throbber
JOSEPH KATONA
`November 15, 2016
`
`1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` SL CORPORATION,
` Petitioner,
` v.
` Adaptive Headlamp Technologies, Inc.,
` Patent Owner
` U.S. Patent No. 7,241,034
` Issue Date: July 10, 2007
` Reexamination Certificate Issue Date: June 14, 2013
` Title:
` Automatic Directional Control System for Vehicle
` Headlights
` Inter Partes Review No. IPR2016-00193
`*********************************************************
` ORAL DEPOSITION OF JOSEPH KATONA
` Taken for the Petitioner
` November 15, 2016
`********************************************************
` ORAL DEPOSITION OF JOSEPH KATONA, produced as a
`witness at the instance of the Petitioner, and duly
`sworn, was taken in the above-styled and numbered cause
`on November 15, 2016, from 8:52 a.m. to 11:41 a.m.,
`before Pennie Futrell, CSR in and for the State of
`Texas, reported by machine shorthand, at the office of
`
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`SL Corporation v. Adaptive Headlamp Technologies, Inc.
`
`
`
`SL Corp. Exhibit 1034
`Case IPR2016-00193
`
`

`
`JOSEPH KATONA
`November 15, 2016
`
`2
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`Friedman, Suder & Cooke, P.C., 604 East 4th Street,
`Suite 200, Fort Worth, Texas 76102, pursuant to the
`United States Patent and Trademark Office Rules and the
`provisions stated on the record or attached hereto.
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`

`
`JOSEPH KATONA
`November 15, 2016
`
`3
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` APPEARANCES
`FOR THE PETITIONER:
` Mr. Peter J. Cuomo
` MINTZ LEVIN COHN FERRIS GLOVSKY & POPEO, PC
` One Financial Center
` Boston, Massachusetts 02111
` Telephone: 617.348.1854
` Facsimile: 617.542.2241
` E-mail: pjcuomo@mintz.com
`
`FOR THE PATENT OWNER:
` Mr. Brett M. Pinkus
` FRIEDMAN, SUDER & COOKE, P.C.
` 604 East 4th Street
` Suite 200
` Fort Worth, Texas 76102
` Telephone: 817.334.0400
` Facsimile: 817.334.0401
` E-mail: pinkus@fsclaw.com
`
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`

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`JOSEPH KATONA
`November 15, 2016
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`4
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` I N D E X
`APPEARANCES.......................................... 2
`EXAMINATION OF JOSEPH KATONA
` Examination by Mr. Cuomo......................... 5
` Examination by Mr. Pinkus........................ 48
` Examination by Mr. Cuomo......................... 68
`SIGNATURE AND CORRECTION PAGE........................ 69
`CERTIFICATE.......................................... 71
` E X H I B I T S
`NO. DESCRIPTION PAGE
`Exhibit 2003 Curriculum Vitae 7
`Exhibit 1001 United States Patent 7,241,034 12
`Exhibit 2002 Declaration of Joe Katona in Support of 30
` Patent Owner's Response to Petition for
` Inter Partes Review
`Exhibit 1024 Japanese Unexamined Patent Application 34
` Publication H-10-324191
`Exhibit 1029 Suzuki SV650S brochure 37
`Exhibit 1030 Press release 41
`Exhibit 1019 UK Patent Application GB 2 309 774 43
`Exhibit 1031 Photograph 44
`Exhibit 1032 Honda Gold Wing GL1800 Owner's Manual 45
`Exhibit 1033 Suzuki TL1000S brochure 47
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`

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`JOSEPH KATONA
`November 15, 2016
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` JOSEPH KATONA,
`having been first duly sworn, testified as follows:
` EXAMINATION
`BY MR. CUOMO:
` Q. Good morning.
` A. Good morning.
` Q. Could you please state your name for the
`record?
` A. My name is Joe Katona.
` Q. And, Mr. Katona, what is your current address?
` A. My address is 1475 Ridge Court, Rochester,
`Michigan 48306.
` Q. And, Mr. Katona, have you ever been deposed
`before?
` A. Yes.
` Q. And when was that?
` A. It was about 2011 or '12.
` Q. What type of case did that involve?
` A. It was an insurance case.
` Q. Other than that case, have you been deposed
`before?
` A. No.
` Q. All right. I'm just going to go over some of
`the ground rules.
` I'll be asking questions today. We have
`
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`
`JOSEPH KATONA
`November 15, 2016
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`a court reporter here. She's going to be making a
`record. If you could answer my questions audibly, yes
`or no or -- as long as there's no grunts or groans. We
`want to have a clean record.
` From time to time, your attorney is going
`to object. When an objection is raised, you still need
`to answer my questions unless you're specifically
`instructed by your counsel not to answer.
` If you don't understand a question for
`me, just let me know and I'll rephrase the question.
` And during the course of the day, we'll
`take regular breaks. If you need a break at any time,
`just let me know. As long as there's no question
`pending, I'm happy to accommodate your request.
` Does that sound acceptable to you?
` A. Yes.
` MR. PINKUS: Let me just introduce myself
`for the record.
` MR. CUOMO: Sure.
` MR. PINKUS: I'm the attorney for
`Adaptive Headlamp, Brett Pinkus, from Friedman, Suder &
`Cooke.
` MR. CUOMO: Yeah, thank you. I should do
`the same.
` Peter Cuomo from Mintz Levin representing
`
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`
`JOSEPH KATONA
`November 15, 2016
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`the Petitioner, SL Corporation.
` THE WITNESS: And am I speaking loudly
`enough for the recorder?
` (Exhibit 2003 marked previously.)
` Q. (By Mr. Cuomo) I'm going to introduce --
`well, not introduce. This is an exhibit that was
`already marked. This is Exhibit 2003, the C.V. of
`Joseph Richard Katona.
` Mr. Katona, do you recognize this
`document?
` A. Yes, I do.
` Q. And I'd like to go over your education a
`little bit.
` Could you tell me what degrees you have?
` A. Yes. I have a degree in electrical
`engineering from General Motors Institute. Now it would
`be Kettering. And I have a -- and that's a Bachelor of
`electrical engineering. And I have a Master of Science
`in industrial engineering from Purdue University.
` Q. And I see on your C.V. that you had -- you
`were the General Motors Fellowship recipient for the
`pursuit of your Master's degree, is that correct?
` A. That's correct.
` Q. What is the General Motors Fellowship?
` A. The General Motors Fellowship is a program in
`
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`
`JOSEPH KATONA
`November 15, 2016
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`which General Motors is grooming what they think to be
`good candidates for future executive positions in the
`company. And they -- General Motors, that is -- will
`assist that candidate in the pursuit of an advanced
`degree. In this case, they provided a stipend and paid
`tuition to attend Purdue University's Krannert school.
` Q. And when you were getting your Master's
`degree -- of Science in industrial administration, what
`sort of coursework was required for that?
` A. It was -- the coursework was a combination of
`business type courses at a Master's level as well as
`technical courses. It was a -- it was intended to be
`a -- a school to -- to train and teach future business
`leaders in a -- of a technical organization.
` So it would -- it would combine technical
`as well as managerial, thus the Master of Science
`designation.
` Q. Was it mostly a managerial degree?
` A. I don't know that I would be able to say one
`way or the other whether it was mostly one or the other.
`It was -- it was quite well balanced, I think, between
`managerial and technical. The managerial courses
`included technical aspects and the technical courses
`included managerial aspects.
` Q. Do you recall what some of the technical
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`
`JOSEPH KATONA
`November 15, 2016
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`coursework entailed?
` A. It was a long time ago, but I remember that
`there -- there were statistics, there were business
`classes that had technical and statistical analyses
`involved in every one of the business classes, so -- and
`they were all case study-based, somewhat modeled after
`Harvard.
` Q. Did any of the coursework involve mechanical
`engineering?
` A. Not to my recollection.
` Q. Did you write a Master's degree thesis?
` A. I wrote an undergraduate thesis --
` Q. All right.
` A. -- that -- that General Motors accepted as a
`Master's thesis.
` Q. All right. What was the topic of that
`undergraduate thesis?
` A. Oh, boy. It was a -- it was a long title, so
`I could -- it was -- give me a minute to think of that
`one, okay?
` Q. Sure.
` A. It was quite technical and it had to do with
`time-domain reflectometry.
` Q. Maybe you could explain what -- what that is.
` A. Well, you're just -- you're digging way back.
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`
`JOSEPH KATONA
`November 15, 2016
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` Time-domain reflectometry has to do with
`reflected waves, reflected signals of electronic waves.
`And by looking at the original signal as well as the
`reflected signal and comparing the time aspects, the
`time domain aspects of the frequency content of those
`waves, you could produce a signature that would indicate
`the nature of the reflected entity that caused the
`reflection, thereby being able to detect a presence and
`location of a fault in an electrical system.
` Q. All right.
` A. I don't know if that helped.
` Q. Is that similar to sonar with electrical --
` A. You could think of it --
` Q. -- parts?
` A. You could think of it as sonar. You could
`think of it as sonar, yes, in an electrical sense,
`looking at a wave, a reflected wave.
` Q. For your Master's degree from Purdue, did you
`write a thesis?
` A. I did not.
` Q. Did not.
` And turning to your work experience, did
`your work at VIA Motors involve the development, design
`or implementation of control systems?
` A. Yes.
`
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`
`JOSEPH KATONA
`November 15, 2016
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` VIA, it would be called VIA Motors.
` Q. VIA.
` A. Yeah, VIA is not an acronym, it's a name.
` And I was in -- at VIA Motors, we were a
`very small start-up company and everybody had multiple
`roles. My designated role at that company was as a
`director of certification and validation. And a key
`aspect of that electric vehicle was a control system
`that would enable the vehicle to operate on electrical
`power or mechanical power or a combination of those two.
` Q. So is that a hybrid motor system?
` A. It was -- it was a parallel hybrid system.
` Q. Did your work at VIA Motors ever involve
`control systems for headlights?
` A. No, it did not.
` Q. And, Mr. Katona, you have 23 years of
`experience at GM, is that correct?
` A. No, I have 37 years of experience --
` Q. Thirty-seven.
` A. -- at GM.
` Q. Excuse me.
` A. But thank you for thinking I look so young. I
`appreciate that.
` Q. Well, you do, certainly.
` While you were at GM, did you develop,
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`
`JOSEPH KATONA
`November 15, 2016
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`design or implement any electric control systems?
` A. I did not.
` Q. Do you have any other experience related to
`the development, design or implementation of control
`systems that are not listed on your C.V. here?
` A. Yes. While at General Motors, I participated
`in the development, design of control systems in that I
`directed those activities. I didn't personally design
`and develop those systems, and that's why I answered,
`no, I did not, I wasn't personally involved in that.
`However, I was responsible for those activities.
` Q. And did any of those control systems relate to
`headlights?
` A. No.
` (Exhibit 1001 marked previously.)
` Q. (By Mr. Cuomo) I'd like to introduce a
`premarked exhibit. This is Exhibit 1001, 1001, and this
`is U.S. Patent 7,241,034.
` And, Mr. Katona, do you recognize this
`exhibit?
` A. I do, yes.
` Q. When did you last see it?
` A. Yesterday.
` Q. All right. Did -- did you prepare for your
`deposition yesterday?
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`
`JOSEPH KATONA
`November 15, 2016
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` A. I did.
` Q. And approximately how long did you spend
`preparing?
` A. Yesterday?
` Q. Yes.
` A. So you're asking how long did I spend
`preparing yesterday?
` Q. We'll start with yesterday, sure.
` A. Okay. Let's say seven hours.
` Q. All right. And were there other times where
`you were preparing for your deposition other than
`yesterday?
` A. Yes.
` Q. And when were those times?
` A. In the previous two weeks or so since I was
`notified that there was a deposition pending.
` Q. And how did you prepare for today's
`deposition?
` A. I prepared by reading over the materials that
`I was given originally.
` Q. And do you recall what those materials were?
` A. Probably not all of them specifically, but
`they were the '034 patent, there was a patent by what
`we're calling Kato, and there was a patent by what we're
`calling Takahashi, and of course my declaration.
`
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`
`JOSEPH KATONA
`November 15, 2016
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` Q. All right. Any other documents that you
`reviewed?
` A. Yes, there were other patents that were
`reviewed.
` Q. And do you recall the names of any of those
`patents?
` A. One was what I'm calling Uguchi, I'm not sure
`if I got that right, but -- and there were a couple of
`others whose titles I cannot remember.
` Q. All right.
` A. I'd have to pull out the papers.
` Q. Did you meet with anyone to prepare for your
`deposition?
` A. I did.
` Q. And who was that?
` A. He's sitting right next to me.
` Q. So that would be --
` A. His name is Brett Pinkus.
` Q. -- Mr. Pinkus?
` All right. And when did you meet with
`Mr. Pinkus?
` A. Yesterday.
` MR. PINKUS: I'm just going to instruct
`you not to discuss the content of any discussion we had
`because that's privileged.
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`
`JOSEPH KATONA
`November 15, 2016
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` THE WITNESS: Okay. Thanks.
` MR. PINKUS: But the fact that you met
`with us or what you generally did, you can testify
`about.
` Q. (By Mr. Cuomo) Sure. And just so you know,
`I'm not trying to delve into any of those conversations.
` A. I understand.
` Q. Did you meet with Mr. Pinkus at any other time
`in preparation for your deposition today?
` A. No.
` Q. If we could take a look at the '034 patent.
` The '034 patent's general field is
`automatic directional control systems for vehicle
`headlights, correct?
` A. Yes.
` Q. And if you could turn your attention to --
`start right at column 1 -- I'm sorry, we'll look at
`column 2, lines 3 to 7.
` The '034 patent discusses making
`adjustments based on certain operating conditions
`changing, is that correct?
` A. Say that again, please.
` Q. Sure.
` The '034 patent discusses making certain
`adjustments based on certain operating conditions --
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`
`JOSEPH KATONA
`November 15, 2016
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` A. Correct.
` Q. -- is that correct? All right.
` And if you look a little further down,
`specifically look to lines 7 to 13, the operating
`conditions that the '034 patent discusses sensing
`includes road speed, correct?
` A. Correct.
` Q. They include rate of change of road speed,
`correct?
` A. Correct.
` Q. They include steering angle, correct?
` A. Yes.
` Q. They include rate of change of steering angle,
`correct?
` A. Yes.
` Q. They include pitch, correct?
` A. Yes.
` Q. They include rate of change of pitch, correct?
` A. Yes.
` Q. They include suspension height of the vehicle,
`correct?
` A. Yes.
` Q. And they include the rate of change of the
`suspension height of the vehicle, correct?
` A. Yes.
`
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`
`JOSEPH KATONA
`November 15, 2016
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` Q. If we can talk about pitch for a moment,
`that's the same thing as the posture of a vehicle,
`correct?
` A. I -- as Takahashi refers to posture, I would
`agree with that. Posture isn't a -- a standard name in
`the industry that I would recognize --
` Q. All right.
` A. -- where pitch is more standard terminology.
`So posture is maybe more colloquial in nature. But as I
`saw -- as I interpreted what Takahashi was referring to,
`I would equate pitch with posture.
` Q. Would it be fair to say that the posture of
`the vehicle includes the pitch?
` A. No, it would only be fair if you understood
`how someone was defining posture and how someone was
`defining pitch. Those terms are ambiguous unless they
`have definitions behind them.
` Q. All right.
` A. I think someone might see that, someone might
`think that, and it would be reasonable to think that,
`but you would really need to have an operational
`definition of both.
` Q. When you say it would be reasonable to think
`that, are you talking about pitch and posture being
`synonymous or posture including pitch?
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`
`JOSEPH KATONA
`November 15, 2016
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` A. I think you would -- once again, you would
`have to see the definitions of both and understand what
`they were referring to in -- in context for -- you know,
`for each entity that was defining it that way.
` Q. All right. For pitch, isn't it true that
`pitch can be sensed by placing suspension height sensors
`on the vehicle and comparing the front and rear
`suspension height?
` A. Yes.
` Q. And isn't it true that one could also compare
`the left and right suspension heights to determine the
`left/right lean of a vehicle?
` A. If done correctly, I would agree with that.
` Q. So if one side was higher than the other, that
`could be sensed, correct?
` A. If one side were totally higher than the
`other, then you might determine a lean, a left/right
`lean.
` Q. That would be the same thing as measuring the
`roll of a vehicle, correct?
` A. Yes.
` Q. And that would be the same thing as measuring
`the bank angle of a vehicle, correct?
` A. Yes.
` Q. Let's talk about why measuring pitch is
`
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`
`JOSEPH KATONA
`November 15, 2016
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`important.
` If a heavy load is placed in the rear of
`a vehicle, the vehicle will pitch upward where
`traditional headlights would be aimed upwards too much,
`correct?
` A. Yes.
` Q. And this would occur on both cars and
`motorcycles, correct?
` A. Yes.
` Q. The pitch of a vehicle would be different
`when, for example, the load is a person when comparing a
`pitch of a car with just a driver and the pitch of a car
`with a driver and a passenger in the back seat?
` MR. PINKUS: Objection; form.
` Q. (By Mr. Cuomo) Did you understand that
`question?
` A. No, I did not understand that question.
` Q. Okay. All right.
` A. I would --
` Q. I'll rephrase that.
` A. Yeah, I would have had you rephrase that.
` Q. If you had just a driver in the front seat and
`you had -- versus a car with a driver and multiple
`passengers in the back seat, the pitch angles would
`differ in those two situations, correct?
`
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`
`JOSEPH KATONA
`November 15, 2016
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` A. Not necessarily.
` Q. So if you had more of a load in the back,
`wouldn't it be true that pitch would -- would be
`different in that situation?
` A. Pitch is affected by load and placement of
`load.
` Q. So multiple passengers in the back seat
`wouldn't affect the pitch?
` A. Pitch is affected by load and placement of
`load. Passengers have mass. You would need to
`understand the mass of the passengers, you would need to
`understand the placement of the passengers.
` Q. The position of passengers being the rear of
`the vehicle or in the back, couldn't that influence
`pitch?
` A. I'm not sure where you're going with this, but
`it's true that pitch is influenced by load and placement
`of load. To me, a back, front, rear seat, front seat is
`ambiguous.
` Q. If the load is in the rear of the vehicle,
`that would influence the pitch, correct?
` A. The placement of load influences pitch.
` Q. And if the placement of the load is in the
`rear of the vehicle, that would influence the pitch?
` A. The placement of load influences pitch.
`
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`
`JOSEPH KATONA
`November 15, 2016
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` I'm not trying to be difficult, I'm just
`trying to be precise.
` Q. All right. Isn't it true that the pitch of a
`car can change when the car accelerates?
` A. Yes.
` Q. And if a car is accelerating, wouldn't it be
`true that it's pitched back such that traditional
`headlights would be aimed too high?
` A. Could you rephrase that?
` Q. Sure.
` If a car is accelerating, wouldn't the
`pitch that you would normally see involve the headlights
`being directed upwards?
` A. Yes.
` Q. And isn't true that the pitch of car can also
`change when a car decelerates?
` A. Yes.
` Q. And if a car is decelerating, wouldn't it
`become pitched such that the headlights would start to
`direct downwards?
` A. Yes.
` Q. Isn't it true that bumps or small changes in
`gradient in the road can also change the pitch of a
`vehicle?
` A. Not necessarily. You need to be more specific
`
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`
`JOSEPH KATONA
`November 15, 2016
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`with your question.
` Q. All right. Can bumps in the road temporarily
`change the pitch of the vehicle?
` A. Yes.
` Q. And while going over a bump in the road, first
`the car is pitched one way and then the other way as it
`clears the bump, correct?
` A. I think that's too general of a question.
` Q. I'll try and make it more specific.
` When you're driving over a bump and the
`front wheel hits the bump, that causes the pitch to be
`directed upwards, correct?
` A. Not necessarily. Bumps can go up or down.
`Bumps can go side to side.
` Q. How about a speed bump, if you were going over
`a speed bump, wouldn't the front wheel when it hits the
`bump cause the car to be pitched back and the lights to
`be directed upwards?
` A. I need you to be more specific. And once
`again, I'm not trying to be difficult.
` Are you going over the speed bump in a
`forward direction?
` Q. Yes.
` A. And is the speed bump proud of the normal
`surface? In other words, is it an up -- upward bump?
`
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`

`
`JOSEPH KATONA
`November 15, 2016
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` Q. Yeah, we'll take the case where it's not a
`speed depression, as you might have seen them on the
`road, but an actual speed bump --
` A. Okay.
` Q. -- where it's raised from the road.
` A. Okay.
` Q. In that situation when the front wheels hit
`the bump, the -- that would cause the car to be pitched
`back and the headlights to be aimed too high, correct?
` A. If you're moving in a forward direction.
` Q. In that case --
` A. Correct.
` Q. -- that would be correct?
` And if -- taking that same hypothetical,
`if you're moving in a forward direction and next the
`rear wheel hits the bump, this would cause the car to be
`pitched forward and the lights to be aimed too low,
`correct?
` A. I would have to know what the front wheels
`were doing at that moment.
` Q. Let's assume the front wheels have cleared the
`bump.
` A. And the front wheels are on level ground?
` Q. Correct.
` A. And the rear wheels are now going over the
`
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`
`JOSEPH KATONA
`November 15, 2016
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`bump?
` Q. That's right.
` A. The headlights will now aim downward.
` Q. And, Mr. Katona, isn't it true that the same
`kind of pitch effects can occur on a motorcycle?
` A. Yes.
` Q. Mr. Katona, the '034 patent discusses a broad
`variety of vehicles. Is there any place in the '034
`patent where motorcycles are specifically excluded?
` A. I don't know that. I don't know that. I'd
`have to read it -- read through it again. I don't
`recall -- I don't recall a spot where they would -- it
`would specifically include motorcycles.
` Q. Well, let's take a step back.
` A. I think they're talking about vehicles with a
`certain number of wheels.
` Q. All right. Let's -- let's take a step back.
` What is a headlight in your opinion?
` A. A headlight is a device that illuminates the
`road. But it's more than that. It's a device that's
`regulated by Federal Motor Vehicle Safety Standards and
`other regulations that require it to perform in a
`certain way.
` Q. Mr. Katona, what types of vehicles have
`headlights?
`
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`
`JOSEPH KATONA
`November 15, 2016
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` A. Many types of vehicles; cars, trucks,
`motorcycles, buses.
` Q. Any others?
` A. Certainly.
` Q. Can you name a few?
` A. I prefer not to name more vehicles because the
`way that I'm thinking of headlights, I'm thinking of
`headlights that are regulated on public roads and not on
`railroad tracks or airplane runways because those have
`different operating characteristics and different
`requirements.
` Q. And, Mr. Katona, is that the way that you
`interpreted "vehicle" in this proceeding -- or, excuse
`me, "headlight" in this proceeding?
` A. You'd have to be more specific about your
`question.
` Q. All right. If you could take -- turn to
`column 1 of the '034 patent and look at what begins at
`line 20.
` Do you see where this says that,
`"Virtually all land vehicles, and many other types of
`vehicles (such as boats and airplanes, for example), are
`provided with one or more headlights that are adapted to
`illuminate a portion of a dark road surface or other
`area in the path of movement of the vehicle to
`
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`
`JOSEPH KATONA
`November 15, 2016
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`facilitate straight (sic) travel thereon"?
` MR. PINKUS: Safe travel thereon.
` MR. CUOMO: Yes.
` THE WITNESS: I see that.
` Q. (By Mr. Cuomo) And do you agree with the
`statement that all land vehicles, boats, and airplanes
`have headlights?
` A. I think that's a reasonable statement.
` Q. And do you agree that the '034 patent is
`directed generally to headlights?
` A. Yes.
` Q. Do you agree that the headlight discussed in
`the '034 patent applies to any type of vehicle?
` A. Again, I need to -- I need you to be more
`specific when you say discussed in the patent.
` Q. Well, as --
` A. There -- there are claims and there is
`background.
` Q. Based on the portion of the background of the
`invention that we just read, do you agree that the
`headlight discussed in this patent applies to any type
`of vehicle?
` A. Could you repeat that, please?
` Q. Sure.
` Based on this portion of the patent that
`
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`
`JOSEPH KATONA
`November 15, 2016
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`we just read, do you agree that the '034 -- that the
`headlight discussed in the '034 patent applies to any
`type of vehicle?
` A. No, I agree that it applies to virtually all
`land vehicles and many other types of vehicles.
` Q. And that would --
` A. Such as boats and airplanes, for example.
` Q. All right. Mr. Katona, four-wheeled cars
`typically have two or more headlights, correct?
` A. Correct.
` Q. And there aren't any cars that only have a
`single headlight, correct?
` A. Not anymore and not legally, but there was a
`Tucker and the Tucker had a single headlight.
` Q. What was the Tucker?
` A. I don't remember exactly when they were built,
`but they were built back in the '30s, and it was a
`vehicle with a single headlight.
` Q. Do you recall the time when the Tucker was out
`of existence or out of manufacture?
` A. No.
` Q. With the exception of the Tucker, there aren't
`any cars that you're aware of that only have one
`headlight, correct?
` A. Correct.
`
`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
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`

`
`JOSEPH KATONA
`November 15, 2016
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` Q. Isn't it true that motorcycles can have one
`headlight?
` A. Correct.
` Q. Wouldn't you agree that a motorcycle is a land
`vehicle?
` A. Yes.
` Q. If you could look at column 1 on line 22 where
`it discusses vehicles having one or more headlights.
` Do you see that?
` A. Yes.
` Q. Isn't it reasonable to conclude that this line
`is referring to motorcycles by including vehicles with
`one headlight?
` A. Could you say that again, please?
` Q. Sure.
` Isn't it reasonable to conclude that this
`line of the patent specification is referring to
`motorcycles by including vehicles with one headlight?
` A. Yes.
` Q. Mr. Katona, there's nothing in the '034 patent
`concerning the number of wheels a vehicle has, correct?
` A. I would have to look it over and reread the
`entire '034 to be able to answer that.
` Q. Mr. Katona, I'm happy to allow you to take a
`look through and ask if there's anyplace that you can
`
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`
`JOSEPH KATONA
`November 15, 2016
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`find in the '034 patent that refers to the number of
`wheels that a vehicle has.
` Would you like to do that?
` A. I would.
` Q. All right.
` A. And could you repeat the question that we're
`trying to answer?
` Q. Sure.
` The question is that there's nothing in
`the '034 patent concerning the number of wheels that a
`vehicle has. And I'd like to know if you agree with
`that statement.
` A. Okay. So let me look -- take a look.
` Q. Sure. Take your time.
` A. Okay. Can you please ask the question again?
` Q. Sure.
` Mr. Katona, there's nothing in the '034
`patent concerning the number of wheels a vehicle has,
`correct?
` A. Concerning. So --
` Q. I'll ask it --
` A. Can you as

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