Dr. K. Mathioudakis
`
`London, UK
`
`April 20, 2017
`
`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` ---------------------------------
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ---------------------------------
`
` GENERAL ELECTRIC COMPANY, Petitioner
`
` -v-
`
`UNITED TECHNOLOGIES CORPORATION, Patent Owner
`
` ---------------------------------
`
` Case IPR2016-00952
`
` Patent No. 9,121,412
`
` Videotaped Deposition of DR. K. MATHIOUDAKIS
`
` On April 20 2017
`
` 9:00 am
`
` Taken at:
`
` Finnegan, Henderson,
`
` Farabow,Garrett & Dunner, L.L.P.
`
` 16 Old Bailey, London
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`1-800-FOR-DEPO
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`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-00952
`GE-1031.001
`
`
`
`London, UK
`
`April 20, 2017
`
`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` ---------------------------------
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ---------------------------------
`
` GENERAL ELECTRIC COMPANY, Petitioner
`
` -v-
`
`UNITED TECHNOLOGIES CORPORATION, Patent Owner
`
` ---------------------------------
`
` Case IPR2016-00952
`
` Patent No. 9,121,412
`
` Videotaped Deposition of DR. K. MATHIOUDAKIS
`
` On April 20 2017
`
` 9:00 am
`
` Taken at:
`
` Finnegan, Henderson,
`
` Farabow,Garrett & Dunner, L.L.P.
`
` 16 Old Bailey, London
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`1-800-FOR-DEPO
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`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-00952
`GE-1031.001
`
`
`
`Dr. K. Mathioudakis
`
`London, UK
`
`April 20, 2017
`
`Page 2
`
` A P P E A R A N C E S
`
`Appearing on behalf of the Plaintiff:
`
`M.ANDREW HOLTMAN
`
`FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, LLP
`
`901 New York Avenue, NW
`
`Washington, DC 20001-4413
`
`JANICE V. JABIDO
`
`PRATT & WHITNEY
`
`400 Main Street, M/S 132-13
`
`East Hartford, CT 06118
`
`Appearing on behalf of the Defendant:
`
`CHRISTOPHER PEPE
`
`WEIL, GOTSHAL & MANGES LLP
`
`1300 Eye Street NW, Suite 900
`
`Washington, DC 20005-3314
`
`ANISH DESAI
`
`WEIL, GOTSHAL & MANGES LLP
`
`1300 Eye Street NW, Suite 900
`
`Washington, DC 20005-3314
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`Alderson Court Reporting
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`GE v. UTC
`IPR2016-00952
`GE-1031.002
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`
`
`Dr. K. Mathioudakis
`
`London, UK
`
`April 20, 2017
`
`Page 3
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`Also present:
`
`Katy Ryder - Court Reporter
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`David Erdos - Videographer
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`www.aldersonreporting.com
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`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-00952
`GE-1031.003
`
`
`
`Dr. K. Mathioudakis
`
`London, UK
`
`April 20, 2017
`
`Page 4
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` I N D E X
`
`DR. K. MATHIOUDAKIS, (Sworn) .........................5
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`EXAMINATION BY MR. PEPE ..............................5
`
`EXAMINATION BY MR HOLTMAN ...........................53
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` E X H I B I T S
`
`No. Description Page
`
`Exhibit UTC-2026 Curriculum Vitae 6
`
`Exhibit UTC-2015 Declaration 10
`
`Exhibit GE-1001 Example Patent 20
`
`Exhibit UTC-2022 29
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`Exhibit UTC 2007 Journal Article 38
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`www.aldersonreporting.com
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`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-00952
`GE-1031.004
`
`
`
`Dr. K. Mathioudakis
`
`London, UK
`
`April 20, 2017
`
`Page 5
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` P R O C E E D I N G S
`
` DR. K. MATHIOUDAKIS,
`
` Having been sworn testified as follows:
`
`EXAMINATION BY MR. PEPE
`
` Q. Good morning.
`
` A. Good morning.
`
` Q. Have you ever been deposed before?
`
` A. No.
`
` Q. Okay. So before we get into it I just want to go
`
`over a few guidelines with you. I'm here today to ask you
`
`questions on behalf of General Electric. You are here today
`
`to answer questions. The court reporter here is writing
`
`down everything that we are saying so it is very important
`
`that we don't speak over each other so I'll just ask that
`
`while I'm asking you a question, you wait until I'm done
`
`before you answer and when you're answering I'm going to try
`
`my best not to speak over you. Does that sound good?
`
` A. Yes.
`
` Q. At certain points today your counsel Mr. Holtman
`
`may object to some of the questions that I ask but unless he
`
`instructs you not to answer the question you should go ahead
`
`and answer it after he's done objecting.
`
` I will plan to take break about once every hour. If
`
`before an hour you need to take a break to just stretch your
`
`legs, get a drink of water, just let me know and we can do
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-00952
`GE-1031.005
`
`
`
`Dr. K. Mathioudakis
`
`London, UK
`
`April 20, 2017
`
`Page 6
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`so. I'll just ask that if there's a pending question you
`
`answer the question before we take a break, is that okay?
`
` A. Yes.
`
` Q. Okay. Prior to this matter, have you had any
`
`interactions with United Technologies Corporation?
`
` A. What do you mean "interactions"?
`
` Q. Have you done any consulting work for
`
`United Technologies prior to this IPR proceeding?
`
` A. No.
`
` Q. Have you done any consulting work for
`
`Pratt & Whitney prior to this IPR proceeding?
`
` A. No.
`
` Q. So this particular matter is the first consulting
`
`arrangement you have had with United Technologies or
`
`Pratt & Whitney?
`
` A. Yes.
`
` Q. Have you had any prior interactions, consulting
`
`agreements with General Electric before?
`
` A. No.
`
` Q. Any prior interactions or consulting arrangements
`
`with Rolls Royce before?
`
` A. No.
`
` (Exhibit UTC-2026 marked for identification.)
`
` Q. I'm going to hand you what has been previously
`
`marked as Exhibit UTC-2026.
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-00952
`GE-1031.006
`
`
`
`Dr. K. Mathioudakis
`
`London, UK
`
`April 20, 2017
`
`Page 7
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` A. Thanks.
`
` Q. Do you recognise this document?
`
` A. Yes I do.
`
` Q. This is a copy of your resume or curriculum vitae?
`
` A. Yes, it looks like it is.
`
` Q. Okay if you can turn to page .004.
`
` A. Yes.
`
` Q. And at the very top of the page it says that:
`
` "He has been invited to give lectures at many
`
`institutions in different countries including
`
`Pratt & Whitney."
`
` Do you see that?
`
` A. Yes.
`
` Q. In what year did you give a lecture at
`
`Pratt & Whitney?
`
` A. I think it was 2008.
`
` Q. What was the topic of that lecture?
`
` A. The topic was related to engine condition
`
`monitoring and phone diagnostic techniques.
`
` Q. What do you mean by engine condition monitoring?
`
` A. Engine condition monitoring are all the actions
`
`that an engine operator does to know what the condition of
`
`the engine is.
`
` Q. Who invited you to give that lecture?
`
` A. It was a person called Allan Volponi.
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-00952
`GE-1031.007
`
`
`
`Dr. K. Mathioudakis
`
`London, UK
`
`April 20, 2017
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`Page 8
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` Q. Prior to being invited to give that lecture did you
`
`have a relationship with Allan Volponi?
`
` A. What do you mean "relationship"?
`
` Q. Did you know him before he contacted you to give
`
`the lecture?
`
` A. Yes, I knew him.
`
` Q. In a professional context?
`
` A. Yes, in a professional context.
`
` Q. Were you compensated for giving that lecture?
`
` A. No, I was not.
`
` Q. Was that the only lecture that you have given at
`
`Pratt & Whitney?
`
` A. Yes, it was the only one.
`
` Q. Do you still keep in contact with Allan Volponi?
`
` A. Yes, but very rarely. It's a long time, I have not
`
`contacted him.
`
` Q. With respect to this proceeding, when were you
`
`first contacted by United Technologies?
`
` A. I think some time in October, some time around
`
`then.
`
` Q. Do you remember who contacted you?
`
` A. I think I was contacted by Mr Mike Vakili.
`
` Q. What actions did you take before agreeing to
`
`consult for United Technologies on this matter?
`
` MR. HOLTMAN: Objection to form, vague.
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-00952
`GE-1031.008
`
`
`
`Dr. K. Mathioudakis
`
`London, UK
`
`April 20, 2017
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`Page 9
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` A. What do you mean, "what actions"?
`
` MR. PEPE: Did you review any documents before you
`
`agreed to consult on this matter?
`
` A. I read one document.
`
` Q. What document did you read?
`
` A. The patent '412.
`
` Q. Okay so the only document you read before agreeing
`
`to consult was the '412 patent?
`
` A. Yes.
`
` Q. Did you write the first draft of your declaration
`
`for this matter?
`
` A. Yes, I did.
`
` Q. How many hours did you spend writing that first
`
`draft?
`
` A. I don't remember how because it is not something
`
`that I did, sit down, so -- I wrote parts of it so I cannot
`
`really answer.
`
` Q. How much have you been compensated thus far for
`
`your work in this proceeding?
`
` A. I am compensated for my work, the compensation is
`
`€380 per hour so it's for the number of hours I spent times
`
`this compensation.
`
` Q. How many hours have you spent thus far?
`
` A. I do not recall the exact record because it is
`
`happening gradually.
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-00952
`GE-1031.009
`
`
`
`Dr. K. Mathioudakis
`
`London, UK
`
`April 20, 2017
`
`Page 10
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` Q. Do you know if it's more than 50 hours?
`
` A. It should be more than 50 hours.
`
` Q. More than 75 hours?
`
` A. I wouldn't think so, I think it would be something
`
`like between 50 and 70, something like this.
`
` (Exhibit UTC-2015 marked for identification.)
`
` Q. Okay. I'm going to hand you what has been
`
`previously marked as UTC-2015.
`
` A. Thank you.
`
` Q. This is a copy of the declaration that you have
`
`submitted in this matter, correct?
`
` A. Yes it looks as it is, a copy of my declaration.
`
` Q. Previously when I asked you how many hours you
`
`spent writing your declaration you said that you couldn't
`
`remember because you wrote parts of it. Can you tell me
`
`which parts of your declaration you wrote and which parts
`
`you didn't write?
`
` A. I wrote all of my declaration.
`
` Q. So on that previous answer you just misspoke?
`
` MR. HOLTMAN: Objection, I think the record speaks
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`for itself. You may be misinterpreting what he said.
`
` A. What I said before was referring to the time of,
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`how did I divide the time in writing declaration. So parts
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`were in different time slots. So it was not meant that
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`I wrote parts and I didn't write parts.
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`1-800-FOR-DEPO
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`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-00952
`GE-1031.010
`
`
`
`Dr. K. Mathioudakis
`
`London, UK
`
`April 20, 2017
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`Page 11
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` MR. PEPE: Okay let's turn back to your CV. Can
`
`you turn to page .002.
`
` A. I have done that.
`
` Q. Okay so in 1980 you received a degree in mechanical
`
`engineering?
`
` A. That's correct.
`
` Q. Did your studies focus on any particular area in
`
`mechanical engineering?
`
` A. What do you mean by that? Further specialization?
`
`I got a mechanical engineering degree.
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` Q. Did your degree have any emphasis in a particular
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`subject matter such as heat transfer or fluid mechanics or
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`was it just a general degree?
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` A. It had more weight on energetics and fluid
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`mechanics and also my diploma thesis which is something that
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`is concentrating on subject was turbo machinery.
`
` Q. And after receiving your mechanical engineering
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`degree you received a degree from the Von Karman Institute
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`for fluid dynamics?
`
` A. That's correct.
`
` Q. What was the emphasis of your studies at the
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`Von Karman Institute?
`
` A. At the Von Karman Institute I was a student in one
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`of the three departments that existed at the time and that
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`was the turbo machinery department. So my studies were in
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`1-800-FOR-DEPO
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`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-00952
`GE-1031.011
`
`
`
`Dr. K. Mathioudakis
`
`London, UK
`
`April 20, 2017
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`Page 12
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`turbo machinery.
`
` Q. And you received a doctorate in applied sciences
`
`after that?
`
` A. That's correct.
`
` Q. Was the emphasis of your studies with respect to
`
`your doctorate?
`
` A. The emphasis of my studies was turbo machinery,
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`again, and my doctorate was on compressors.
`
` Q. Since receiving your doctorate degree, what
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`experience do you have working in industry?
`
` MR. HOLTMAN: Objection to form, vague.
`
` A. What do you mean exactly by what experience I have?
`
` MR. PEPE: Your career on page .002 lists a number
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`of positions as a professor at universities, correct?
`
` A. That's correct.
`
` Q. Aside from working as a professor at universities,
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`have you been employed by private companies in your career?
`
` A. No, I have not been employed by private companies
`
`but I have done a lot of work for private companies from my
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`university position.
`
` Q. But in terms of your main employment since
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`receiving your doctorate it has been extensively in
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`academia, correct?
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` A. My official position has been in the University.
`
` Q. What is the current focus of your research at the
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`1-800-FOR-DEPO
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`Alderson Court Reporting
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`GE v. UTC
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`GE-1031.012
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`
`Dr. K. Mathioudakis
`
`London, UK
`
`April 20, 2017
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`Page 13
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`University?
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` A. There are several areas. One of those areas is the
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`modeling of the performance of gas turbines. Another area
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`is the diagnosis of faults in gas turbines. Another area is
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`gas turbines in relation to renewable energy sources.
`
` Q. Does all of your current research involve working
`
`with computer simulations?
`
` A. Computers are used a lot in my research, whether it
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`is for simulations or other purposes.
`
` Q. Do you currently do any research that involves
`
`performing experiments with hardware related to gas
`
`turbines?
`
` MR. HOLTMAN: Objection to form, vague.
`
` A. Could you make your question a bit more specific
`
`please?
`
` MR. PEPE: So you mentioned previously that some
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`of your research involves doing computer performance
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`simulations, correct?
`
` A. Modeling the performance of gas turbines, yes.
`
` Q. Do you have any current research projects that
`
`involve testing gas turbine engines or components of gas
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`turbine engines?
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` A. Yes, I have research projects which are related to
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`measuring the performance of gas turbine engines.
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` Q. And you have a facility at your university where
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`you test gas turbine engines?
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` A. I have a facility with one gas turbine engine that
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`can be used for performing measurements.
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` Q. What kind of gas turbine is it?
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` A. It is a small jet engine for propelling small
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`aircraft.
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` Q. When you say small jet engine, do you mean an
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`turbofan engine?
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` A. It is a small turbojet.
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` Q. Okay. So when you say "turbojet" you mean a gas
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`turbine engine with a compressor, a combustor and a turbine
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`but one that does not include a fan, right?
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` A. That's right.
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` Q. What experience do you have designing components
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`for gas turbine engines?
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` A. I have designed components, turbo machinery
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`components.
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` Q. What kind of turbo machinery components have you
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`designed?
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` A. I have designed compressors, and fans.
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` Q. And you have designed compressors and fans that
`
`have been physically built?
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` A. Yes, I have.
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` Q. When in your career did you do that?
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` A. I did it at several stages. My career in the early
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`90s, for example.
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` Q. Who were you working for when you designed
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`compressors and fans?
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` A. I did this work for facilities that were built in
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`our laboratory.
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` Q. And this was for a gas turbine engine that was
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`installed in your laboratory?
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` A. It was for individual components that were
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`installed in my laboratory.
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` Q. Who manufactured the fans and compressors that you
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`designed?
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` A. They were manufactured in Greece and they were also
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`manufactured abroad.
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` Q. Are those fans and compressors still operating in
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`your lab?
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` A. Some are.
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` Q. Have you ever designed any components for gas
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`turbine engines that have been used in commercial service?
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` A. I have not participated in the design of commercial
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`engine components.
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` Q. What design experience do you have with geared
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`turbofan engines?
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` A. I have done work on the cycle analysis of geared
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`turbofan engines which is usually the early stage of the
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`design.
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` Q. By cycle analysis you are referring to computer
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`simulations?
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` A. Yes, I'm referring to work that is done with
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`computer models.
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` Q. Have you written any publications regarding geared
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`turbofan engines?
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` A. Yes, I have.
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` Q. How many have you written?
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` A. I have two in my record.
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` Q. So the two listed in your CV are the only two you
`
`have written?
`
` A. Yes.
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` Q. Are you an inventor on any patents?
`
` A. No, I am not.
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` Q. Have you ever served as an expert witness in a
`
`patent case before?
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` A. No, I have not.
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` Q. Have you ever participated in the filing of any
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`patents?
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` A. I have not participated.
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` Q. Have you ever reviewed patents prior to working on
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`this matter?
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` A. I have looked at patents in several occasions.
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` Q. There regulations in Europe and the US that
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`establish noise limits for a commercial aircraft, correct?
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` A. As far as I know, yes.
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` Q. Aircraft are required to meet those noise limits,
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`correct?
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` A. From my experience I know that aircraft are
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`required to meet those regulations.
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` Q. And is it fair to say that those regulations have
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`become more stringent over time?
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` MR. HOLTMAN: Objection to form, vague.
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` A. What do you mean by more stringent over the time?
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` MR. PEPE: Have regulators been requiring that
`
`aircraft become quieter over time?
`
` A. As a general statement I would agree that, yes,
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`this has happened.
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` Q. Aircraft engines are one of the components of an
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`aircraft that contribute to the overall noise of the
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`aircraft, right?
`
` A. Yes.
`
` Q. So then noise would be a consideration in the
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`design of an aircraft engine, correct?
`
` A. As a general principle, yes.
`
` Q. As of the filing dated '412 patent what were the
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`known ways in which an engine designer could reduce the
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`noise in a turbofan?
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` A. There are several ways. There are ways that are
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`related to the operation, to the fluid dynamics of the
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`Page 18
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`components and there are ways that are related to how the
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`sound propagates.
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` Q. What are the ways related to the fluid dynamics of
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`the components?
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` A. These are ways that have to do with the flow field
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`within the components and how this flow field is set so that
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`the source of noise is minimal in intensity or in strength.
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` Q. How do you set the flow field so that the source of
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`the noise is minimal?
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` A. This is a very general question which covers very
`
`extensive fields so I don't think that there is a unique
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`answer to this question.
`
` Q. I'll try to be more specific then. One of the ways
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`that you can reduce the noise in a turbofan engine is to
`
`lower the pressure ratio of the fan, correct?
`
` A. Yes.
`
` Q. Can you go ahead and turn to paragraph 17 of your
`
`declaration.
`
` A. Yes, I have done that.
`
` Q. The very first sentence of that paragraph states
`
`that:
`
` "The '412 patent identifies and claims specific
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`combinations of gas turbofan engine features at lower losses
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`than the bypass flow passage."
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` Do you see that?
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` A. Yes.
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` Q. Is it your opinion that the '412 patent is the
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`first document to recognise the importance of minimizing
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`pressure losses and the bypass flow passage of a turbofan
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`engine?
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` A. The importance of losses has been recognised
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`already before the '412 patent. This is stated in the
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`patent itself.
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` Q. What is the impact of pressure losses in the bypass
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`flow passage?
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` A. Could you be a bit more specific? The impact on
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`what?
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` Q. What are the engine performance impacts of pressure
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`losses in the bypass flow passage?
`
` A. Pressure losses in the bypass flow passage
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`influence all the performances of the engine.
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` Q. So increased pressure losses will negatively affect
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`fuel consumption?
`
` MR. HOLTMAN: Objection to form, also objection
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`for incomplete hypothetical.
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` A. I can answer that the losses have a negative impact
`
`on fuel consumption.
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` MR. PEPE: And this was known before the
`
`'412 patent was filed, correct?
`
` A. Yes, this was known before the '412 patent was
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`filed.
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` Q. Is there any reason why you would want to design
`
`the bypass flow passage to have high pressure losses?
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` MR. HOLTMAN: Objection to form, vague as to
`
`whether we are still talking about the '412 patent and if we
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`are I think you should put the document in front of him.
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` A. Could you please repeat your question?
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` MR. PEPE: In general, is there any reason why you
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`would want to design the bypass flow passage for the
`
`turbofan engine to have high pressure losses?
`
` A. If we're talking in general, I would answer that
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`there is one aim, to have small pressure losses, small
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`amount of pressure losses.
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` Q. I just want to make sure that last answer isn't
`
`lost in translation. So are you saying that the aim is to
`
`have small pressure losses in general, right?
`
` A. The aim is to have small pressure losses. What we
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`actually achieve is something else. We may have the aim,
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`the desire to have small pressure losses but, nevertheless,
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`not to be able to have small pressure losses. So our desire
`
`is to have small pressure losses but what we can do is
`
`something else. On many occasions we cannot have small
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`pressure losses.
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` (Exhibit GE-1001 marked for identification.)
`
` Q. I want to hand you what has previously been marked
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`as GE-1001.
`
` A. Thank you.
`
` MR. PEPE: So GE-1001 is the '412 patent that is
`
`at issue in this proceeding, right?
`
` A. Yes.
`
` Q. If you could take a look at figure 1 in the
`
`'412 patent.
`
` A. I have it in front of me.
`
` Q. Okay so I want to ask you a few questions about
`
`that but I just want to first establish that we are talking
`
`about the same part so I'm going to refer to the area of the
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`flow passage to the left of the fan as upstream of the fan.
`
` A. Yes.
`
` Q. And the area to the right of the fan as downstream
`
`of the fan.
`
` A. Yes.
`
` Q. Where in the '412 patent does it can describe how
`
`to design the section of the flow passage that's upstream of
`
`the fan to have minimal pressure losses?
`
` A. The patent does not give some particular
`
`instruction as to the upstream part of the fan.
`
` Q. So it doesn't describe how to minimize losses in
`
`the flow passage upstream of the fan, right?
`
` MR. HOLTMAN: Objection, misstates the record.
`
` A. What do you mean?
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` MR. PEPE: In your previous answer you said that
`
`the patent doesn't give some particular instruction as to
`
`the upstream part of the fan. So we can agree that the
`
`'412 patent doesn't describe how to design the flow passage
`
`upstream of the fan to have minimal pressure losses, right?
`
` A. I would give some different interpretation to what
`
`you say. I don't agree with what you are saying. You asked
`
`me if I agree so I'm saying I don't agree.
`
` Q. Can you show me where in the '412 patent it
`
`describes how to design the portion of the flow passage
`
`upstream of the fan to have minimal pressure losses?
`
` A. The patent does not describe the design of details
`
`of the design of the bypass flow passage. The patent
`
`however provides means that would take the design of such
`
`parts into account and what I mean by that is that the
`
`patent specifies the total pressure has to be measured at
`
`the inlet and at the outlet of the bypass flow duct and
`
`I can point out where this is specified in the patent, if
`
`you want.
`
` Q. So the '412 patent doesn't provide the details of
`
`the design of the bypass flow passage, right?
`
` MR. HOLTMAN: Objection, misstates the record.
`
` A. I have answered already this question, my answer
`
`that I gave you is valid already.
`
` MR. PEPE: Where in the '412 patent does it
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`describe how to design the section of the bypass flow
`
`passage downstream of the fan to minimize pressure losses?
`
` A. The patent does not give details as to how to
`
`minimize pressure losses. However, by introducing the
`
`bypass flow passage pressure ratio it gives a means for
`
`encountering of all those losses.
`
` Q. The claim on the '412 patent requires a bypass flow
`
`passage pressure ratio between 1.1 and 1.35, correct?
`
` A. Yes.
`
` Q. So you could have a turbofan engine with a design
`
`fan pressure ratio of 2.5 that has 50 percent pressure
`
`losses in the bypass flow passage and that would fall within
`
`the claim range, right?
`
` MR. HOLTMAN: Objection, calls for legal
`
`conclusion and incomplete hypothetical.
`
` A. This is hypothetical situation and I wouldn't want
`
`to answer that.
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` MR. PEPE: So you don't know for a fan pressure
`
`ratio of 2.5 and pressure losses of 50 percent what the
`
`corresponding bypass flow passage pressure ratio would be?
`
` MR. HOLTMAN: Objection, the question referred to
`
`the claim --
`
` MR. PEPE: Andy, that's like the tenth time we've
`
`had a speaking objection. The rules are pretty clear.
`
` MR. HOLTMAN: Actually it is not, we've got the
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`record here.
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` MR. PEPE: Yes it is.
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` MR. DESAI: The trial practice guide actually
`
`specifically says "objection, vague" is an improper
`
`objection. I think you have actually lodged an objection
`
`six times in the first hour or so.
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` MR. HOLTMAN: It is a fine objection.
`
` MR. DESAI: Perhaps you should read the trial
`
`practice guide before you're making objections, Andy.
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` MR. PEPE: You need me to repeat the question?
`
` A. Please do.
`
` Q. So you don't know that for a fan pressure ratio of
`
`2.5 and a certain amount of pressure losses is what the
`
`corresponding bypass flow passage pressure ratio would be?
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` MR. HOLTMAN: Same objection.
`
` A. I answered before that I would not like to consider
`
`hypothetical situations and the situation you are discussing
`
`about is a hypothetical situation.
`
` Q. And I'm allowed to ask you hypothetical questions
`
`and you are required to answer them whether you like it or
`
`not. So should I ask again?
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` A. I assume you know what you are allowed to ask and
`
`what you are not allowed to ask. But --
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` Q. So you are refusing to answer?
`
` A. I answered already.
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` Q. Your answer was "this is a hypothetical situation
`
`and I wouldn't want to answer that"?
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` MR. HOLTMAN: Objection, misstates the record.
`
` MR. PEPE: So you're not going to answer?
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` MR. HOLTMAN: You can answer to the extent you
`
`can.
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` A. I mentioned that I wouldn't want to answer
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`hypothetical situations because hypothetical situations are
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`hypothetical. If you have some specific situation that you
`
`would like me to answer that is related to my opinion, the
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`opinion expressed in my declaration, I would be pleased to
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`answer. But I consider this as a hypothetical situation.
`
` Q. You provided opinions in your declaration regarding
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`the relationship between fan pressure ratio and bypass flow
`
`pressure ratio, correct?
`
` A. Yes, I have.
`
` Q. And for a given fan pressure ratio what the
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`corresponding bypass flow passage pressure ratio would be,
`
`right?
`
` A. Will you show me where I said this because I cannot
`
`recall. Defining what the corresponding -- what you just
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`said.
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` Q. Why don't we take a look at figure 1 of the
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`'412 patent.
`
` A. So you are not going to continue your questioning
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`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-00952
`GE-1031.025
`
`
`
`Dr. K. Mathioudakis
`
`London, UK
`
`April 20, 2017
`
`Page 26
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`for previously?
`
` Q. I'm continuing my questions.
`
` A. Okay.
`
` Q. So there we have a fan, correct, in figure 1?
`
` A. Correct.
`
` Q. And there's a bypass flow passage that is between
`
`what is identified as (60) and (62), correct?
`
` A. Correct.
`
` Q. Okay so for that fan, if the fan pressure ratio is
`
`2.5 and the pressure losses and the bypass flow passage are
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`50 percent, the corresponding bypass flow passage pressure
`
`ratio would be between 1.1 and 1.35, correct?
`
` A. May I ask you what you mean by losses of
`
`50 percent?
`
` Q. What don't you understand about that?
`
` A. When we quote losses we quote them with respect to
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`specific quantities, so 50 percent of what?
`
` Q. 50 percent of the fan pressure
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