UNITED STATES PATENT AND TRADEMARK OFFICE
`
` _________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________________
`
`Page 1
`
` FORD MOTOR COMPANY,
`
` Petitioner,
`
` -vs-
`
` PAICE, LLC & ABELL FOUNDATION, INC.,
`
` Patent Owner.
`
` _____________________
`
` U.S. Patent No. 7,237,634
`
` IPR Case Nos: IPR2015-790, IPR2015-791,
`
` IPR2015-784, IPR2015-787, IPR2015-794,
`
` IPR2015-795 and IPR2015-722
`
` ____________________
`
`
`
` Deposition of GREGORY DAVIS, PhD
` Friday, May 13, 2016
` Southfield, Michigan
` 9:35 a.m.
`
`
`
`
`
`
`Reported by:
`Laura J. Steenbergh, CSR-3707, RPR, CRR, RMR
`Job no: 16341
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`PAICE 2314
`Ford v. Paice & Abell
`IPR2015-00795
`
`

`
`Page 2
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` APPEARANCES:
`
` MR. JOHN RONDINI, ESQ.
`
` MR. ANDREW B. TURNER, ESQ.
`
` Brooks Kushman, P.C.
`
` 1000 Town Center, 22nd Floor
`
` Southfield, Michigan 48075
`
` (248) 358-4400
`
` jrondini@brookskushman.com
`
` aturner@brookskushman.com
`
` Appearing on behalf of the Petitioner.
`
` MR. BRIAN LIVEDALEN, ESQ.
`
` Fish & Richardson, P.C.
`
` 1425 K Street NW, 11th Floor
`
` Washington, DC 20005
`
` (202) 783-5050
`
` livedalen@fr.com
`
` Appearing on behalf of the Patent Owner.
`
` * * * *
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` TABLE OF CONTENTS
`
`Page 3
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`Witness Page
`
`GREGORY DAVIS, PhD
`
`EXAMINATION BY MR. LIVEDALEN: 4
`
`EXAMINATION BY MR. RONDINI: 103
`
` INDEX TO EXHIBITS
`
` (Exhibits attached to transcript)
`
`Exhibit Page
`
` DAVIS EXHIBIT 1 G. Davis Reply to IPR 2014-00790 5
`
` DAVIS EXHIBIT 2 SAE Technical Paper 10
`
` DAVIS EXHIBIT 3 Hannemann Declaration 18
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` DAVIS EXHIBIT 4 Suga Reference 22
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` DAVIS EXHIBIT 5 Reply Declaration of G. Davis 36
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` DAVIS EXHIBIT 6 '882 Ibaraki Patent 42
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` DAVIS EXHIBIT 7 Declaration of Neil Hannemann 72
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` DAVIS EXHIBIT 8 SAE SP 1331 102
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`Page 4
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` Southfield, Michigan
`
` Friday, May 13, 2016
`
` About 9:35 a.m. 09:35:39AM
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` MR. LIVEDALEN: Good morning, Dr. Davis. 09:35:39AM
`
` THE WITNESS: Good morning. 09:39:21AM
`
` GREGORY DAVIS, PhD, 09:39:21AM
`
` having first been duly sworn, was examined and testified 09:39:21AM
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` on his oath as follows: 09:39:21AM
`
`EXAMINATION BY MR. LIVEDALEN: 09:39:21AM
`
`Q. Would you mind stating your full name for the record? 09:39:23AM
`
`A. Sure. Dr. Gregory W. Davis. 09:39:25AM
`
`Q. And you understand that you've taken an oath today? 09:39:28AM
`
`A. Yes, I do. 09:39:31AM
`
`Q. And it's the same as if you were testifying in court? 09:39:32AM
`
`A. Yes. 09:39:35AM
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`Q. And I think you're familiar by now with the general 09:39:35AM
`
` procedures of the deposition, but I'll repeat some of 09:39:42AM
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` the rules. 09:39:45AM
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`A. Okay. 09:39:45AM
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`Q. If you don't understand a question, please ask for 09:39:45AM
`
` clarification. If you can't hear a question or anything 09:39:48AM
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` like that, just please let me know. Please answer in 09:39:53AM
`
` audible responses, yeses and nos. No head nods or head 09:39:57AM
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` shakes. And if you want a break, just let me know. 09:40:03AM
`
` Any questions on your end? 09:40:06AM
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`Page 5
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`A. No. 09:40:09AM
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`Q. All right. 09:40:10AM
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`A. I think I'm ready. 09:40:10AM
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`Q. Let's get going then. 09:40:12AM
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` MR. LIVEDALEN: So I'm going to hand the 09:40:19AM
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` witness what we'll mark as Exhibit Number 1. 09:40:21AM
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` DAVIS EXHIBIT 1 09:40:39AM
`
` G. Davis Reply to IPR 2014-00790 09:40:39AM
`
` WAS MARKED BY THE REPORTER 09:40:39AM
`
` FOR IDENTIFICATION 09:40:39AM
`
`BY MR. LIVEDALEN: 09:40:39AM
`
`Q. Do you recognize Exhibit Number 1? 09:40:43AM
`
`A. Yes. 09:40:46AM
`
`Q. And what is it? 09:40:59AM
`
`A. It's my reply to IPR 2014-00790. 09:41:00AM
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`Q. And if you turn to page two of Exhibit 1, you'll see a 09:41:08AM
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` table of contents. Do you see that? 09:41:24AM
`
`A. Yes, I do. 09:41:25AM
`
`Q. And do you see Roman Numeral I, it talks about Ibaraki 09:41:26AM
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` '882? 09:41:34AM
`
`A. Yes. 09:41:34AM
`
`Q. And that's what you refer to -- or strike that. 09:41:34AM
`
` So we refer to Ibaraki '882 as U.S. Patent 09:41:40AM
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` Number 5,789,882, is that right? 09:41:46AM
`
`A. Yes. 09:41:50AM
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`Page 6
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`Q. And so for today's deposition we can call that the 09:41:55AM
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` Ibaraki '882 reference? 09:42:00AM
`
`A. Sounds good. 09:42:02AM
`
`Q. Okay. So, Dr. Davis, why did you submit a reply 09:42:02AM
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` declaration in IPR 2014-790? 09:42:16AM
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`A. I was asked to. 09:42:19AM
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`Q. And in preparing your reply declaration, did you review 09:42:20AM
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` the declarations submitted by Mr. Hannemann in this 09:42:28AM
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` matter? 09:42:32AM
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`A. Yes, at least portions. I didn't look in detail at all 09:42:32AM
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` sections, but yes. 09:42:35AM
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`Q. So you didn't read the entire declaration? 09:42:37AM
`
`A. Well, I believe I read through the entire declaration, 09:42:45AM
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` but I was only asked to focus on specific areas, so 09:42:48AM
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` those were the areas that I actually really looked at 09:42:52AM
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` closely. 09:42:57AM
`
`Q. Okay. Let's go to page 30 of Exhibit 1. And can you 09:42:58AM
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` read the heading for me, heading number VI? 09:43:43AM
`
`A. Sure. Ground 6: Claims 67 and 79 are obvious over 09:43:46AM
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` Ibaraki -- the one little kind of comma raised there -- 09:43:55AM
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` '882 in view of Suga -- S-U-G-A. 09:44:05AM
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`Q. And Suga is short for U.S. Patent Number 5,623,104, is 09:44:10AM
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` that right? 09:44:16AM
`
`A. U.S. Patent 5,623,104. I believe that's what it said. 09:44:16AM
`
`Q. Can you read paragraph 59 from your declaration into the 09:44:28AM
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`Page 7
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` record? 09:44:44AM
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`A. An -- it's A-N -- 1998 further explains that HEVs have 09:44:44AM
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` various operational strategies, including: 09:44:57AM
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` Charge-sustaining, charge-depleting, and zero emission 09:45:03AM
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` vehicle (ZEV) capability. (Exhibit 1688, An 1998 at 8.) 09:45:09AM
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` An also discloses that the sizing of the electric motor 09:45:22AM
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` determines whether or not the HEV is capable of ZEV 09:45:26AM
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` operation. 09:45:29AM
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`Q. And so An is a reference that you're citing from 1998, 09:45:30AM
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` is that right? 09:45:39AM
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`A. I believe so. 09:45:40AM
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`Q. And as it states here, An discloses that the sizing of 09:45:41AM
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` the electric motor determines whether or not the HEV is 09:45:48AM
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` capable of ZEV operation, is that your opinion? 09:45:51AM
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` MR. RONDINI: Objection, form. 09:45:55AM
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` THE WITNESS: I said An also discloses that 09:45:55AM
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` the sizing of the electric motor determines whether or 09:45:58AM
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` not HEV is capable of ZEV operation. 09:46:01AM
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`BY MR. LIVEDALEN: 09:46:04AM
`
`Q. But An does not state that ZEV operation has anything to 09:46:04AM
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` do with whether or not the electric motor is 09:46:11AM
`
` sufficiently powerful to provide acceleration of a 09:46:14AM
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` hybrid sufficient -- of a hybrid sufficient to conform 09:46:17AM
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` to the Federal Urban Cycle Driving Fuel Mileage Test, 09:46:20AM
`
` right? 09:46:25AM
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`Page 8
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` MR. RONDINI: Objection to form, vague. 09:46:25AM
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` THE WITNESS: I don't know. I'd have to look 09:46:26AM
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` at a copy of An. There's an awful lot of stuff here. 09:46:28AM
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`BY MR. LIVEDALEN: 09:46:32AM
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`Q. But you don't cite any evidence in your declaration to 09:46:32AM
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` that point, right? 09:46:34AM
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` MR. RONDINI: Objection, mischaracterizes his 09:46:35AM
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` testimony. 09:46:36AM
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` THE WITNESS: Basically I said An also 09:46:37AM
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` discloses that the sizing of the electric motor 09:46:38AM
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` determines whether or not the HEV is capable of ZEV 09:46:42AM
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` operation. 09:46:46AM
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`BY MR. LIVEDALEN: 09:46:46AM
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`Q. But you didn't provide any evidence or opinions 09:46:47AM
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` connecting the ZEV operation to whether or not the motor 09:46:49AM
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` would be sufficiently powerful to provide acceleration 09:46:53AM
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` to conform to the Federal Urban Cycle Driving Fuel 09:46:54AM
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` Mileage Test, right? 09:46:56AM
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` MR. RONDINI: Objection, mischaracterizes 09:46:57AM
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` testimony. 09:47:02AM
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` THE WITNESS: Again, I don't have the benefit 09:47:02AM
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` of having An in front of me here, so I can't go totally 09:47:05AM
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` from memory on this, but basically this is what I said. 09:47:08AM
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` An also discloses that the sizing of the electric motor 09:47:11AM
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` determines whether or not the HEV is capable of ZEV 09:47:14AM
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`Page 9
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` operation. 09:47:18AM
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`BY MR. LIVEDALEN: 09:47:18AM
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`Q. But you don't have any evidence or opinion in your 09:47:18AM
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` declaration here about connecting ZEV operation to 09:47:22AM
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` whether or not an electric motor in a hybrid vehicle is 09:47:25AM
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` sufficiently powerful to provide acceleration to conform 09:47:28AM
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` to the Federal Urban Cycle Driving Fuel Mileage Test, 09:47:31AM
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` right? 09:47:36AM
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` MR. RONDINI: Objection, mischaracterizes 09:47:36AM
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` testimony. 09:47:37AM
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` THE WITNESS: Again, what I said is, An also 09:47:38AM
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` discloses that the sizing of the electric motor 09:47:40AM
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` determines whether or not the HEV is capable of ZEV 09:47:43AM
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` operation. 09:47:47AM
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`BY MR. LIVEDALEN: 09:47:47AM
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`Q. Right. So I'm not asking about what you did say, I'm 09:47:48AM
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` asking about what you didn't say. So do you see an 09:47:51AM
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` opinion in your declaration that ties ZEV operation 09:47:55AM
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` capability to whether or not a motor in a hybrid vehicle 09:48:00AM
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` is sufficiently powerful to provide acceleration of the 09:48:05AM
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` hybrid vehicle sufficient to conform to the Federal 09:48:10AM
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` Urban Cycle Driving Fuel Mileage Test? 09:48:13AM
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` MR. RONDINI: Same objection. 09:48:16AM
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` THE WITNESS: Well, again, this is what I've 09:48:17AM
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` said here about An. And as I go on to say, you know, 09:48:19AM
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`Page 10
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` that -- and actually if we go back a little bit, you 09:48:24AM
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` have to remember, ZEV mode of operation is a mode of 09:48:27AM
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` operation that was widely understood by people. And in 09:48:34AM
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` order to be able to provide a vehicle with ZEV mode of 09:48:38AM
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` operation it has to meet, without the assistance of the 09:48:43AM
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` engine, it has to meet the acceleration demands, the 09:48:46AM
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` drivability demands placed on the vehicle. 09:48:51AM
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` MR. LIVEDALEN: All right. Let's mark the An 09:49:00AM
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` reference as Exhibit 2. 09:49:02AM
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` DAVIS EXHIBIT 2 09:49:18AM
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` SAE Technical Paper 09:49:18AM
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` WAS MARKED BY THE REPORTER 09:49:18AM
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` FOR IDENTIFICATION 09:49:19AM
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`BY MR. LIVEDALEN: 09:49:19AM
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`Q. All right. So can you identify Exhibit 2 for me? 09:49:29AM
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`A. Yes. It's the SAE technical paper from 1998, 981902, 09:49:33AM
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` and it's entitled, Critical Issues in Quantifying Hybrid 09:49:41AM
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` Electric Vehicle Emissions and Fuel Consumption. 09:49:45AM
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`Q. All right. Let's go to page eight. And this is the 09:49:48AM
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` page you cite in paragraph 59, right? 09:50:07AM
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`A. Yes, that is the page. 09:50:48AM
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`Q. Okay. So now that you have the An reference in front of 09:50:49AM
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` you, my question is, where in An does he tie ZEV 09:50:52AM
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` operation to whether or not the electric motor of a 09:51:02AM
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` hybrid is sufficiently powerful to provide acceleration 09:51:04AM
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`Page 11
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` of the hybrid vehicle sufficient to conform to the 09:51:07AM
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` Federal Urban Cycle Driving Fuel Mileage Test? 09:51:11AM
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`A. Well, at the beginning of the paper, actually in the 09:51:14AM
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` introduction, they talk about an electric vehicle, and 09:51:21AM
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` in -- this is the right-hand column on page one -- and 09:51:27AM
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` they talk about the five driving cycles applied to the 09:51:33AM
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` simulation models include: 1) EPA's Highway Cycle 09:51:37AM
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` (HWY); 2) EPA's City Cycle (LA4); 3) California Air 09:51:44AM
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` Resources Board (CARB) Unified LA 92 Cycle; 4) the New 09:51:54AM
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` York City Cycle (NYC); and 5) the US06 Cycle (US06). 09:52:02AM
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` And so they're talking about the LA4 cycle, 09:52:13AM
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` the EPA City Cycle, which is commonly known as the FUDDS 09:52:17AM
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` test -- all caps F-U-D-S or often now F-U-D-D-S. 09:52:29AM
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`Q. And so where in the An reference does it say that the 09:52:33AM
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` motor of a hybrid vehicle needs to be sufficiently 09:52:36AM
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` powerful to provide sufficient acceleration to meet the 09:52:39AM
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` FUDDS test? 09:52:43AM
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`A. Well, again, one of ordinary skill in the art would 09:52:44AM
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` understand when they're looking at page 8 of 21, ZEV 09:52:47AM
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` Operation Capability, if an HEV is capable of operating 09:52:52AM
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` entirely in electric mode only, i.e., the APU is not 09:52:56AM
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` used, then it is referred to as ZEV operation capable. 09:53:01AM
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` On the other hand, the electric motor may be 09:53:06AM
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` sized too small for practical driving speeds to allow 09:53:09AM
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` for ZEV operation. In this case the HEV is ZEV 09:53:12AM
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`Page 12
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` operation incapable. 09:53:19AM
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` And so what he's talking about there is the 09:53:20AM
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` ZEV mode of operation that most people were interested 09:53:22AM
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` in trying to use is the city mode of operation. For 09:53:26AM
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` example, many cities in Europe were at the time 09:53:32AM
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` considering banning the use of IC engines in city 09:53:37AM
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` centers. I believe that California, the CARB, was also 09:53:41AM
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` considering some similar proposals in the LA area. So 09:53:49AM
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` in order to provide ZEV operation only you would have to 09:53:58AM
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` meet the driving demands required in the city. And, of 09:54:01AM
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` course, the standard test for city driving is the FUDDS 09:54:04AM
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` test. 09:54:11AM
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`Q. All right. So let's focus on the bullet point on the 09:54:11AM
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` bottom right-hand corner you've been talking about 09:54:14AM
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` labeled ZEV Operation Capability. Where in that 09:54:16AM
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` paragraph does it talk about acceleration? 09:54:19AM
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`A. Well, again, one of ordinary skill in the art would 09:54:24AM
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` understand that it says, On the other hand, the electric 09:54:27AM
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` motor may be sized too small for practical driving 09:54:30AM
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` speeds to allow for ZEV operation. In this case the HEV 09:54:33AM
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` is ZEV-operation incapable. 09:54:39AM
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`Q. It says driving speeds, right, not acceleration? 09:54:42AM
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`A. Well, sometimes people speak a little bit loosely, but 09:54:45AM
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` everybody -- one of ordinary skill in the art would 09:54:48AM
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` understand that what we're talking about is being able 09:54:51AM
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`Page 13
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` to meet the drivability demands to drive in the city. 09:54:53AM
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`Q. But there's -- the word city's also not in this 09:54:56AM
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` paragraph, right? 09:55:00AM
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`A. Well, because one of ordinary skill in the art would 09:55:00AM
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` understand that ZEV mode is being discussed for city 09:55:03AM
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` driving. Not for highway driving, but for city driving. 09:55:07AM
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` And, again, the standard test for city driving is the 09:55:13AM
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` FUDDS test. 09:55:16AM
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`Q. All right. For my next question let's focus on what's 09:55:17AM
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` in the reference and not what you think someone of 09:55:21AM
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` ordinary skill in the art would read into the reference. 09:55:25AM
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`A. Well, it is in -- I mean, you know, you're taking one 09:55:28AM
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` small snippet out of context here, but, you know, when 09:55:31AM
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` you look at the entire reference, then you get a better 09:55:35AM
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` understanding. 09:55:38AM
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`Q. But you'd agree with me, right, that the word 09:55:38AM
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` acceleration is not in the bullet point paragraph 09:55:41AM
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` labeled ZEV Operation Capability? 09:55:43AM
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` MR. RONDINI: Objection, form, vague. 09:55:45AM
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` THE WITNESS: Actually the word acceleration 09:55:47AM
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` is in there. Oh, I'm sorry, I turned to the wrong page. 09:55:48AM
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` I was looking at the last paragraph in the two pages 09:55:53AM
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` before. 09:55:56AM
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` The word acceleration is not in that 09:56:04AM
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` paragraph. But again -- 09:56:05AM
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` MR. LIVEDALEN: That's my only question. 09:56:07AM
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` MR. RONDINI: Well, let the witness answer. 09:56:07AM
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` THE WITNESS: Again, you're trying to take a 09:56:09AM
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` snippet out of context and I don't think that's proper. 09:56:13AM
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` I mean, you have to understand that he's clearly talking 09:56:15AM
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` about ZEV operation capabilities meaning that the 09:56:17AM
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` vehicle's going to meet all the drivability requirements 09:56:25AM
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` using just the electric motor in the ZEV mode and that 09:56:28AM
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` the ZEV mode is the mode of operation that you would use 09:56:31AM
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` in city driving. 09:56:34AM
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`BY MR. LIVEDALEN: 09:56:36AM
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`Q. So you'd agree with me, right, that the word city 09:56:40AM
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` driving is also not in the paragraph bullet pointed ZEV 09:56:42AM
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` Operation Capability? 09:56:45AM
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` MR. RONDINI: Objection, form. 09:56:48AM
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` THE WITNESS: Again, you're taking that out of 09:56:49AM
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` context. I mean, one of ordinary skill in the art when 09:56:51AM
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` reading this SAE paper would understand the moment you 09:56:53AM
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` mention ZEV operation that you're gauging this for city 09:56:58AM
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` operation. Because that was at the time and still is a 09:57:03AM
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` discussion about zones of operation in city centers that 09:57:08AM
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` will be IC engine -- will not allow IC engine operation. 09:57:13AM
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` And so one of ordinary skill in the art would fully 09:57:18AM
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` understand that. 09:57:22AM
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` MR. LIVEDALEN: Going forward, to be clear, if 09:57:27AM
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`Page 15
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` I ask you about what's in a particular part of the 09:57:30AM
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` reference, that was my question. If I ask you about 09:57:32AM
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` what one of skill in the art would understand from that, 09:57:35AM
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` then that's a separate question. 09:57:40AM
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`BY MR. LIVEDALEN: 09:57:41AM
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`Q. So you'd agree with me, right, that ZEV operation 09:57:41AM
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` capability -- or, strike that. 09:57:44AM
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` You'd agree with me that the paragraph that 09:57:47AM
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` says ZEV operation capability does not state anything 09:57:48AM
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` about the FUDDS test, right? 09:57:52AM
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` MR. RONDINI: Objection, form. 09:57:54AM
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` THE WITNESS: I would agree that it is not 09:57:55AM
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` explicitly in that paragraph, but, again, as I've stated 09:57:59AM
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` a few times now, one of ordinary skill in the art would 09:58:02AM
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` understand that that would be the discussion that is at 09:58:05AM
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` hand there. 09:58:08AM
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`BY MR. LIVEDALEN: 09:58:09AM
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`Q. Okay. And you'd also agree with me that, on this 09:58:14AM
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` discussion of ZEV operation capability, it does not say 09:58:19AM
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` anything about the relative sizing of the electric motor 09:58:24AM
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` as compared to the size of the engine, right? 09:58:27AM
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` MR. RONDINI: Objection to form. 09:58:29AM
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` THE WITNESS: Well, actually it is talking 09:58:30AM
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` about electric motor sizing. And, of course, if you did 09:58:40AM
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` nothing to the engine and changed the size of the 09:58:47AM
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`Page 16
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` electric motor, then you are changing that relationship. 09:58:51AM
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`BY MR. LIVEDALEN: 09:58:54AM
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`Q. But there's nowhere in An that tells you to size your 09:58:55AM
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` motor relative to the size of the engine, right? 09:58:59AM
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`A. Well, as I just said, that if you are changing the size 09:59:05AM
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` of your electric motor, and even if you did nothing to 09:59:09AM
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` the engine, you are changing the relative size, the 09:59:12AM
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` relative power distribution, torque distribution. 09:59:15AM
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`Q. But An does not say to use the engine size as a 09:59:20AM
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` benchmark to size your motor, right? 09:59:27AM
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` MR. RONDINI: Objection, form. 09:59:28AM
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` THE WITNESS: Again, here An is focusing on 09:59:30AM
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` the ZEV operation here. And as I say, that if you're 09:59:39AM
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` changing the size of the electric motor, even if you did 09:59:44AM
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` nothing to the size of the engine, you are changing the 09:59:47AM
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` relationship. 09:59:49AM
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`BY MR. LIVEDALEN: 09:59:50AM
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`Q. I'm not asking about the relationship, I'm asking about 09:59:51AM
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` whether or not An uses the engine as a benchmark to size 09:59:54AM
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` the motor. 09:59:59AM
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`A. Well, of course, An is going to look at all of the 10:00:06AM
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` relationships. You know, for example, if I increase the 10:00:11AM
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` size of my electric motor in order to meet the FUDDS 10:00:17AM
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` test for ZEV capability, that would often require a 10:00:20AM
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` potential increase in size of the battery pack as well, 10:00:30AM
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`Page 17
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` and you have to remember in hybrid electric vehicles 10:00:35AM
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` we're very weight conscious and we're very conscious 10:00:38AM
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` about the fact that one of the benefits of the hybrid is 10:00:42AM
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` that if it's a parallel or a serious parallel hybrid 10:00:45AM
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` vehicle, that we're able to use the power and torque 10:00:50AM
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` availability of both the electric motor and the engine 10:00:53AM
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` to propel the vehicle. So if I'm making an electric 10:00:58AM
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` motor larger, then I have the option to make the engine 10:01:01AM
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` smaller in relation to that. And often I would have the 10:01:05AM
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` motivation to do that because I'm trying to reduce or 10:01:09AM
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` maintain a weight limitation for the hybrid vehicle. 10:01:13AM
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` And also cost is an issue as well. 10:01:17AM
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`Q. But An doesn't tell you to pick your motor size 10:01:20AM
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` according to the size of the engine, right? 10:01:27AM
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` MR. RONDINI: Objection, asked and answered. 10:01:29AM
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` THE WITNESS: I think I have answered that, 10:01:30AM
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` and that you're looking at the relationship of the whole 10:01:35AM
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` vehicle as a system. And so, therefore, you are looking 10:01:38AM
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` at always the relationship between the size of the 10:01:42AM
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` electric motor and the size of the engine. 10:01:45AM
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` MR. LIVEDALEN: So I'm not asking you about 10:01:48AM
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` your opinion, I'm asking about what An says. 10:01:50AM
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`BY MR. LIVEDALEN: 10:01:50AM
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`Q. Does An say anywhere that he's sizing his motor based on 10:01:52AM
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` the size of the engine? 10:02:01AM
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`Page 18
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` MR. RONDINI: Objection, form. 10:02:02AM
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` THE WITNESS: Again, as I explained, one of 10:02:03AM
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` ordinary skill