Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 1 of 173 PageID 353
`
`EXHIBIT 3
`
`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(1 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 2 of 173 PageID 354
`
` UNITED STATES DISTRICT COURT
`
` FOR THE
`
` WESTERN DISTRICT OF TENNESSEE
`
`Buckman Laboratories, Inc., )
`
` Plaintiff, ) Civil Action No:
`
`vs. ) 1:15-cv-02063-JPM-TMP
`
`Solenis, LLC, et al., )
`
` Defendants. )
`
`______________________________
`
` Videotaped Deposition of VINCENT EDWARD COPA,
`
` as Chippewa Valley Ethanol Company representative
`
` and in his individual capacity, taken at
`
` 2870 Metro Drive, Bloomington, Minnesota,
`
` commencing at 9:10 a.m.,Wednesday, September 9,
`
` 2015, before ANDREA J. TUNGLAND HEAIRET, RMR,
`
` CRR, CLR, Notary Public.
`
`JOB No. 2119671
`
`PAGES 1 - 173
`
`PAGES 27-34; 37-46 ARE ATTORNEYS' EYES ONLY
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`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(2 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 3 of 173 PageID 355
`
` A P P E A R A N C E S :
`
`O n B e h a l f o f t h e P l a i n t i f f :
`
` B Y : J E S S E J . C A M A C H O , E S Q .
`
` M A R Y J . P E A L , E S Q .
`
` S H O O K , H A R D Y & B A C O N , L L P
`
` 2 5 5 5 G r a n d B o u l e v a r d
`
` K a n s a s C i t y , M i s s o u r i 6 4 1 0 8 - 2 6 1 3
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` ( 8 1 6 ) 4 7 4 - 6 5 5 0
`
` j c a m a c h o @ s h b . c o m
`
` m p e a l @ s h b . c o m
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` a n d
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` B Y : M I C H A E L R A F F E R T Y , E S Q .
`
` ( A p p e a r e d t e l e p h o n i c a l l y )
`
` H A R R I S S H E L T O N H A N O V E R W A L S H , P L L C
`
` O n e C o m m e r c e S q u a r e , S u i t e 2 7 0 0
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` M e m p h i s , T e n n e s s e e 3 8 1 0 3 - 2 5 5 5
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`
`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(3 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 4 of 173 PageID 356
`
`A P P E A R A N C E S c o n t i n u e d :
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`O n B e h a l f o f D e f e n d a n t S o l e n i s , L L C :
`
` B Y : R O D G E R D . S M I T H I I , E S Q .
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` M O R R I S , N I C H O L S , A R S H T & T U N N E L L , L L P
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` 1 2 0 1 N o r t h M a r k e t S t r e e t
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` W i l m i n g t o n , D e l a w a r e 1 9 8 9 9 - 1 3 4 7
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` ( 3 0 2 ) 3 5 1 - 9 2 0 5
`
` r s m i t h @ m n a t . c o m
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`O n B e h a l f o f t h e W i t n e s s a n d C V E C :
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` B Y : J . D O N A L D B E S T , E S Q .
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` M I C H A E L B E S T & F R I E D R I C H , L L P
`
` O n e S o u t h P i n c k n e y S t r e e t
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` S u i t e 7 0 0
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` j d b e s t @ m i c h a e l b e s t . c o m
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`A l s o P r e s e n t :
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` C h a r s B o n i n , V i d e o g r a p h e r
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`
`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(4 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 5 of 173 PageID 357
`
` I N D E X
`
`VINCENT EDWARD COPA: Page:
`
`EXAMINATION BY MR. CAMACHO .......................... 9
`
`EXAMINATION BY MR. SMITH ............................ 97
`
`EXAMINATION BY MR. CAMACHO .......................... 140
`
`EXAMINATION BY MR. SMITH ............................ 162
`
`EXAMINATION BY MR. CAMACHO .......................... 165
`
`EXAMINATION BY MR. SMITH ............................ 170
`
`EXAMINATION BY MR. CAMACHO .......................... 171
`
`REPORTER'S CERTIFICATE .............................. 175
`
`ATTORNEYS' EYES ONLY SECTIONS: 27-34; 37-46
`
`COPA EXHIBITS MARKED:
`
`EXHIBIT 1: CVEC Subpoena ......................... 9
`
`EXHIBIT 2: Copa Subpoena ......................... 9
`
`EXHIBIT 3: 8-7-12 Copa transcript ................ 11
`
`EXHIBIT 4: '858 CVEC Supplemental Responses
`
` [Bates Chippewa 000024-31] ............ 12
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`
`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(5 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 6 of 173 PageID 358
`
`COPA EXHIBITS MARKED (Continued):
`
`EXHIBIT 5: 1-24-08 email chain
`
` Subject: Static Spin Test Results on
`
` CVEC Stillage Corn Syrup
`
` [Bates CVEC 002149-52] ................ 17
`
`EXHIBIT 6: Diagram
`
` [Bates CVEC 000217-232] ............... 23
`
`EXHIBIT 7: Hawkins invoices
`
` [Bates Chippewa 000032-47] ............ 24
`
`EXHIBIT 8: 2007 to 2008 Operation Statistics
`
` [Bates Chippewa 005846-48] ............ 26
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`EXHIBIT 9: 2008 to 2009 Operation Statistics
`
` [Bates Chippewa 005849-51] ............ 29
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`EXHIBIT 10: 10-09 to 9-10 production spreadsheet
`
` [Bates Chippewa 000001] ............... 33
`
`EXHIBIT 11: 10-08 to 9-09 Inventory Sales Report
`
` [Bates Chippewa 000525-527] ........... 36
`
`EXHIBIT 12: 10-07 to 9-08 Inventory Sales Report
`
` [Bates CVEC 000477-480] ............... 38
`
`EXHIBIT 13: US Patent 8,841,469 ................... 38
`
`EXHIBIT 14: 12-10-08 email chain
`
` Subject: Corn Oil
`
` [Bates Chippewa 000010-23] ............ 46
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`Page 5
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`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(6 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 7 of 173 PageID 359
`
`COPA EXHIBITS MARKED (Continued):
`
`EXHIBIT 15: 6-12-09 Crude Corn Oil Separation at
`
` CVEC slides
`
` [Bates Chippewa 00002-9] .............. 49
`
`EXHIBIT 16: 4-27-09 email chain
`
` Subject: De-emulsifier
`
` [Bates Chippewa 006059-62] ............ 51
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`EXHIBIT 17: 8-24-09 email chain
`
` Subject: CVEC samples
`
` [Bates Chippewa 006243-44] ............ 54
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`EXHIBIT 18: 10-21-09 email from Janowiec
`
` [Bates Chippewa 006239] ............... 56
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`EXHIBIT 19: 1-26-10 email chain
`
` Subject: Thoughts
`
` [Bates Solenis 0000792-96] ............ 60
`
`EXHIBIT 20: 3-8-11 email chain, Subject: Corn Oil
`
` Trial Recommendations
`
` [Bates CVEC 005663-64] ................ 67
`
`EXHIBIT 21: 10-29-14 letter re: patent to CVEC
`
` [Bates Chippewa 006124] ............... 79
`
`EXHIBIT 22: 11-3-14 letter re: patent to Friese
`
` [Bates Chippewa 006237] ............... 79
`
`EXHIBIT 23: 10-21-14 email chain, Subject:
`
` Polysorbate [Bates Chippewa 006015] .. 80
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`Page 6
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`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(7 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 8 of 173 PageID 360
`
`COPA EXHIBITS MARKED (Continued):
`
`EXHIBIT 24: 8-7-15 email chain
`
` Subject: DPI-428 Bulk Tank
`
` [Bates Chippewa 006075-76] ............ 83
`
`EXHIBIT 25: 2-17-15 CVEC News Stories
`
` [Bates Superior 00146-147] ............ 105
`
`EXHIBIT 26: 5-11-09 Trial Evaluation
`
` [Bates Solenis 0000801-806] ........... 118
`
`EXHIBIT 27: Undated letter to Kent, Benson,
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` DeBoer from Storm and Tegels
`
` [Bates Chippewa 006149-51] ............ 135
`
`EXHIBIT 28: 6-17-15 Bench Testing of Corn Oil
`
` Extraction Additives
`
` [Bates Chippewa 006603-10] ............ 136
`
`EXHIBIT 29: 8-13-15 email chain
`
` Subject: corn oil additive email
`
` [Bates Chippewa 006601-02] ............ 137
`
`EXHIBIT 30: 3-11-09 email chain
`
` Subject: Tuesday, March 17, 2009
`
` [Bates Chippewa 006048] ............... 157
`
`EXHIBIT 31: 2-6-15 email chain
`
` Subject: Poly 80
`
` [Bates Chippewa 005971] ............... 160
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`Page 7
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`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(8 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 9 of 173 PageID 361
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` P R O C E E D I N G S
`
` THE VIDEOGRAPHER: We are now on the 09:09:47
`
`record. Please note that the microphones are sensitive 09:09:49
`
`and they may pick up whispering and private 09:09:52
`
`conversations. Please turn off all cell phones and place 09:09:55
`
`them away from the microphones as they can interfere with 09:09:57
`
`the deposition audio. Recording will continue until all 09:10:02
`
`parties agree to go off the record. 09:10:06
`
` My name is Charles Bonin, and I'm representing 09:10:08
`
`Veritext. Today's date is September 9, 2015. The time 09:10:11
`
`is approximately 9:10 a.m. This deposition is being held 09:10:17
`
`at Springhill Suites by Marriott in Bloomington, 09:10:26
`
`Minnesota. 09:10:30
`
` The caption of this case is Buckman 09:10:37
`
`Laboratories, Incorporated, versus Solenis LLC, et al., 09:10:41
`
`Case No. 1:15-CV-02063-JPM-TMP. The name of the witness 09:10:44
`
`today is Vincent Copa, who is also a representative of 09:11:01
`
`Chippewa Valley Ethanol Company. 09:11:10
`
` Would the attorneys present in the room and 09:11:11
`
`attending remotely please identify themselves and the 09:11:13
`
`parties they represent. 09:11:16
`
` MR. CAMACHO: Jesse Camacho of Shook, Hardy 09:11:18
`
`and Bacon for Buckman Laboratories. 09:11:21
`
` MS. PEAL: Mary Peal from Shook, Hardy and 09:11:25
`
`Bacon also for Buckman. 09:11:28
`
`Page 8
`
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`
`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(9 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 10 of 173 PageID 362
`
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` MR. SMITH: Rodger Smith from Morris 09:11:29
`
`Nichols Arsht & Tunnell on behalf of Solenis. 09:11:32
`
` MR. BEST: Don Best, Michael Best and 09:11:34
`
`Friedrich, on behalf of both CVEC and Mr. Copa. 09:11:37
`
` THE VIDEOGRAPHER: Attending on the phone? 09:11:45
`
` MR. RAFFERTY: This is Michael Rafferty 09:11:47
`
`with Harris Shelton Hanover Walsh in Memphis, 09:11:49
`
`representing plaintiff and counter-defendant Buckman 09:11:52
`
`Laboratories, Inc. 09:11:55
`
` THE VIDEOGRAPHER: Our court reporter today 09:11:58
`
`is Andrea Heairet representing Veritext. And, Andrea, 09:11:59
`
`will you please swear in our witness and we can proceed. 09:12:03
`
` VINCENT EDWARD COPA, 09:12:06
`
`duly sworn, was examined and testified as follows:
`
` EXAMINATION
`
`BY MR. CAMACHO: 09:12:18
`
` Q. Mr. Copa, I'm Jesse Camacho. And would you just 09:12:18
`
`introduce yourself to the people present? Give them your 09:12:24
`
`name and who you work for. 09:12:29
`
` A. Okay. Vincent Copa, process engineer at 09:12:30
`
`Chippewa Valley Ethanol Company. 09:12:34
`
` (Copa Exhibit 1 and Exhibit 2 marked for
`
`identification.) 09:12:36
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` Q. (By Mr. Camacho) I'm handing you what's been 09:12:36
`
`
` Q. (By Mr. Camacho) I'm handing you what's been 09:12:36 Q. (By Mr. Camacho) I'm handing you what's been 09:12:36 Q. (By Mr. Camacho) I'm handing you what's been 09:12:36
`
`marked as Copa Exhibit 1, which is a copy of the 09:12:38
`marked as Copa Exhibit 1, which is a copy of the 09:12:38
`
`Page 9
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`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(10 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 11 of 173 PageID 363
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`deposition notice in this case. Have you seen this 09:12:47deposition notice in this case. Have you seen this 09:12:47deposition notice in this case. Have you seen this 09:12:47
`
`document before? 09:12:50
`document before? 09:12:50
`
` A. Yes, I have. 09:12:51
`
` A. Yes, I have. 09:12:51 A. Yes, I have. 09:12:51
`
` Q. Do you understand that you're here today to 09:12:51
`
` Q. Do you understand that you're here today to 09:12:51 Q. Do you understand that you're here today to 09:12:51
`
`offer testimony on behalf of Chippewa? 09:12:55
`offer testimony on behalf of Chippewa? 09:12:55
`
` A. Yes, I do. 09:12:57
`
` A. Yes, I do. 09:12:57 A. Yes, I do. 09:12:57
`
` Q. And were you able to review the deposition 09:12:58
`
` Q. And were you able to review the deposition 09:12:58 Q. And were you able to review the deposition 09:12:58
`
`topics in Exhibit B? 09:13:02
`topics in Exhibit B? 09:13:02
`
` A. Yes, I was. 09:13:15
`
` A. Yes, I was. 09:13:15 A. Yes, I was. 09:13:15
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` Q. And are you prepared to offer testimony on those 09:13:15
`
` Q. And are you prepared to offer testimony on those 09:13:15 Q. And are you prepared to offer testimony on those 09:13:15
`
`deposition topics? 09:13:18
`deposition topics? 09:13:18
`
` A. Yes, I am. 09:13:18
`
` A. Yes, I am. 09:13:18 A. Yes, I am. 09:13:18
`
` Q. I am now going to hand you what I've marked as 09:13:19
`
`Copa Exhibit 2, which is a copy of your individual 09:13:23
`
`subpoena in this case. Have you seen this document? 09:13:31
`
` A. Yes, I have. 09:13:33
`
` Q. And then do you understand that today in order 09:13:34
`
`to save time we're also taking your deposition in your 09:13:37
`
`personal capacity? 09:13:44
`
` A. Yes, I am. 09:13:44
`
` Q. Now, I understand you've had your deposition 09:13:45
`
` Q. Now, I understand you've had your deposition 09:13:45 Q. Now, I understand you've had your deposition 09:13:45
`
`taken before. 09:13:47
`taken before. 09:13:47
`
` A. Yes, I have. 09:13:47
`
` A. Yes, I have. 09:13:47 A. Yes, I have. 09:13:47
`
` Q. And can you provide -- what was the context that 09:13:48
`
` Q. And can you provide -- what was the context that 09:13:48 Q. And can you provide -- what was the context that 09:13:48
`
`you had your deposition taken before? 09:13:51
`you had your deposition taken before? 09:13:51
`
`Page 10
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`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(11 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 12 of 173 PageID 364
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` A. Context was that I was a representative of 09:13:54 A. Context was that I was a representative of 09:13:54 A. Context was that I was a representative of 09:13:54
`
`Chippewa Valley Ethanol, who was a defendant in the 09:13:58
`Chippewa Valley Ethanol, who was a defendant in the 09:13:58
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`GreenShift corn oil patent dispute. I was deemed the 09:14:02
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`GreenShift corn oil patent dispute. I was deemed the 09:14:02GreenShift corn oil patent dispute. I was deemed the 09:14:02
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`person most knowledgeable of the process as it was 09:14:07
`person most knowledgeable of the process as it was 09:14:07
`
`incorporated at Chippewa Valley Ethanol. 09:14:12
`incorporated at Chippewa Valley Ethanol. 09:14:12
`
` (Copa Exhibit 3 marked for identification.) 09:14:16
` (Copa Exhibit 3 marked for identification.) 09:14:16
`
` Q. (By Mr. Camacho) And I'm handing you what is 09:14:16
`
`
` Q. (By Mr. Camacho) And I'm handing you what is 09:14:16 Q. (By Mr. Camacho) And I'm handing you what is 09:14:16 Q. (By Mr. Camacho) And I'm handing you what is 09:14:16
`
`marked as Copa 3, which is a copy of the transcript from 09:14:19
`marked as Copa 3, which is a copy of the transcript from 09:14:19
`
`your former deposition in that case. Have you had a 09:14:27
`
`your former deposition in that case. Have you had a 09:14:27your former deposition in that case. Have you had a 09:14:27
`
`chance to review this deposition while preparing for this 09:14:31
`chance to review this deposition while preparing for this 09:14:31
`
`deposition? 09:14:34
`deposition? 09:14:34
`
` A. Yes, I have. 09:14:35
`
` A. Yes, I have. 09:14:35 A. Yes, I have. 09:14:35
`
` Q. And is the information in this transcript 09:14:35
`
` Q. And is the information in this transcript 09:14:35 Q. And is the information in this transcript 09:14:35
`
`accurate? 09:14:39
`accurate? 09:14:39
`
` A. Yes, it is. 09:14:40
`
` A. Yes, it is. 09:14:40 A. Yes, it is. 09:14:40
`
` Q. This will also help us to save some time today. 09:14:41
`
`There's information in here that I'm happy to reuse, but 09:14:46
`
`is your address still 33779 State Highway 29 in Benson? 09:14:51
`
` A. No, it's not. 09:14:58
`
` Q. What is your current address? 09:14:59
`
` A. Post Office Box 85 in Benson. 09:15:00
`
` Q. And could you state your role -- what is your 09:15:03
`
` Q. And could you state your role -- what is your 09:15:03 Q. And could you state your role -- what is your 09:15:03
`
`current job title at Chippewa? 09:15:12
`current job title at Chippewa? 09:15:12
`
` A. I'm the process engineer. 09:15:14
`
` A. I'm the process engineer. 09:15:14 A. I'm the process engineer. 09:15:14
`
` Q. And then can you really quickly just summarize 09:15:16
`
` Q. And then can you really quickly just summarize 09:15:16 Q. And then can you really quickly just summarize 09:15:16
`
`Page 11
`
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`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(12 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 13 of 173 PageID 365
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`your education background and how you came to be a 09:15:19your education background and how you came to be a 09:15:19
`
`process engineer at Chippewa? 09:15:22
`process engineer at Chippewa? 09:15:22
`
` A. Okay. Originally got a degree, bachelor's 09:15:24
`
`
` A. Okay. Originally got a degree, bachelor's 09:15:24 A. Okay. Originally got a degree, bachelor's 09:15:24 A. Okay. Originally got a degree, bachelor's 09:15:24
`
`degree from the United States Air Force Academy, class of 09:15:28
`degree from the United States Air Force Academy, class of 09:15:28
`
`1989. Spent six years' active duty, resigned my 09:15:32
`
`1989. Spent six years' active duty, resigned my 09:15:321989. Spent six years' active duty, resigned my 09:15:32
`
`commission in '95, went back and got a chemical 09:15:36
`commission in '95, went back and got a chemical 09:15:36
`
`engineering degree from the University of Minnesota. 09:15:40
`engineering degree from the University of Minnesota. 09:15:40
`
` I've had several positions in industry, all of 09:15:43
`
`them biotechnology related. I've been at Chippewa Valley 09:15:48
`
`Ethanol just short of nine years now. And my role is 09:15:53
`
`really to discover and implement process efficiencies, 09:15:56
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`both in terms of energy, electrical and, you know, yield 09:16:01
`
`from feed products. 09:16:08
`
` Q. Did you start with Chippewa in 2006? 09:16:10
`
` A. Yes, I did. 09:16:12
`
` Q. And are you familiar with Chippewa's corn oil 09:16:13
`
`extraction process? 09:16:18
`
` A. Yes, I am. 09:16:20
`
` (Copa Exhibit 4 marked for identification.) 09:16:34
`
` Q. (By Mr. Camacho) I'm now going to hand you what 09:16:36
`
`is marked as Copa 4, which is a copy of an Interrogatory 09:16:48
`
`response provided by Chippewa in what I'll refer to as 09:16:57
`
`the Indiana litigation. Are you familiar with this 09:16:59
`
`document? 09:17:03
`
` A. Yes, I am. 09:17:04
`
`Page 12
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`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(13 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 14 of 173 PageID 366
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` Q. I'd like to direct your attention to page 4 near 09:17:10
`
`the bottom. And could you -- withdrawn. 09:17:15
`
` I direct your attention for your benefit, but my 09:17:21
`
`general question is could you describe in kind of summary 09:17:24
`
`fashion how Chippewa came to extract corn oil? But if 09:17:30
`
`you wanted a copy of this Interrogatory response at the 09:17:39
`
`ready, I wanted to provide it to you. 09:17:41
`
` A. Okay. 09:17:43
`
` MR. SMITH: Objection to form. 09:17:44
`
` Q. (By Mr. Camacho) He might object during the 09:17:46
`
`course of the deposition, but that's just so he can put a 09:17:48
`
`stakeholder in and we can discuss some formalities later. 09:17:51
`
`After he objects, unless your counsel instructs you not 09:17:56
`
`to answer, it's okay if you just go ahead. 09:17:59
`
` A. Okay. There had been some work done prior to 09:18:03
`
`the start of my employment. But when I started there was 09:18:06
`
`a pilot scale centrifuge on-site that I spent several 09:18:10
`
`months running batches of condensed distiller solubles or 09:18:19
`
`syrup through that machine, and measured the yield of 09:18:24
`
`corn oil at various feed rates, feed temperatures, 09:18:28
`
`settings on the machine itself. From that experimental 09:18:33
`
`data we were able to say there's an acceptable ROI on 09:18:38
`
`this project. 09:18:42
`
` So early in 2007, I think it was, we -- our 09:18:42
`
`board of directors approved a project to construct a corn 09:18:47
`
`Page 13
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`"
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`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(14 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 15 of 173 PageID 367
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`oil separation process, which in large part consisted of 09:18:54
`
`a disc stack centrifuge supplied by Westfalia, along with 09:18:57
`
`some ancillary equipment, you know, pumps, strainers, 09:19:03
`
`heaters. 09:19:10
`
` Q. So you obtained what -- was it a centrifuge from 09:19:11
`
`Westfalia? 09:19:13
`
` A. Yes. 09:19:14
`
` Q. And what was the purpose of the centrifuge? 09:19:14
`
` A. The centrifuge was used to take out the oil from 09:19:17
`
`the bulk liquid. The oil has a lower density, and the 09:19:23
`
`g-forces of the centrifuge would preferentially send the 09:19:27
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`oil outward or to the top, and the heavier remaining 09:19:31
`
`solids would remain with the bulk of the feed. 09:19:37
`
` Q. And for people who are not familiar with the 09:19:43
`
`corn oil extraction process or even ethanol process at 09:19:47
`
`all, could you provide just a high-level overview of 09:19:49
`
`what's happening, from the corn to ethanol to corn oil? 09:19:52
`
` MR. SMITH: Objection to form. 09:19:56
`
` THE WITNESS: Yes. Corn is ground into a 09:19:58
`
`
` THE WITNESS: Yes. Corn is ground into a 09:19:58 THE WITNESS: Yes. Corn is ground into a 09:19:58 THE WITNESS: Yes. Corn is ground into a 09:19:58
`
`flour and mixed with recycled water and a number of 09:20:02
`flour and mixed with recycled water and a number of 09:20:02
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`different enzymes that break down the starches in the 09:20:06
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`corn into fermentable sugars. 09:20:09
`
` After a certain amount of time, that liquid is 09:20:13
` After a certain amount of time, that liquid is 09:20:13
`
`put into a fermenter where it ferments for 50 hours or 09:20:17
`put into a fermenter where it ferments for 50 hours or 09:20:17
`
`so. From there it is pre-heated and sent into a 09:20:23
`
`so. From there it is pre-heated and sent into a 09:20:23so. From there it is pre-heated and sent into a 09:20:23
`
`Page 14
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`HYDRITE EXHIBIT 1031
`Hydrite v. Solenis
`Trial IPR2015-1592
`(15 of 173)
`
`

`
`Case 2:15-cv-02063-JPM-tmp Document 62-6 Filed 11/02/15 Page 16 of 173 PageID 368
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`distillation column. Essentially the ethanol always 09:20:27distillation column. Essentially the ethanol always 09:20:27distillation column. Essentially the ethanol always 09:20:27
`
`comes off of the top of the distillation column. The 09:20:31
`
`comes off of the top of the distillation column. The 09:20:31comes off of the top of the distillation column. The 09:20:31
`
`non-fermentables come off the bottom of the first 09:20:35
`non-fermentables come off the bottom of the first 09:20:35
`
`distillation column. 09:20:38
`distillation column. 09:20:38
`
` Those non-fermentables are sent through a 09:20:40
` Those non-fermentables are sent through a 09:20:40
`
`centrifuge to get a split between suspended solids and 09:20:43
`centrifuge to get a split between suspended solids and 09:20:43
`
`dissolved solids. The suspended solids are sent to a 09:20:50
`
`dissolved solids. The suspended solids are sent to a 09:20:50dissolved solids. The suspended solids are sent to a 09:20:50
`
`dryer. The dissolved solids are further concentrated in 09:20:54
`
`dryer. The dissolved solids are further concentrated in 09:20:54dryer. The dissolved solids are further concentrated in 09:20:54
`
`an evaporator, and then heated, undergo some retention, 09:20:58
`an evaporator, and then heated, undergo some retention, 09:20:58
`
`the oil is removed. And then that is mixed with the 09:21:05
`
`the oil is removed. And then that is mixed with the 09:21:05the oil is removed. And then that is mixed with the 09:21:05
`
`suspended solids, or wet cake as we call it, and dried. 09:21:10
`suspended solids, or wet cake as we call it, and dried. 09:21:10
`
` Q. Would this be fair, for my benefit: Would it be 09:21:16
`
`fair to say that at some point we start with corn? 09:21:22
`
` A. Yes. 09:21:25
`
` Q. And then as ethanol is produced there's a 09:21:25
`
` Q. And then as ethanol is produced there's a 09:21:25 Q. And then as ethanol is produced there's a 09:21:25
`
`by-product? 09:21:29
`by-product? 09:21:29
`
` A. We prefer the term "co-product," but yes. 09:21:30
`
` A. We prefer the term "co-product," but yes. 09:21:30 A. We prefer the term "co-product," but yes. 09:21:30
`
` Q. Co-product. And in that co-product, locked up 09:21:33
`
`
` Q. Co-product. And in that