FORD MOTOR COMPANY v. PAICE L.L.C., ET AL.
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`NEIL HANNEMANN (875)
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`April 30, 2015
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`Prepared for you by
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`Bingham Farms/Southfield • Grand Rapids
`Ann Arbor • Detroit • Flint • Jackson • Lansing • Mt. Clemens • Saginaw
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`FORD 1455
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`NEIL HANNEMANN (875)NEIL HANNEMANN (875)
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`April 30, 2015April 30, 2015
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`Page 1
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`Page 3
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`------------------------------x
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`FORD MOTOR COMPANY, :
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` Petitioner, :
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`vs. : IPR2014-00875
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`PAICE LLC & ABELL FOUNDATION, :
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`INC., :
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` Patent Owner. :
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`------------------------------x
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` Deposition of NEIL HANNEMANN
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` Washington, DC
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` Thursday, April 30, 2015
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` 9:53 a.m.
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`Job No.: 78417
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`Pages: 1 - 113
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`Reported by: Janet A. Hamilton, RDR
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` A P P E A R A N C E S
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`ON BEHALF OF PETITIONER:
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`FRANK A. ANGILERI, ESQUIRE
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`JOHN P. RONDINI, ESQUIRE
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`BROOKS KUSHMAN, PC
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`1000 Town Center
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`22nd Floor
`8
`Southfield, Michigan 48075
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`(248) 358-4400
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` -and-
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`THOMAS W. YEH, ESQUIRE
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`LATHAM & WATKINS, LLP
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`555 Eleventh Street, NW
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`Suite 1000
`15 Washington, DC 20004
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`(202) 637-2200
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`ON BEHALF OF THE PATENT OWNER:
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`BRIAN J. LIVEDALEN, ESQUIRE
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`FISH & RICHARDSON
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`1425 K Street, NW
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`11th Floor
`23 Washington, DC 20005
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`(202) 783-5070
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`Page 2
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`Page 4
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` C O N T E N T S
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`EXAMINATION OF NEIL HANNEMANN PAGE
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`By Mr. Angileri 5
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` E X H I B I T S
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` Deposition of NEIL HANNEMANN, held at the
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`Fish & Richardson, PC
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`1425 K Street, NW
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`11th Floor
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`Washington, DC 20005
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`(202) 783-5070
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`Pursuant to Notice, before Janet A. Hamilton,
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`Registered Diplomate Reporter and Notary Public in and
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`for the District of Columbia.
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` (Attached to the transcript)
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`HANNEMANN DEPOSITION EXHIBIT
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`Ex. 1 Declaration of Neil Hannemann in 5
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` Support of the Patent Owner's Response
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` Case IPR 2014-00875
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` Patent 7,559,388
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`Ex. 2 United States Patent No. 7,559,388 5
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` Severinsky, et al.
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`Ex. 3 Electric Vehicle Association of the 65
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` Americas (EVAA) 12th International
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` Electric Vehicle Symposium
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` Poster Sessions
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`Ex. 4 Abstract: Hybrid Power Unit Development 81
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` For Fiat Multipla Vehicle
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`Ex. 5 Equation 3 91
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`Ex. 6 Pages 76, 77 and 78 of Dr. Stein's 104
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` declaration
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`Ex. 7 United States Patent 4,335,429 104
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` Kawakatsu
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`Pages 1 to 4Pages 1 to 4
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`FORD 1455
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`

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`NEIL HANNEMANN (875)NEIL HANNEMANN (875)
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`April 30, 2015April 30, 2015
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`Page 5
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` P R O C E E D I N G S
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` -----
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` (Hannemann Deposition Exhibit No. 1 and
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`Exhibit No. 2 were pre-marked for identification and
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`are attached to the transcript.)
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` NEIL HANNEMANN,
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`a witness herein, being duly sworn, testified as
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`follows:
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` EXAMINATION BY COUNSEL FOR THE PETITIONER
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`BY MR. ANGILERI:
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` Q Good morning.
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` A Good morning.
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` MR. LIVEDALEN: Guarnieri.
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` A Pete Guarnieri. The primary ones, and Linda
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`Kordziel was also in the meetings at times.
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` Q Anyone else that you can think of?
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` A No. That was it.
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` Q Or is there anyone else who you can't
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`remember their name?
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` A No. It was really the, just the three
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`people.
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` Q Did you review any documents in these
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`meetings?
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` A Yes, we did.
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` Q Would you please state your full name for
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` Q Did any of them refresh your recollection on
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`the record.
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` A Neil Hannemann.
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` Q Mr. Hannemann, has your experience changed
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`since the depositions that we had a couple of weeks
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`ago?
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` A You're talking like work experience?
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` Q Sure.
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` A Not -- not significantly, no.
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` Q Anything relevant to your technical
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`expertise change since then?
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` A No.
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` Q Any -- has your experience changed in any
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`anything?
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` A Well, I guess every time I review a document
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`it's refreshing my memory, so I would say yes.
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` Q What documents did you review?
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` A They were all either the, my declaration,
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`the patents at issue or the prior art references.
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` Q So basically the declaration and the things
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`you cite in the declaration?
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` A Yes.
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` Q Anything else?
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` A No. I think that was pretty much it.
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` Q The court reporter's marked as Exhibit 1 --
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`way relevant to these proceedings since your
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`depositions a couple of weeks ago?
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` A You mean experiences I may have had between
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`the two depositions. Is that what your, like work I
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`5 may have done between depositions?
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` Q That would be one example.
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` A Yeah. In that example, no, I haven't done
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`anything relevant between the depositions.
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` Q Has it changed in some other way?
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` A I was just trying to imagine other ways that
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`you might be talking about, and I, I can't come up
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`with any.
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` Q Okay. What did you do to prepare for this
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`well, she's marked two exhibits, Exhibit 1 and Exhibit
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`2.
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` A Okay.
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` Q Can you please tell us what is Exhibit 1?
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` A Well, Exhibit 1 is my declaration and
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`IPR2014-00875 relating to patent 7,559,388, and
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`Exhibit 2 is a copy of the patent 7,559,388.
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` Q How much time did you spend preparing
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`Exhibit 1?
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` A Um, boy, I don't really recall. It was back
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`in probably March or February.
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` Q Did you work with Fish & Richardson
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`deposition?
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` MR. LIVEDALEN: I would caution the witness
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`not to reveal any communications between him and
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`counsel.
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` A Yeah. I've been basically -- I've been here
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`the last three days meeting with counsel.
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` Q Today is April 30th. So the last three days
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`you're talking April 27 through 29?
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` A That's correct.
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` Q With whom did you meet?
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` A I met with Brian Livedalen and Pete -- I
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`always get this pronunciation wrong.
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`attorneys in preparing Exhibit 1?
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` A Yes, I did.
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` Q Would you turn to page 13, paragraph 35.
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` A Okay.
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` Q Can you read into the record, the sentence
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`starts on line 7 says "as noted in the '388 patent"?
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` A Just the first, that sentence?
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` Q Just that sentence, yeah.
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` A Yeah. "As noted in the '388 patent, these
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`prior systems fail to understand that the vehicle
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`operational mode should preferably be controlled in
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`response to the vehicle's actual torque requirements,
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`i.e., the road load, which provides superior
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`Pages 5 to 8Pages 5 to 8
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`FORD 1455
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`

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`NEIL HANNEMANN (875)NEIL HANNEMANN (875)
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`April 30, 2015April 30, 2015
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`Page 9
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`Page 11
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`performance in terms of both vehicle response to
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`operator commands and dual efficiency under the widely
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`varying conditions encountered in the real world
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`driving situations."
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` Q That statement that you quote about superior
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`performance, do you have any basis to support that
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`statement?
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` A I don't have any test data, but the '388
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`patent is based on a, a, you know, a road load based-
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`system and the others aren't, and I guess, you know,
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`that, you know, particular element could give superior
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`performance.
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`of using a road load -- strike that. Are you offering
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`an opinion on the benefits of using road load to
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`select vehicle mode?
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` A Not what's beyond stated in the patent, no.
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` Q Well, what's -- what's stated in the patent?
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` A Well, it's the -- what I cite is column 13,
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`lines 33 and 49 in the patent.
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` Q So are you offering an opinion that the road
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`load -- strike that. Are you offering an opinion that
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`using road load to select vehicle mode provides
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`benefits?
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` MR. LIVEDALEN: Objection. Asked --
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` Q Are you offering an opinion that a road
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`load-based system provides superior performance to
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`other systems?
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` A The -- I believe the patent gives that, that
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`statement, that's --
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` Q Are you, Mr. Hannemann, offering an opinion
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`that a road load-based system offers superior
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`performance to other systems?
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` A I would just defer to any statements about
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`that that are in the patent.
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` Q Do you have any opinion that a road
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`load-based system provides superior performance to
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`other systems?
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` Q Or are you just quoting the patent?
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` MR. LIVEDALEN: Objection. Vague. Asked
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`and answered.
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` A Well, I am -- this is my analysis of the
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`patent, and that's a statement the patent makes, and I
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`don't have any reason to disagree with that statement.
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` Q Do you have any reason to agree with it?
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` A Well, I -- I do agree with it, yes.
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` Q Why? What basis do you have for agreeing
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`with it?
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` A Well, it's just discussing some general
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`concepts that someone of skill in the art would
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`understand are technically correct.
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` MR. LIVEDALEN: Asked and answered.
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` A Yeah. That's not -- that's not something I
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`analyzed. I -- I'm just going off material in the
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`patent.
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` Q Can you provide any support for the
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`statement that a road load-based system provides
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`superior performance to other systems other than just
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`quoting the '388 patent?
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` A I would say the '388 patent is sufficient
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`for that.
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` Q You can't cite anything else that supports
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`that statement; correct?
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` A Well, I haven't, like I say, I haven't
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` Q Where does it discuss -- are you talking
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`about column 13, lines 33 to 49, the ones you cite?
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` A Yes.
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` Q Have you done any test data to address
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`whether those statements are correct or not?
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` A I haven't done any testing, no.
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` Q Yeah, that was a bad question. The question
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`is, have you done any testing to address whether those
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`statements in the patent are correct?
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` A Correct. I have -- I've not done any
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`testing.
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` Q Have you done any independent analysis to
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`analyzed that as part of this case. So I haven't done
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`the research to go cite a different reference other
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`than what I've looked at for this case.
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` Q Further down, can you read the next sentence
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`into the record, please? Starts with "additionally."
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` A "Additionally this failure to recognize
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`benefits of using road load to select vehicle mode
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`also led prior art systems to incorrectly cite other
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`system components such as the battery and motors which
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`similarly resulted in operating the engine under less
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`efficient conditions."
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` Q Are you offering an opinion on the benefits
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`determine whether those statements in the patent are
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`correct?
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` A No. My -- my work here was to respond to
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`the declaration of either Dr. Stein or Davis. So I
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`didn't do any independent work.
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` Q Likewise, when you talk about prior art
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`systems incorrectly sizing system components, do you
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`have any support for that statement other than the
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`patent?
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` A I'm basing that statement on the patent.
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` Q And you have no other support; correct?
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` A Correct.
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` Q So for all these statements about the '388
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`Pages 9 to 12Pages 9 to 12
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`FORD 1455
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`

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`NEIL HANNEMANN (875)NEIL HANNEMANN (875)
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`April 30, 2015April 30, 2015
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`Page 13
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`patent being superior to other modes or providing
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`benefits, you rely solely on the '388 patent for those
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`statements; correct?
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` A Well, I wouldn't say all the other comments,
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`but if they're all in the same section, it's my
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`analysis of the patent, so it's based strictly on the
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`patent.
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` Q Could you turn to page 16, paragraph 40.
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` A Okay.
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` Q Do you see it?
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` A Yes.
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` Q There's a portion of a dashed line that's
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`nonlinear, the engine output torque threshold will be
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`nonlinear?
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` MR. LIVEDALEN: Objection. Mischaracterizes
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`previous testimony.
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` A Well, the patent does state that it's
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`limited to a threshold, and so it wouldn't exceed the
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`threshold, but it may be possible that it's lower than
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`the threshold.
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` Q What is the "it" in your last answer?
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` A The engine torque output.
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` Q In the portion of the graph where you have
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`the cross-hatching, is the engine torque output box
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`labeled engine torque output. Do you see that?
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`pointing to a section of a line where the engine
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` A Yes.
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` Q And did you add some cross-hatching between
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`the engine torque output and the road load?
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` A Yeah. That's not in the original graph.
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` Q Why did you add that cross section?
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` A Well, that's the, the difference in, you
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`know, a limited torque output and the road load.
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` Q The line for engine torque output that's
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`being pointed to, and that's at the bottom of your
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`cross-hatching; right?
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` A Yes.
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` Q Is that a linear -- is that line generally
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`torque output is limited to a threshold?
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` A In this part of the graph, yes, that's --
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`that is the threshold limit.
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` Q What does figure 7C show in paragraph 40 of
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`your declaration?
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` A So figure 7, there's a general description
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`in the patent of what figure 7 is which states figure
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`7 comprising figures 7A through C and extending over
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`two sheets is a timing diagram showing road load,
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`engine torque output, the state of charge the battery
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`bank and engine operations as functions of time, thus
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`illustrating a typical control strategy employed
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`linear?
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` MR. LIVEDALEN: Objection. Vague.
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` A It is shown in this graph as linear. I
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`would -- based on the, what I understand of the
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`control strategy in the patent, I don't think it
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`necessarily has to be linear.
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` Q Why is that?
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` A I think that the patent which is determining
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`the road load, if the amount of road load changes
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`during a certain time period, then it may change its
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`control strategy. The control strategy may change the
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`engine output torque.
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` Q Can you give me an example what you're
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`during low speed city driving, highway cruising and
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`extended high load driving.
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` Q What is 7C?
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` A Well, this general description I just read
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`describes A through C.
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` Q You cannot elaborate on that?
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` A Well, let me see if the patent elaborates on
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`it anywhere.
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` Q Can you elaborate on it separate from
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`looking at the patent?
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` Mr. Hannemann, did you hear my question?
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` A Yeah and --
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`talking about in connection with this portion of the
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`curve that where you've got the cross-hatching?
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` A Well, if -- I mean you can see in what's
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`referenced as area F that's near the top portion of
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`that what appears to be a straight line does turn into
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`a curve line. So if that, that kind of curve
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`character, you know, of the, of the road load were in
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`a mode similar to the mode that's referred to in the
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`cross-hatched area, then it's possible the engine
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`output torque could also not follow the linear
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`characteristic that it has here.
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` Q So you're saying that if the road load is
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` Q The question was, can you elaborate on
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`figure 7C separate from reading what the patent says
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`about it?
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` A And, no, I'd rather read from the patent,
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`so, for accuracy.
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` Q Does figure 7C mean anything to you separate
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`from reading the patent?
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` A Well, I -- I think that it's most accurate
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`to refer to the patent for that reference.
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` Q That wasn't my question. I can read the
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`patent. I can't go into your brain. What does figure
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`7C mean to you?
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` MR. LIVEDALEN: Objection. Asked and
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`Pages 13 to 16Pages 13 to 16
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`FORD 1455
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`

`
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`NEIL HANNEMANN (875)NEIL HANNEMANN (875)
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`April 30, 2015April 30, 2015
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`Page 17
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`answered.
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` Q So can you tell me anything about figure 7C
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`separate from reading what the patent says about it?
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` MR. LIVEDALEN: Same objection.
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` A Well, let me read what the patent says about
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`it, and then I'll answer your question.
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` Q I guess the answer is "no" then; right?
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` MR. LIVEDALEN: Objection. Mischaracterizes
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`previous testimony.
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` A Well, the patent states that the area K is
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`an area where excess engine torque available from the
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`engine is used to charge the batteries.
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`output is not limited, I would assume that it would
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`follow the road load, and that's those two areas. I'm
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`still looking in the patent to see where it discusses
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`area Q of the graph.
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` I'm not finding a discussion in the patent
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`of area Q, and so it's hard for me to determine if
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`that's an area where the torque's limited to a
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`threshold, and I don't know, since my job mostly was
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`responding to Dr. Stein or Dr. Davis, is this an area
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`that they opined on that, that I would have responded
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`to or --
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` Q Did you finish completing the red portions
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` Q Does figure 7C show two times when the
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`of the other parts of figure 7? I think you did 7C.
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`engine torque output is limited to a threshold value?
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` MR. LIVEDALEN: Objection. Vague.
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` A I think there's likely more than two times
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`where it's limited to threshold.
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` Q What are those times?
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` A Well, any area on the graph where the torque
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`is changing, either increasing or decreasing.
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` Q So could you point out where on figure 7C
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`the rate of change of engine output torque is limited
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`to a threshold value? Here's a red pen. You can mark
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`on it.
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` A The -- so the graph, the full two pages of
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`Did you circle the portions of 7A where the rate of
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`change of engine output torque was limited to a
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`threshold value?
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` A I circled two areas, and I wouldn't say that
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`those are all the areas, but those are two areas.
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` Q Would you turn to paragraph 43 of your
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`declaration, please.
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` A Okay.
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` Q Paragraphs 43 and 44 are your summaries of
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`claims 1 and 19; correct?
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` A Yeah. 44 discusses claim 1, or 43 discusses
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`claim 1. 44 discusses claim 19.
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`Page 20
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`the graph is not on my declaration, so do you want me
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`to just mark the part that's in here in the
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`Page 18
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`declaration?
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` Q Why don't you mark the patent. That's going
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`to have the full graph. Mark the portions in figure 7
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`where the rate of change of engine output torque is
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`limited to a threshold value.
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` (Witness marking document.)
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` Q My original question asked you to mark them
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`on figure 7C. Can you also mark them on the other
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`portions of figure 7, please?
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` A Sure.
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` Q Do you agree that the control strategy of
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`claim 1 and the method of claim 19 arise only when the
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`rate of change of engine output is limited to a
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`threshold value and the rate of change of road load
`
`exceeds that threshold value?
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` MR. LIVEDALEN: Objection. Vague. Calls
`
`for a legal conclusion.
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` A So claim 1 states when the rate of change of
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`torque output is limited to threshold value wherein a
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`rate of change of road load exceeds said threshold
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`value. So, so I think claim 1 answers that, answers
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`your question in claim 1.
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` Yeah, claim 19 also states that when the
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` Q Before you road any further, how did you
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`know to mark those portions?
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` A Well, by comparing 7C to 7A, the two graphs
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`are different, the road load and the engine torque
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`output.
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` Q So you -- you knew where to -- strike that.
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`You knew where the rate of change of engine output
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`torque is limited to threshold value because the
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`engine output torque lags the road load at certain
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`portions of the graph?
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` MR. LIVEDALEN: Objection. Mischaracterizes
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`previous testimony and calls for legal conclusion.
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` A That is, was my basis. If the engine torque
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`rate of change of road load exceeds a threshold value
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`of the rate of change of torque output engine. So
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`that would I believe be a yes answer to your question.
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` Q What is the benefit of the invention of the
`
`'388 patent?
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` MR. LIVEDALEN: Objection. Vague.
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` A I don't know if there's one single benefit
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`to the patent.
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` Q Can you identify any benefit to this
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`invention?
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` MR. LIVEDALEN: Same objection.
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` A Well, there's some general benefits that the
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`
`
`Pages 17 to 20Pages 17 to 20
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`FORD 1455
`
`

`
`
`NEIL HANNEMANN (875)NEIL HANNEMANN (875)
`
`April 30, 2015April 30, 2015
`
`Page 21
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`Page 23
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`patent discusses since it's all in the patent.
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` Q Can you identify any?
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` MR. LIVEDALEN: Asked and answered.
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` A I guess I could go through and pick out
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`some. I'm not sure I just go through and pick out all
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`the benefits, but --
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` Q Is it fair to say you can't identify any of
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`them right now without reading the patent?
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` MR. LIVEDALEN: Objection. Mischaracterizes
`
`previous testimony.
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` A I would prefer to read them out of the
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`patent just for accuracy.
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` Q Is a user getting any benefits from this
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`strategy and method of the '388 patent when the road
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`load isn't changing?
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` MR. LIVEDALEN: Objection. Vague.
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` A I guess which, which user are you talking
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`of? Somebody who used the patent or someone who would
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`use a vehicle that uses the patent control strategy?
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` Q It would be a person using a vehicle that's
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`using this strategy or method.
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` MR. LIVEDALEN: Same objection.
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` A Okay. So now we've clarified that, could
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`you repeat the first part of the question?
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` Q Can you identify any benefits of the '388
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` Q Sure. If a person is using a vehicle that
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`invention without reading the patent right now?
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` A I probably could, but I wouldn't -- it
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`wouldn't be a complete and -- complete answer.
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` Q Go ahead.
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` A Well, in general it's improvements for
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`hybrid vehicles, and it also states that there were
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`improvements for fuel economy and emissions and just
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`general vehicle efficiency. So in a broad general
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`sense those are some advantages to the patent.
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` Q Are those benefits achieved by limiting the
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`rate of change of engine output torque when the rate
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`of change of road load exceeds the threshold value?
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`is using the strategy and method of claims 1 and 19,
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`do you agree that that person is not getting any
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`benefit of the strategy and method when the road load
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`is not changing?
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` MR. LIVEDALEN: Same objection.
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` A Yeah. That's I guess the benefit relative
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`to, to what? So it's hard to claim you have a benefit
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`unless you're comparing it to something else.
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` Q Do the strategy and method of claims 1 and
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`19 provide any benefit during a time when the road
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`load isn't changing?
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` MR. LIVEDALEN: Same objection and asked and
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`Page 22
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` MR. LIVEDALEN: Objection. Vague.
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` Q Strike that. Are those benefits achieved by
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`limiting the rate of a change of engine output torque
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`to a threshold value when the rate of change of road
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`load exceeds that threshold value?
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` A I know there are benefits during times when
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`I think the road, change in road load exceeds the
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`engine torque output, and as far as the entire patent
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`having benefits and other operating conditions, there
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` MR. LIVEDALEN: Same objection.
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`6 may be. It's just something I haven't studied.
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` A Yes. I think someone skilled in the art
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`would recognize that would give you a fuel economy and
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`emissions benefit.
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` Q Do you agree that the control strategy and
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`method of the '388 patent are not used when the rate
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`of change of engine output torque is not limited to a
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`threshold value?
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` Q Can you identify any benefit that the
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`strategy and method of claims 1 and 19 provide during
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`times when the rate of change of road load does not
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`exceed the threshold of those claims, the threshold
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`value of those claims?
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` MR. LIVEDALEN: Objection.
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` MR. LIVEDALEN: Objection. Vague.
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` A I guess I couldn't really state for
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`certainty when it's not used.
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` Q Do you agree that the strategy of claim 1
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`and the method of claim 19 are not used when the rate
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`of change of road load does not exceed the claimed
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`threshold value?
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` MR. LIVEDALEN: Objection. Vague. Asked
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`and answered.
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` A Well, these statements do state when the
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`strategy is applied, but I -- it doesn't go on to
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`exclude or state when it's, when it's not applied.
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` A I guess I could only respond to that if you
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`can, if it's something that Dr. Stein or Davis opined
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`on because I was responding to their, to their claims
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`and not, you know, not providing a complete analysis
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`of how one of skill in the art would apply the patent.
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` Q Does that mean that at this time you cannot
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`identify any benefit that the strategy and method of
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`the '388 patent provides when the rate of change of
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`road load does not exceed the threshold value of those
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`claims; correct?
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` MR. LIVEDALEN: Objection. Vague.
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` A No, that's not correct. What I -- I haven't
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`done that analysis, and were there an opinion I was
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`Pages 21 to 24Pages 21 to 24
`
`FORD 1455
`
`

`
`
`NEIL HANNEMANN (875)NEIL HANNEMANN (875)
`
`April 30, 2015April 30, 2015
`
`Page 25
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`responding to about that particular condition, then I
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`could give you an opinion on it, but I guess that's
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`not an analysis I've done in this case.
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` Q Please turn to paragraph 54.
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` MR. LIVEDALEN: Is this a good time to take
`
`a break, either now or in the next few minutes?
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` MR. ANGILERI: We can do that.
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` MR. LIVEDALEN: Okay. Cool.
`
` (A recess was taken from 10:50 a.m. until
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`11:04 a.m.)
`
`BY MR. ANGILERI:
`
` Q Mr. Hannemann, I was -- I think I focused
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` Q It shows a vehicle where the drivability
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`torque requirements are increasing over time. Do you
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`agree with that?
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` A Right. The drivable torque requirement as
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`defined in this reference is basically the accelerator
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`pedal position. So this shows different accelerator
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`pedal positions.
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` Q And those accelerator pedal positions are
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`increasing over time?
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` A It shows three different positions on this
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`graph.
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` Q Do you agree it doesn't show any kind of
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`you to paragraph 54 of your declaration.
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`braking situation?
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` A Yes.
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` Q There's a figure 8 from the Vittone
`
`reference in your declaration; right?
`
` A Yes.
`
` Q And -- strike that. Do you agree that this
`
`is not showing the entire drive cycle of vehicle?
`
` MR. LIVEDALEN: Objection. Vague.
`
` Q This figure 8 that you reproduced?
`
` A Well, I'm not sure it shows a drive cycle at
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`all, but that's kind of a broad term, drive cycle.
`
` Q Fair enough. What does drive cycle -- since
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`I used the term -- what does drive cycle mean to you?
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` MR. LIVEDALEN: Objection. Vague.
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` A You know, could I replicate this data and
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`have brakes on? I probably could, but I -- but from
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`17 my recollection, reference I don't recall that it
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`specifically discussed braking.
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` Q With respect to figure 8?
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` A Yeah, correct. I just don't recall. I'd
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`have to look through the reference again to know for
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`sure, but it's probably not likely this was showing
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`any braking.
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` Q What would you expect braking to look like
`
`on this, if it was on figure 8?
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`Page 28
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` A Well, there's probably, depending on the
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`context, it could mean, you know, different things.
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` Q All right. Well, you said, "I'm not sure
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`it," referring to figure 8, "shows a drive cycle at
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`all." What did you mean by that?
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` A Well, you know, drive cycle, as I say, can
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`be different things, but this just could be a
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`something that's an example of how you would operate
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`this engine. It could also be a, you know, a data
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`grab of three seconds of data off of a test vehicle,
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`or it can even be a computer simulation.
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` Q Either way, do you agree that figure 8 is
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`not intended to show all of the things that might
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` MR. LIVEDALEN: Objection. Vague. Calls
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`for speculation.
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` A I guess it could vary differently depending
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`on the control strategy that this particular reference
`
`has for braking.
`
` Q In paragraph 54 you state, quote, "figure 8
`
`depicts the driving torque management for the hybrid
`
`mode," end quote. Do you see that?
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` A Yes.
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` Q What is the purpose of driving torque?
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` MR. LIVEDALEN: Objection. Vague.
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` A Well, and I probably pulled that term right
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`happen when you're driving a vehicle?
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` MR. LIVEDALEN: Objection. Vague.
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` A I would agree that's probably not likely. I
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`think this figure is showing what the reference
`
`describes that it was showing.
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` Q This figure 8 in paragraph 54 of your
`
`declaration -- strike that. This figure 8 from the
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`Vittone reference, it shows a vehicle accelerating.
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`Do you agree with that?
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` A You know, I don't see speed on here anyways.
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`So I guess I couldn't say it shows a vehicle
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`accelerating.
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`out of this reference, so I'd probably rather refer to
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`the reference to see how they, how they referred to
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`driving torque.
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` Q Is driving torque some kind of unique term
`
`that you've never heard of before, that's why you need
`
`the reference?
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` MR. LIVEDALEN: Objection. Vague.
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`Compound.
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` A It's not -- it's probably not the most
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`standard term. It's not the word that I would refer
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`to, or the two words don't have a particular meaning
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`to me, no.
`
` Q What about traction torque? Does that mean
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`
`Pages 25 to 28Pages 25 to 28
`
`FORD 1455
`
`

`
`
`NEIL HANNEMANN (875)NEIL HANNEMANN (875)
`
`April 30, 2015April 30, 2015
`
`Page 29
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`anything to you?
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` A Traction torque in the context of a hybrid
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`vehicle or an electric vehicle would generally refer
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`to the torque off of an electric motor.
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` Q So the total traction torque, is it your
`
`understanding that the total traction torque only
`
`refers to an electric motor?
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` MR. LIVEDALEN: Objection. Vague.
`
`