FORD MOTOR COMPANY v. PAICE,LLC, ET AL.
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`NEIL HANNEMANN
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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 1460
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`

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`NEIL HANNEMANNNEIL HANNEMANN
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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. : IPR2014-00884
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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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` Volume 1
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` Deposition of NEIL HANNEMANN
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` Washington, DC 20005
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` Thursday, April 30, 2015
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` 3:07 p.m.
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`Job No.: 81418
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`Pages: 1 - 60
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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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` Deposition of NEIL HANNEMANN, held at the
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`office of:
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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. Rondini 5
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`Fish & Richardson, PC
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` E X H I B I T S
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` (Attached to the transcript)
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`HANNEMANN DEPOSITION EXHIBIT
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`Ex. 8 Declaration of Neil Hannemann in 5
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` Support of the Patent Owner's Response
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` Case IPR 2014-00884
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` Patent 7,104,347
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`Ex. 9 United States Patent No. 5,841,201 6
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` Tabata, et al.
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`Ex. 10 United States Patent No. 7,104,347 13
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` Severinsky, et al.
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`Ex. 11 Hand drawing engine speed/torque 40
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`Pages 1 to 4Pages 1 to 4
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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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`FORD 1460
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`

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`NEIL HANNEMANNNEIL HANNEMANN
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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. 8 was
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`pre-marked for identification and is attached to the
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`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 PETITIONER
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`BY MR. RONDINI:
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` Q Good afternoon, Mr. Hannemann.
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` A Good afternoon.
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`you recognize this patent?
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` A Yes, I do.
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` Q What is this patent?
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` A This is the what we refer to as the Tabata
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`'201 patent.
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` Q Okay. Can you turn to paragraph 121 of your
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`report? Paragraph 121 you continue talking about
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`instantaneous demand power, and then you conclude the
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`paragraph by illustrating figure 5 of Caraceni; is
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`that correct?
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` A Yes.
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` Q Why did you insert the figure from Caraceni
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` Q I'm going to hand you what's been marked
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`to your discussion of Tabata '201?
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`Exhibit No. 8, and if it's okay we're just going to
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`continue the numbering from the previous one.
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` MR. LIVEDALEN: Yeah, sure. Thanks.
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` Q Mr. Hannemann, what is Exhibit No. 8 that I
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`just handed you?
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` A Well, it's just in the references we had
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`involved six IPRs just one where there was a torque in
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`power curve, and I just picked that as an example.
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` Q Why did you feel that was important?
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` A I did it to show that there is, you know,
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` A That's my declaration in IPR2015-00884 [sic]
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`19 more than one torque curve if you're not at wide open
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`for patent 7,104,347.
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` Q And do you recall what references you were
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`reviewing with respect to this declaration?
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` A It's in the table of contents, but it's
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`reference we call Caraceni, and then there were two,
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`two patents by Tabata.
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`throttle that you could have various torque levels,
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`and then to, just to digitize the, the torque curve to
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`create some of the other graphs that I created in the
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`declaration.
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` Q Okay. What do you mean by digitize the
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`graphs?
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`Page 8
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`Page 6
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` Q The Tabata '201 patent and the '501 patent?
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` A That's correct.
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` Q Could you turn to page 60 of your report.
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`Page 60 starts your analysis with respect to the
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`Tabata '201 and Tabata '501 patent; correct?
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` A Yes.
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` Q You start off in paragraph 113 talking about
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`Tabata 1, and it calculates demand power; is that
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`correct?
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` A Yes.
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` Q Can you explain what demand power means?
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` A Well, it can be contextual. So I have to
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` A Well, just to pull off the values and get
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`torque and, torque and RPM. I could have used fewer
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`values and just scaled it off, but it's just the way I
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`did it.
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` Q So you're referring to paragraph 123? Is
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`that what you're looking at where you have a chart
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`with engine speed and torque? Is that what you're
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`talking about --
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` A Yes.
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` Q -- with digitizing?
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` A That's the data from the graph. So that was
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`the purpose for using this graph.
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`remember how Tabata used that, and demand power I
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` Q So is it fair to say that you extrapolated
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`refer to it as instantaneous drive power.
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` Q Paragraph 113 you also talk about how Tabata
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`'201 determines or calculates instantaneous drive
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`power; is that correct?
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` A Well, I said it can be calculated by the
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`product being torque. I'm not sure that Tabata's
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`doing exactly that way.
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` (Hannemann Deposition Exhibit No. 9 was
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`22 marked for identification and is attached to the
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`transcript.)
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` Q Mr. Hannemann, what's been marked and handed
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`to you as Exhibit No. 9 is US Patent 5,841,201. Do
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`the data from the graph shown in paragraph 121 to
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`generate the chart shown in 123?
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` A That's accurate, yes.
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` Q Okay. And you did that I believe you just
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`testified in order to generate the figures and graphs
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`that you have in paragraphs 124 and 126 of your
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`report; is that correct?
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` A Yes.
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` Q What are you showing in paragraph 126 of
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`your report?
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` A Well, they're all, those few paragraphs are
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`all related, but 126 just shows a control sample of a
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`Pages 5 to 8Pages 5 to 8
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`FORD 1460
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`

`
`
`NEIL HANNEMANNNEIL HANNEMANN
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`April 30, 2015April 30, 2015
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`Page 9
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`control strategy that would compare road load to a
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`setpoint.
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` Q What control strategy is it a sample of?
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` MR. LIVEDALEN: Objection. Vague.
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` A Yeah. This would be out of the subject
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`6 matter.
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` Q So it's your opinion that paragraph 126, the
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`chart in paragraph 126 is illustrating the control
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`strategy as disclosed by the '347 patent?
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` A Yes.
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` Q What are you representing on the y-axis?
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` A Of the graph in 126?
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`This was done to get a comparison really to lead in to
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`the later graph where I compare the power threshold to
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`the torque threshold.
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` Q Well, you previously testified this is the
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`control strategy of the '347; correct?
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` A This is based on the control strategy. It's
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`not a full disclosure of the control strategy.
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` Q What's missing from it?
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` A Well, there's other modes of operation that
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`this graph doesn't, doesn't describe.
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` Q What other modes?
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` A All this graph is describing is the, the 30
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` Q Correct.
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` A Yeah. That's the 5 Newton meters is 30
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`percent of the 115 Newton meters of the Caraceni
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`engine.
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` Q I want to back up and be more general. Just
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`on the y-axis what are you illustrating on the y-axis
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`in general?
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` A Oh, it's engine torque.
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` Q Engine torque. And is the x-axis
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`illustrating engine speed?
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` A Yes.
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` Q And what does the area shaded in green
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`represent?
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`percent MTO setpoint which the engine operates or
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`doesn't operate. That's all it's doing.
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` Q Okay. So based just on the graph here, if
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`you had an engine torque value of 60 Newton meters and
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`engine speed of 2,000 RPM, what would the operational
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`mode be?
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` MR. LIVEDALEN: Objection. Vague.
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`Foundation. Incomplete hypothetical.
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` A Yeah. That's not an analysis that I've
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`done.
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` Q You previously testified that the green area
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`that's shaded on this graph is where the engine
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`operates; is that correct?
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` A That's torque values that are above 30
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`percent of the maximum torque output.
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` Q And what is occurring in the area shaded
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`green?
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` A Well, various things could occur. It's just
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`showing above and below the setpoint.
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` Q Well, with respect to the control strategy
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`the '347 what would happen above in the green area?
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` MR. LIVEDALEN: Objection. Vague.
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` A Well, that's the decision to turn on and
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`operate the engine.
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` Q And below in the red area, what's happening
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` A Yes.
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` Q And red area is where the motor operates; is
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`that correct?
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` A Yes, and there may be motor operation in the
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`green area. I just didn't go to that level of detail.
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` Q What do you mean there may be motor
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`operation in the green area?
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` A If the motor's supplementing the maximum
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`torque of the engine.
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` Q Where is the maximum torque of the engine
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`illustrated on this graph?
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` A Well, the maximum I use for the 30 percent
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`is 115 Newton meters which is along in the blue line
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`there?
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` A In the red area the engine would not be
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`operated and you'd have an electric-only mode.
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` Q Okay. Sticking with this graph shown in
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`paragraph 126, if we had an engine torque value of 60
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`Newton meters and engine speed of 2,000 RPM, what
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`would the control strategy of the '347 do?
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` MR. LIVEDALEN: Objection. Vague.
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`Incomplete hypothetical. Foundation.
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` A I didn't do this, this graph to illustrate
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`the entire working of the control strategy. So I'd
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`have to probably read through the patent to try to
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`figure that out. That's not something I analyzed.
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`probably between 4,000 and 5,000 RPM.
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` Q So the maximum torque output is above every
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`portion that's shaded in green; isn't that correct?
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` A That's the maximum torque at that particular
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`engine speed.
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` Q So is it your opinion that control strategy
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`as described in '347 the motor can operate somewhere
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`in the green shaded area?
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` MR. LIVEDALEN: Objection. Vague.
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` A I think there's, there's other modes that I
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`didn't put on this graph. So could there be? Yes,
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`it's possible, but I didn't analyze every mode on this
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`Pages 9 to 12Pages 9 to 12
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`FORD 1460
`
`

`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 30, 2015April 30, 2015
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`Page 13
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`graph. Like I said, this was just used to illustrate
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`the 30 percent MTO setpoint.
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` Q And the 30 percent MTO setpoint, that's the
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`claim setpoint of the '347 patent?
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` MR. LIVEDALEN: Objection. Vague.
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`Mischaracterizes previous testimony. Calls for legal
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`conclusion.
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` A It is a setpoint at least as claimed in
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`claim 23.
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` Q What about claim 1 of the '347 patent?
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` A I don't have a section in my declaration
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`about claim 1 in particular.
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`than the maximum torque output as claim 1 describes.
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` Q Can you look at claim 6 of the '347 patent?
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` A Yes.
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` Q Does claim 6 recite a setpoint that's at
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`least 30 percent of the maximum torque output of the
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`engine?
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` A It actually says at least approximately 30
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`percent of the maximum torque output.
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` Q So with claim 6 as guidance, is it fair to
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`say that the 35 Newton meter setpoint you have
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`illustrated in paragraph 126 is representative of that
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`setpoint?
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`transcript.)
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` Q Mr. Hannemann you've just been handed
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`Exhibit No. 10 which is US Patent 7,104,347. Do you
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`recognize this exhibit?
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` A Yes, I do.
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` Q What is this exhibit?
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` A It's what you just said it was.
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` Q This is the '347 you were just referring to?
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` A Yes.
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` Q Could you turn to column 58 of the '347
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`patent. Do you see setpoint mentioned within claim 1
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` A It would also apply to that setpoint, yes.
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` Q So is it fair to say that since claim 6
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`depends from claim 1, the 35 Newton meter setpoint you
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`have illustrated in paragraph 126 is illustrative of
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`the setpoint claimed in or recited in claim 1?
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` A Well, I'm not sure that I was doing that
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`kind of analysis when I picked the number for the
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`graph. So if we're still talking in context to the
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`graph, I would say that I wouldn't apply that kind of
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`statement.
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` Q But this setpoint you have illustrated in
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`paragraph 126, the graph in 126 of your report, it is
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`representative of the setpoint as recited in claim 6
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`of the '347 patent?
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` A Yes, I do.
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` Q Is the setpoint that is recited in claim 1
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`of the '347 patent the same setpoint you're
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`illustrating in paragraph 126 of your report?
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` MR. LIVEDALEN: Objection. Calls for legal
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`conclusion.
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` A No. It could be, and the setpoints are
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`illustrated values in the patent, and someone of skill
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`in the art would take this patent and then apply it to
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`the calibration of implementing the patent, and they
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`12 may come up with a slightly different value, and the
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`of the '347 patent; is that correct?
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` A It does illustratively represent that, yes,
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`it does.
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` Q With respect to the setpoint illustrated in
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`paragraph 126, why did you illustrate it as a straight
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`line that's parallel to the engine speed x-axis?
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` A Well, because it's a fixed value. It's 30
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`percent of the maximum torque output gives you a
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`constant number.
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` Q Is it always going to be a straight line?
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` A You know, I think that's -- as I said
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`before, somebody applying the patent would calibrate
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`different vehicles applying this technology may have a
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`the system and, you know, applying the patent there's
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`different value. So the numbers here are, are
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`illustrative.
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` Q I realize the numbers are illustrative. I'm
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`wondering, you have a torque value illustrated here as
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`a setpoint; is that correct?
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` A Yes.
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` Q And you said that's the setpoint as recited
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`in claim 23 of the '347 patent; is that correct?
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` MR. LIVEDALEN: Objection. Mischaracterizes
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`previous testimony.
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` A Yeah. I use 30 percent. 30 percent is in
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`25 more than one claim, and it also is substantially less
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`some, there's some scope to calibrating to a
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`particular car, and that may change the value. It
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`could make it change the character of the line or
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`change the values.
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` Q Okay. You said it could change the
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`character of the line. Can you please explain what
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`you meant by that?
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` A Yes. Some -- someone may choose to, to not
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`have it a constant value across the entire RPM range.
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` Q Well, what example could you provide that
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`would be a nonconstant value across the entire RPM
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`range?
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`Pages 13 to 16Pages 13 to 16
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`FORD 1460
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`

`
`
`NEIL HANNEMANNNEIL HANNEMANN
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`April 30, 2015April 30, 2015
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`Page 17
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`Page 19
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` A Well, I could imagine somebody might apply
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`the, the torque at that particular RPM.
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` Q Could you explain that a little bit more.
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`I'm not sure I understand.
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` A I'm just looking through to see if there's
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`an example.
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` Q Sure. Mr. Hannemann, let's start with a
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`different question. Could the claim setpoint, the
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`claim setpoint vary as a function of vehicle speed?
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` MR. LIVEDALEN: Objection. Vague. Calls
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`for a legal conclusion.
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` A Well, I think there's scope to vary it I
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` A Well, again --
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` MR. LIVEDALEN: Same objections.
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` A This just says it can be varied. It doesn't
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`say how you would do it. So I can imagine different
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`ways of doing it, but the patent doesn't specify that.
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` Q I realize that, but as someone skilled in
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`the art who's read these patents and opined on them,
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`in your opinion what examples can you provide of a
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`setpoint that varies as a function of engine speed?
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` MR. LIVEDALEN: Same objections.
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` A Well, if you were to apply the 30 percent to
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`the torque at each engine speed, that would vary it by
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`think in different claims, and it generally specifies
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`engine speed, and if you chose to increase the
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`that's the maximum of the engine at any RPM or if it's
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`at the RPM that the engine's operating at. So I think
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`there's some interpretation there.
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` Q Okay. Well, let's start with my question
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`though. Could -- could the setpoint you've
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`illustrated in paragraph 126 of your report, could
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`that vary as a function of vehicle speed?
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` MR. LIVEDALEN: Same objection.
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` A Well, the setpoint and the scope it talks
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`about being, the term here at least approximately 30
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`percent, and it's not specific as to whether that
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`percentage over the range of engine speed or decrease
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`it, these are two other ways I could think that it may
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`be varied.
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` Q Start with the last example you just gave.
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`You said one could choose to increase the percentage
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`over the range of engine speeds. Can you please
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`elaborate how that would look?
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` A Just on the graph?
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` Q Sure.
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` A It would be just a straight line but a
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`sloped line.
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` Q So it's your opinion that with respect to a
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`Page 20
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`would always be a fixed value or if you could vary it
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`Page 18
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`within a particular control. So I guess there's
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`not -- it's not specific on that issue.
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` Q So you can't answer whether or not the
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`setpoint you've illustrated in paragraph 126 could
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`vary as a function of vehicle speed?
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` MR. LIVEDALEN: Same objections.
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`Mischaracterizes previous testimony.
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` A Yeah. I can't -- I can't say for sure.
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` Q What about varying the setpoint you have
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`illustrated in paragraph 126 as a function of engine
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`speed?
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`varying setpoint it would be a slope line?
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` MR. LIVEDALEN: Objection. Vague.
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`Mischaracterizes previous testimony.
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` A I was speaking in the way that a person
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`skilled in the art might vary it. So that was just
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`giving you examples of how somebody might choose to
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`vary it.
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` Q Would a person of ordinary skill in the art
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`understand that it wouldn't have to be a sloped line?
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` A I think that's possible also, yes.
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` Q So would a person of ordinary skill in the
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`art understand that it could be a parabolic line?
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` MR. LIVEDALEN: Same objections.
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` MR. LIVEDALEN: Objection. Vague. Calls
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`for a legal conclusion.
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` A Yeah. I think that that's possible, but I
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`can't really say one way or the other if it's, you
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`know, required in the claim or not.
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` Q Well, could you look at claim 5 of '347?
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` A Okay. Well, there it is. Thank you.
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` Q No problem.
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` A Yes. So it may be varied by the control as
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`a function of engine speed.
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` Q So how would the setpoints you have
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`illustrated in paragraph 126 vary as a function of
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`engine speed?
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` A I think what someone of skill in the art
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`would do when applying this patent when they're
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`calibrating the vehicle they would vary the setpoint
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`to determine either for the optimal efficiency or
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`possibly good drivability and see how those different
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`setpoints might affect the vehicle and then make
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`decisions based on what those might be.
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` Q So a person of ordinary skill in the art
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`performing those calibrations determined that a
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`parabolic line gave them the best efficiency, would
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`that meet the scope of the claims?
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` MR. LIVEDALEN: Same objections.
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`
`
`Pages 17 to 20Pages 17 to 20
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`FORD 1460
`
`

`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 30, 2015April 30, 2015
`
`Page 21
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`Page 23
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` A You know, if they, if they decided that's
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`the character they wanted and I guess it would have to
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`comply with the rest of the, the claims. If it were
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`less than 30 percent, and then it's a little vague, at
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`least approximately 30 percent. If it's 29 percent,
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`still approximately 30 percent, some people might say
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`yes. So, so unless it was outside of that range I
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`would say it would still comply with the claims.
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` Q Do all the claims require that the setpoint
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`be 30 percent or approximately 30 percent?
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` A No.
`
` Q Looking back at -- so let's look back at
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` Q The x-axis is engine speed?
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` A Yes.
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` Q So in the area shaded red those are engine
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`torques at a specific engine speed; is that correct?
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` A Yes.
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` Q And looking at the graph in paragraph 126
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`likewise the area shaded red are engine torques and
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`certain engine speeds; is that correct?
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` A Yeah. The whole graph's torque versus
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`speed.
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` Q So with respect to the graph shown in 126,
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`is that an illustration of control strategy that
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`paragraph 124. You have another graph illustrated
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`there; correct?
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` A Yes.
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` Q Again, what does the y-axis represent in
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`this graph?
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` A Well, y-axis is torque.
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` Q Engine torque?
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` A Yes.
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` Q What does the x-axis represent?
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` A Engine speed.
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` Q And again you have an area shaded in red and
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`an area shaded in green. What does the area shaded in
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`green represent?
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`compares a road load to a set point?
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` MR. LIVEDALEN: Objection. Vague. Calls
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`for legal conclusion.
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` A It's a graph that compares the Tabata
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`setpoint -- or excuse me -- Tabata strategy to the
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`patent strategy, and they're drawn in the same graphs
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`to demonstrate the differences.
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` Q I realize that. We're -- I'm talking
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`specifically about 126. Let's put 124 back to the
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`side. I'm sorry. Put 124 to the side. I just want
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`to focus on 126, and I just want to know, you said
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`that this is the claim control strategy of the '347
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`earlier; is that correct?
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`Page 24
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` A It is an area where, you know, operating the
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`engine above a certain power level is that becomes in
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`the area where the engine would operate.
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` Q That's the area where the engine operates to
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`propel the vehicle?
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` A Yes.
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` Q And what does the area shaded in red
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`represent?
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` A That's where the engine is not in operation
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`or not in normal operation to propel the vehicle.
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` Q What is the black dotted line you have
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`labeled as 20 kilowatts on the graph in 124?
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` MR. LIVEDALEN: Objection. Vague.
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`Mischaracterizes previous testimony.
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` A Yeah. It's one example.
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` Q Example. So is this an example of control
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`strategy where road load's compared to a setpoint?
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` MR. LIVEDALEN: Objection. Vague. Calls
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`for legal conclusion.
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` A In this example, yes, there is a comparison
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`of road load to a torque setpoint.
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` Q And is the road load the engine torque?
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` MR. LIVEDALEN: Objection. Vague. Calls
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`for legal conclusion.
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` A No. The road load is the Ford construction
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` A That's a line of constant power.
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` Q And what is that used to represent?
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` A That's used to represent the Tabata
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`strategy.
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` Q Does this figure illustrate a control
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`strategy that compares road load to a setpoint?
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` MR. LIVEDALEN: Objection. Vague. Calls
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`for a legal conclusion.
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` A This compares, is comparing engine power to
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`a power setpoint.
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` Q But the y-axis is labeled engine torque; is
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`that correct?
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` A Yes.
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`instantaneous torque required to propel the vehicle.
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` Q So with respect to paragraph 124 in the red
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`shaded area why do you say that that is power and then
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`for paragraph 126 you say that's torque?
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` A Well, the point I'm illustrating here is if
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`power is used as the setpoint that, for example, if
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`you're at a certain speed where the engine speed would
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`be 3,000 RPM, you would be, you would be at 60 Newton
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`meters to propel the vehicle, and that would all come
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`from the electric motor; whereas in the strategy
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`outlined, example outlined in 126, the same example,
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`the engine would have been operated. So each of these
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`
`
`Pages 21 to 24Pages 21 to 24
`
`FORD 1460
`
`

`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 30, 2015April 30, 2015
`
`Page 25
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`Page 27
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`strategies has a different, at a different point will
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`operate the engine.
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` Q So with respect to paragraph 126, at 2,000
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`RPMs the setpoint is 35 Newton meters; is that
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`correct?
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` A Yes.
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` Q And that 35 Newton meters represents an
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`engine setpoint of 35 Newton meters; is that correct?
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` A Well, that's their load at 35 Newton meters.
`
` Q Now, with respect to paragraph 124 and
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`engine speed of say 5,017, doesn't that correlate to
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`an engine torque of 114 Newton meters?
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`where you need over 80 meters of torque from the
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`electric motor, whereas in the patent strategy 35
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`Newton meters would be the maximum you require. So
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`each of these strategies would lead you to a different
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`size electric motor. So it would affect the design of
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`the vehicle.
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` Q Would a person of skill in the art ever
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`consider a power threshold to be a torque setpoint?
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` MR. LIVEDALEN: Objection. Vague. Calls
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`for a legal conclusion.
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` A No.
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` Q At a value of 60 with respect to paragraph
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` A Yes, it does.
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` Q And the torque levels above that 114 Newton
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`meters the engine is operating; is that correct?
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` MR. LIVEDALEN: Objection. Vague.
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` A Yeah. I mean if the engine's creating
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`torque output, then it's operating.
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` Q So again at 5,017 RPM you have a torque
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`value of 114 Newton meters; is that correct?
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` A That's the -- yeah, according to the graph
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`of the Caraceni engine that's the maximum torque
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`output at wide open throttle at that RPM.
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` Q And that's a point along the dotted line you
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`have labeled as 20 kilowatts; is that correct?
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`124, at a torque value of 60 Newton meters and engine
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`speed of 2,000 RPM, would that be understood as the
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`torque required to propel the vehicle using the motor?
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` MR. LIVEDALEN: Objection. Vague.
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` A Yeah. That's an area where the motor alone
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`would be used.
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` Q Right. I realize that's the area where the
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`motor alone would be used, but would that be the
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`torque at a given engine speed where -- strike that.
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`Is the 60 Newton meters the torque that the engine
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`must provide to propel the vehicle?
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` MR. LIVEDALEN: Objection. Vague.
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` A Well, at some point the engine may provide
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` A I don't think -- you're saying the 20
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`kilowatt line intersects that point?
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` Q I'm sorry. Paragraph 123, is this the --
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`what does the chart in paragraph 123 represent?
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` A That represents the maximum torque output of
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`the Caraceni engine.
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` Q Okay. So that's the blue line in paragraph
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`124?
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` A Yes.
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` Q Okay. Would any point along the dotted line
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`you've labeled as 20 kilowatt represent a boundary
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`between where the motor is used to propel the vehicle
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`60 Newton meters and at some, some points it may be
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`the electric motor that's providing 60 Newton meters.
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` Q Okay. So at 60 Newton meters and engine
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`speed of 2,000 RPM who is, what power source is
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`producing the 60 Newton Meters which would propel the
`
`vehicle?
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` MR. LIVEDALEN: Objection. Vague.
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` A Using the Tabata strategy it would be the
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`electric motor and using the patent strategy would be
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`the engine.
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` Q Okay. So let's just stick with 124. So
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`with the graph shown in 124 at a torque level of 60
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`and where the engine is used to propel the vehicle?
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`Newton meters and an engine speed of 2,000 RPM, the
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` MR. LIVEDALEN: Objection. Vague.
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` A With the -- yes, with the Tabata strategy.
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` Q So with respect to the graph shown in 124,
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`is that the control strategy disclosed by the '347
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`patent?
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` A No, it's not.
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` Q In your opinion what's the difference
`
`between a torque setpoint and a power threshold?
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` A Well, torque and power are completely
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`different things, and it may be the -- when you look
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`at these two graphs, you can see that, for example, in
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`the Tabata strategy graph you may encounter situations
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`motor alone is providing or providing the torque
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`necessary to propel the vehicle; is that correct?
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` MR. LIVEDALEN: Same objections.
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` A Yes. At all, at all points less than the 20
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`kilowatt power, power threshold you'd be using the
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`19 motor.
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` Q Okay. And at 60 Newton meters and an engine
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`speed of 5,000 RPM the engine alone is being operated
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`to propel the vehicle; is that correct?
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` MR. LIVEDALEN: Same objection.
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` A No. I didn't -- this graph doesn't
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`encompass the entire strategy, so I can say the engine
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`
`
`Pages 25 to 28Pages 25 to 28
`
`FORD 1460
`
`

`
`
`NEIL HANNEMANNNEIL HANNEMANN
`
`April 30, 2015April 30, 2015
`
`Page 29
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`Page 31
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`would be operating, but I couldn't rule out whether
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`the motor would also be operating at that point.
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` Q Fair enough. But the engine would be
`
`operating at 60 Newton meters at an engine speed of
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`5,000 RPM to propel the vehicle; is that correct?
`
` MR. LIVEDALEN: Same objections.
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` A Yeah. Those two points give you a power
`
`greater than 20 kilowatts, so that would be, according
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`to Tabata that would be the strategy for operating the
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`engine.
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` Q Okay. All right. Why don't we turn to
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`paragraph 128. You have another graph here in
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`have a 20 kilowatt line here, and it starts up around
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`2,000 RPM at a hundred roughly Newton meters at
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`parabolic slope that goes down to 6500 RPM at a
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`roughly