. Can you give me the question again? 09:31:18AM
`Q. If I can remember. 09:31:22AM
` Let me just ask you this, what criteria does 09:31:24AM
` the Frank reference evaluate to determine which 09:31:27AM
` operating mode to select? 09:31:30AM
`A. Well, what you can see is if you look on, you know, 09:31:33AM
` starting on page 165, continuing on for, I think, a 09:31:37AM
` couple of pages, that you can see there's lots of 09:31:43AM
` similarities between the hybrid electric vehicles 09:31:46AM
` disclosed here, and that like the Ibaraki '882, the 09:31:53AM
` Frank has mode of operation of engine only mode, 09:31:58AM
` electric motor only mode, and an engine-motor mode. But 09:32:00AM
` unlike the control strategy used by the Ibaraki '882, 09:32:04AM
` which relies on the instantaneous torque to propel the 09:32:11AM
` vehicle and the vehicle speed to make a determination 09:32:16AM
` about which mode to switch into, Frank uses a different 09:32:18AM
` approach. And it's probably best if we look at page 09:32:22AM
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` DAVIS EXHIBIT 2 09:33:58AM
` Declaration in IPR 2015-00784 09:33:58AM
` WAS MARKED BY THE REPORTER 09:33:58AM
` FOR IDENTIFICATION 09:33:59AM
`BY MR. LIVEDALEN: 09:33:59AM
`Q. All right. So if I understand you correctly, you said 09:34:03AM
` that the Frank reference uses speed and battery 09:34:05AM
` discharge to switch modes, is that right? 09:34:10AM
`A. Yeah, or the battery state of charge or depth of 09:34:13AM
` discharge. 09:34:17AM
`Q. And would one of skill in the art understand the Ibaraki 09:34:17AM
` '882 to also use speed switch modes? 09:34:21AM
`A. No. The Ibaraki, as I just explained, and you can see 09:34:24AM
` it in the side-by-side comparison on page 168 of my 09:34:27AM
` declaration, Ibaraki uses, if you look at the Y axis, 09:34:30AM
` instead of seeing, in the Frank figure on the left, you 09:34:34AM
` see speed on the Y axis. On the Y axis or the vertical 09:34:37AM
` axis of Ibaraki on the right, Figure 11, you see the 09:34:42AM
` vehicle drive torque. So Ibaraki is using the torque 09:34:45AM
` and the vehicle speed to make the determination, whereas 09:34:52AM
` Frank was using the speed on the Y axis and the depth of 09:34:54AM
` discharge on the X axis. 09:34:59AM
`Q. So one of skill in the art would not conclude that 09:35:00AM
` Ibaraki '882 is comparing vehicle speed to a speed 09:35:03AM
` threshold, right? 09:35:07AM
`
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`3 (Pages 6 to 9)
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` MR. RONDINI: Objection to form, vague. 09:35:08AM
` THE WITNESS: I'm not sure I understand your 09:35:09AM
` question. 09:35:14AM
`BY MR. LIVEDALEN: 09:35:17AM
`Q. What don't you understand about it? 09:35:18AM
`A. I guess I just -- I'm not sure I understand what you're 09:35:19AM
` asking there. 09:35:25AM
`Q. So in Frank you agree with me, right, that Figure 4 of 09:35:26AM
` Frank discloses evaluating the vehicle speed to a speed 09:35:32AM
` threshold to select an operating mode? 09:35:38AM
` MR. RONDINI: Objection, misstates testimony, 09:35:41AM
` vague. 09:35:43AM
` THE WITNESS: I'm not -- again, I think maybe 09:35:46AM
` it's clearer if we look at my text and maybe that would 09:35:51AM
` clear it up a little bit. If you look at -- let's see, 09:35:57AM
` probably the description I have -- 09:36:04AM
`BY MR. LIVEDALEN: 09:36:07AM
`Q. It's really a simple question. Does Frank -- 09:36:07AM
`A. Sorry, I just don't understand. 09:36:11AM
`Q. Okay. So you've seen Figure 4, right? 09:36:13AM
`A. Yes. 09:36:14AM
`Q. The Y axis is what? 09:36:15AM
`A. It's the vehicle speed. 09:36:18AM
`Q. All right and at below 113 kilometers per hour, what 09:36:22AM
` mode is being used? 09:36:28AM
`
`Page 11
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`A. It depends. 09:36:29AM
`Q. Well, between 0 and 50 percent battery depth of 09:36:35AM
` discharge what mode is being used in under 13 kilometers 09:36:42AM
` per hour? 09:36:45AM
`A. Again, it still depends. 09:36:46AM
`Q. Okay. So looking at Figure 4, you cannot tell me 09:36:48AM
` whether or not Frank uses -- strike that. 09:36:52AM
` Looking at Figure 4, you cannot tell me 09:36:55AM
` whether or not Frank compares vehicle speed to a speed 09:36:57AM
` threshold or to select operating modes? 09:37:00AM
` MR. RONDINI: Objection, vague. 09:37:02AM
` THE WITNESS: Again, it uses both vehicle 09:37:09AM
` speed, as I described before, and the battery depth of 09:37:11AM
` discharge in order to determine the locations where it's 09:37:14AM
` going to switch modes. 09:37:21AM
`BY MR. LIVEDALEN: 09:37:23AM
`Q. Does it ever compare vehicle speed to a speed threshold 09:37:23AM
` to select an operating mode? 09:37:28AM
`A. Well, it defines its boundaries between modes based on 09:37:30AM
` the vehicle speed and the depth of discharge. So, 09:37:55AM
` again, the comparison that's being made is looking at 09:37:58AM
` the vehicle speed at a particular depth of discharge or 09:38:03AM
` condition of the battery in order to decide which mode 09:38:06AM
` of operation is desired. 09:38:08AM
`Q. And does that ever require a comparison of vehicle speed 09:38:10AM
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` to a speed threshold? 09:38:16AM
` MR. RONDINI: Objection, asked and answered. 09:38:18AM
` THE WITNESS: Again, it's making the 09:38:20AM
` determination, it set up the boundaries, if you will, 09:38:24AM
` between the different modes based on the vehicle speed 09:38:27AM
` and the depth of discharge. 09:38:30AM
`BY MR. LIVEDALEN: 09:38:33AM
`Q. Okay. Now, looking at Ibaraki '882, does Ibaraki '882 09:38:38AM
` compare vehicle speed to a speed threshold? 09:38:43AM
`A. Again, Ibaraki is probably clearest if you look at the 09:38:45AM
` figures that I have annotated on page 168 of my report, 09:38:50AM
` you can see that the Ibaraki uses the vehicle drive 09:38:54AM
` torque and the vehicle speed, and it's to help lay out 09:38:59AM
` the boundaries between the modes. 09:39:08AM
`Q. So it does make a comparison between vehicle speed and 09:39:09AM
` the speed threshold? 09:39:13AM
`A. So it's looking at the torque at a given speed, and 09:39:14AM
` perhaps -- I think I have some other annotated figure at 09:39:19AM
` Figure 11. 09:39:24AM
` Well, perhaps a better figure to look at that 09:40:22AM
` might help clear up any issue here is if we look at 09:40:25AM
` page 87 of my declaration, or one example of an 09:40:27AM
` annotated Figure 11, and you can see I've tried to lay 09:40:32AM
` out some of the conditions here, and you can see -- 09:40:36AM
` looks like you're still turning -- and so you can see 09:40:48AM
`
`Page 13
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` the basic strategy that Ibaraki is employing here is 09:40:50AM
` it's determining the vehicle speed and the required 09:40:54AM
` torque to propel the vehicle, which I've annotated here, 09:40:58AM
` I called that TL on the diagram. And then in order to 09:41:03AM
` make the mode determination it's comparing that value 09:41:06AM
` with the setpoint, which on this curve that I'm showing 09:41:11AM
` is a setpoint to transition to engine drive mode only, 09:41:15AM
` and so it's making comparison that TL is greater than 09:41:20AM
` that setpoint. And the different setpoints, they vary 09:41:24AM
` as a function of speed in Ibaraki, and they're kind of 09:41:28AM
` shown as that line B, that curved line B would be the 09:41:34AM
` kind of boundary value or values in which you would 09:41:39AM
` switch to engine mode, engine drive mode. 09:41:44AM
`Q. So at a point along speed V1 is it your opinion that 09:41:48AM
` there's a comparison between a demand torque and a 09:41:55AM
` torque threshold? 09:42:01AM
` MR. RONDINI: Objection, vague, misstates 09:42:03AM
` testimony. 09:42:07AM
` THE WITNESS: I think what I said is that 09:42:15AM
` there is the -- the curve is set up using the torque, 09:42:18AM
` the vehicle drive torque or the instantaneous torque to 09:42:25AM
` propel the vehicle and vehicle speed so that there are 09:42:29AM
` multiple setpoints. The setpoints vary as a function of 09:42:36AM
` vehicle speed. But in the example I'm showing here on 09:42:40AM
` page 87, at one particular vehicle speed the controller 09:42:43AM
`
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` will determine the value, TL, the torque, at that speed 09:42:49AM
` and make a comparison as to whether that is greater than 09:42:56AM
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` defined by curve B, and it's less than the setpoint that 09:43:10AM
` would be defined on the curve of multiple setpoints of 09:43:16AM
` curve C. So it's looking at the setpoint, SP, that I 09:43:23AM
` have labeled, and the value I called C1, and it's making 09:43:27AM
` a determination in that case that it should be in engine 09:43:31AM
` drive mode. 09:43:35AM
`BY MR. LIVEDALEN: 09:43:35AM
`Q. So is there or isn't there a comparison between a demand 09:43:36AM
` torque and a torque threshold? 09:43:40AM
` MR. RONDINI: Objection, compound. 09:43:42AM
` THE WITNESS: I think I've already answered 09:43:51AM
` that question a couple of times now. 09:44:00AM
`BY MR. LIVEDALEN: 09:44:03AM
`Q. My answer calls for a yes or no answer, so is it yes or 09:44:04AM
` no? 09:44:07AM
` MR. RONDINI: Objection, vague, misstates 09:44:09AM
` testimony. 09:44:13AM
` THE WITNESS: Perhaps I don't understand your 09:44:19AM
` question. 09:44:20AM
`BY MR. LIVEDALEN: 09:44:21AM
`Q. Sitting here today, can you tell me whether or not 09:44:21AM
`
`Page 15
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` Ibaraki '882 compares a torque demand to a torque 09:44:23AM
` threshold? If you can't answer, if you don't know, 09:44:29AM
` that's fine. 09:44:38AM
`A. I guess I don't understand your question. 09:44:38AM
`Q. Okay. So sitting here today you can't tell me whether 09:44:40AM
` Ibaraki '882 compares a torque demand to a torque 09:44:44AM
` threshold, is that right? 09:44:47AM
`A. Again, I don't understand your question. Because I 09:44:48AM
` think I've already answered it a couple of times, but 09:44:51AM
` apparently I haven't. So perhaps we're not 09:44:55AM
` communicating effectively here. 09:45:01AM
`Q. So you can't answer my question? 09:45:02AM
`A. No. I think I already have actually, that I kind of 09:45:03AM
` tried to explain how Ibaraki works here. 09:45:07AM
`Q. I appreciate your long explanations, but I just want an 09:45:13AM
` answer to my question. And if the answer is I don't 09:45:17AM
` know, then that's perfectly fine. So again, I'll repeat 09:45:20AM
` the question. 09:45:23AM
` Sitting here today can you tell me whether or 09:45:23AM
` not Ibaraki '882 compares a torque demand to a torque 09:45:26AM
` threshold? 09:45:29AM
` MR. RONDINI: Objection, asked and answered. 09:45:30AM
` THE WITNESS: Again, I think I did say that, 09:45:31AM
` that the -- the particular example here, you're looking 09:45:37AM
` at the instantaneous torque required to propel the 09:45:42AM
`
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` vehicle, which is indicated by TL if we go back to that 09:45:47AM
` Figure 11 I have annotated on page 87 and you're 09:45:51AM
` comparing to see if it's greater than that setpoint at 09:45:55AM
` the same vehicle speed. And if it is, then you're going 09:45:58AM
` to consider engine drive mode only. You're also going 09:46:03AM
` to look then to see if it's less than the setpoint which 09:46:08AM
` is laid out on -- I called it C1, and if it's between 09:46:13AM
` those two values you're going to go into engine drive 09:46:18AM
` mode. So it's clearly looking at the torque required to 09:46:21AM
` propel the vehicle and comparing it to the setpoint. 09:46:27AM
`BY MR. LIVEDALEN: 09:46:30AM
`Q. So you're telling me there is a comparison? 09:46:30AM
`A. I think I have been telling you that, that it's a 09:46:33AM
` comparison between those values. 09:46:37AM
`Q. Okay. I'm not trying to trick you, I'm just trying to 09:46:38AM
` get -- trying to make sure I understand your opinion. 09:46:41AM
` So you would agree with me then -- or strike 09:46:45AM
` that. 09:46:45AM
` So is it your opinion that Ibaraki '882 09:46:51AM
` compares a torque demand to a torque threshold? 09:46:53AM
` MR. RONDINI: Objection, asked and answered. 09:46:56AM
`BY MR. LIVEDALEN: 09:46:59AM
`Q. I think your answer's yes. I don't know why -- 09:47:01AM
`A. Perhaps I'm just -- I didn't use the exact terms that 09:47:03AM
` you're using in your question, so perhaps maybe that's 09:47:05AM
`
`Page 17
`
` where there's some miscommunication. It definitely 09:47:11AM
` compares its controller determination of the 09:47:17AM
` instantaneous drive torque to propel the vehicle to the 09:47:18AM
` setpoints. 09:47:22AM
`Q. So you said that in your opinion there's a setpoint at 09:47:22AM
` B, along curve B at B1, right, that's where you're 09:47:27AM
` identifying your setpoint? 09:47:35AM
`A. Yes, that's one particular setpoint. That's an example 09:47:36AM
` at that particular vehicle speed. 09:47:39AM
`Q. And at that precise point does Ibaraki compare the 09:47:40AM
` vehicle speed to a speed threshold? 09:47:44AM
`A. You know, it's looking at that particular point in order 09:47:49AM
` to determine what the setpoint torque value would be. 09:47:52AM
`Q. There's no comparison -- 09:47:56AM
`A. And then it's making a comparison. 09:47:58AM
`Q. There's no comparison of a speed, of a vehicle speed to 09:48:00AM
` a speed threshold? 09:48:04AM
`A. I don't believe so, there is a speed threshold there. I 09:48:05AM
` think later on, you know, obviously over the full 09:48:09AM
` operating range of the vehicle, speed is a concern. 09:48:12AM
`Q. Okay. But you would not consider Ibaraki '882 to 09:48:17AM
` disclose a comparison of vehicle speed to a speed 09:48:21AM
` threshold, are you? 09:48:24AM
`A. At this example that I show here, it's using the speed 09:48:25AM
` in order to determine what the setpoint value should be 09:48:28AM
`
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`5 (Pages 14 to 17)
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` at that particular vehicle speed. 09:48:32AM
`Q. Okay. We'll come back to Figure 11 later. But I'd like 09:48:34AM
` to switch to the '634 patent for a little bit. I'll 09:48:47AM
` mark that as an exhibit. 09:48:51AM
` DAVIS EXHIBIT 3 09:49:06AM
` U.S. Patent Number 7,237,634 09:49:06AM
` WAS MARKED BY THE REPORTER 09:49:06AM
` FOR IDENTIFICATION 09:49:11AM
`BY MR. LIVEDALEN: 09:49:11AM
`Q. So, Dr. Davis, do you recognize this exhibit? 09:49:11AM
`A. Yes. 09:49:15AM
`Q. And what is it? 09:49:15AM
`A. It's the Severinsky '634 patent. 09:49:24AM
`Q. Okay. If you can turn with me to Column 23. And at 09:49:30AM
` line 23 through about line 31 do you see a discussion 09:49:55AM
` about typical sedan of 3300 pounds? 09:50:01AM
`A. Yes. 09:50:35AM
`Q. And would you agree that the inventor here indicates 09:51:08AM
` that the typical maximum engine power would be about 165 09:51:13AM
` horsepower, do you see that? 09:51:20AM
`A. That's what he says. 09:51:22AM
`Q. And d