Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`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 No. IPR2016-01301
` Patent No.: 6,939,392
` __________
`
` Videotaped Deposition of Expert Witness
` DR. GERALD VOECKS
` Washington, D.C.
` Friday, March 24, 2017
` 9:03 a.m.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`GE v. UTC
`Trial IPR2016-01301
`
`UTC-2002.001
`
`
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`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 No. IPR2016-01301
` Patent No.: 6,939,392
` __________
`
` Videotaped Deposition of Expert Witness
` DR. GERALD VOECKS
` Washington, D.C.
` Friday, March 24, 2017
` 9:03 a.m.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`GE v. UTC
`Trial IPR2016-01301
`
`UTC-2002.001
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`2
`
` Cross-Examination of Dr. Gerald Voecks, a
`witness herein, called for examination by counsel for
`Patent Owner in the above-entitled matter, pursuant
`to notice, the witness being duly sworn by SUSAN L.
`CIMINELLI, CRR, RPR, a Notary Public in and for the
`District of Columbia, taken at the offices of Weil,
`Gotshal & Manges, LLP, 1300 I Street, Suite 900,
`Washington, D.C., commencing at 9:03 a.m.
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`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.002
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`3
`
`APPEARANCES:
` On behalf of the Petitioner:
` CHRISTOPHER MARANDO, ESQUIRE
` Weil, Gotshal & Manges, LLP
` 1300 I Street, N.W.
` Suite 900
` Washington, D.C. 20005-3314
` 202.682.7094
` christopher.marando@weil.com
`
` On behalf of the Patent Owner:
` C. BRANDON RASH, ESQUIRE
` CARA REGAN LASSWELL, ESQUIRE
` Finnegan, Henderson, Farabow, Garrett &
` Dunner, LLP
` 901 New York Avenue, N.W.
` Washington, D.C. 20001-4413
` 202.408.4000
`
` ALSO PRESENT:
` Mike Shields, Videographer
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`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.003
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`4
`
` C O N T E N T S
`DR. GERALD VOECKS EXAMINATION
` By Mr. Rash 6
` By Mr. Marando 122
`
` Afternoon Session - Page 108
`
` E X H I B I T S
`EXHIBIT NO. PAGE NO.
`Exhibit 1003 GE1003.001-121 Declaration of
` Dr. Gerald Voecks 8
`Exhibit 1004 GE1004.001-002 Voecks Resume 8
`Exhibit 1001 GE1001.001-016 U.S. Patent
` Number 6,939,392 B2 9
`Exhibit 1005 GE1005.001-014 U.S. Patent
` Number 6,315,815 B1 9
`Exhibit 1006 GE1006.001-029 WO 02/16743 A1 10
`
` * * *
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`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.004
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
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` P R O C E E D I N G S
` THE VIDEOGRAPHER: Here begins disc 1 in
`the video deposition of Dr. Gerald Voecks, taken in
`the matter of General Electric Company v. United
`Technologies Corporation, in the United States Patent
`and Trademark Office, Number IPR2016-01301. Today's
`date is March 24th, 2017. The time is 9:03.
` This deposition is being held at 1300 I
`Street, Northwest, Washington, D.C., 20005. The
`court reporter is Sue Ciminelli. The videographer is
`Michael Shields. Both are presenting on behalf of
`Henderson Legal Services. Will counsel and others
`please introduce themselves and state whom they
`represent.
` MR. RASH: Brandon Rash from Finnegan on
`behalf of the United Technologies Corporation. And
`with me from Finnegan is Cara Lasswell.
` MR. MARANDO: Chris Marando with Weil
`Gotshal & Manges on behalf of GE. And with me is
`Brian Ferguson, also of the Weil firm, and GE
`Aviation in-house counsel, Matt Hayden.
` THE VIDEOGRAPHER: Will the court reporter
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.005
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
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`please swear in the witness.
`Whereupon,
` GERALD E. VOECKS, Ph.D.,
`was called as a witness by counsel for Patent Owner,
`and having been duly sworn, was examined and
`testified as follows:
` CROSS-EXAMINATION
`BY MR. RASH:
` Q. Good morning, Dr. Voecks.
` A. Yes, it is.
` Q. I am Brandon Rash. I'm an attorney with
`the law firm of Finnegan, and I'm going to be asking
`you questions today. Could you please state your
`full name for the record, please?
` A. Gerald Elery Voecks.
` Q. Have you ever been deposed before?
` A. Several years ago. '70s.
` Q. Okay. And what type of proceeding was
`that?
` A. That was a contract that was in place that
`was refuted, and the purpose was to rescind the
`particular contract.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.006
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`7
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` Q. Okay. So this -- so that was in the
`context of a litigation?
` A. Right.
` Q. So this will be somewhat of a similar
`process maybe.
` A. Okay.
` Q. At least in terms of the process. Maybe
`not the subject matter. Do you understand that you
`are under oath today?
` A. Yes.
` Q. If you don't understand a question that I
`ask at any time, feel free to ask for a
`clarification. I'm happy to do that.
` A. Okay.
` Q. If at any point -- I don't expect that
`we'll be going all day today, but I do expect we'll
`want to take a break at some point. If you need to
`take a break at any time, just let me know. We can
`do that.
` A. Okay.
` Q. And is there any reason that you cannot
`testify truthfully today?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.007
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
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` A. No.
` Q. Okay. I'll start by giving you some
`documents.
` (GE Exhibit 1003 was
` marked for identification.)
` MR. RASH: Counsel, you have a
`double-sided copy of the same thing. His is
`single-sided.
`BY MR. RASH:
` Q. But the document that you have there is
`marked GE 1003. Does this appear to be the
`declaration that you provided in Case Number
`IPR2016-01301?
` A. Yes, it looks like it is. Yes.
` Q. And if I refer to your declaration, will
`you understand that I'm referring to this exhibit, GE
`1003.
` A. Okay.
` (GE Exhibit 1004 was
` marked for identification.)
`BY MR. RASH:
` Q. This next document is titled Resume,
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.008
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
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`Gerald E. Voecks. And it's marked GE 1004. Does
`this look like the resume that you provided in this
`case?
` A. Yes, it does.
` Q. And again, if I refer to this as your
`resume, will you understand I'm referring to GE 1004?
` A. Yes.
` (GE Exhibit 1001 was
` marked for identification.)
`BY MR. RASH:
` Q. This next document is U.S. Patent Number
`6,939,392, and it has been marked as GE 1001. And do
`I understand correctly that you are here today to
`testify with respect to your declaration concerning
`this U.S. Patent Number 6,939,392?
` A. Yes.
` Q. And if I refer to this patent as the '392
`patent, will you understand that I'm referring to
`U.S. Patent Number 6,939,392 marked GE 1001?
` A. Yes.
` (GE Exhibit 1005 was
` marked for identification.)
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.009
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
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`BY MR. RASH:
` Q. The next document that I've given you is
`U.S. Patent Number 6,315,815 marked GE 1005. Do I
`understand correctly that one of the asserted
`references that you discuss in your declaration is
`this U.S. Patent 6,315,815 marked GE 1005?
` A. Yes.
` Q. And will it be okay if I refer to this
`patent as Spadaccini?
` A. Okay.
` Q. And you'll understand that I'm referring
`to GE 1005?
` A. 815. Okay.
` (GE Exhibit 1006 was
` marked for identification.)
`BY MR. RASH:
` Q. Just one more document here to get that
`out of the way.
` A. You'll have a lot less to carry back with
`you.
` Q. That's usually the goal. Okay. So this
`next document is publication WOO2/16743A1 marked GE
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.010
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
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`March 24, 2017
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`1006. Is this another asserted reference that you
`discuss in your declaration?
` A. Yes, it is.
` Q. And will you understand that I'm referring
`to this publication marked GE 1006 if I call it
`Wilmot?
` A. Yes.
` Q. Okay. When did you first get involved in
`this case?
` A. I guess it was in November of 2015, as I
`recall.
` Q. And am I correct that your declaration is
`dated June 28, 2016?
` A. Yes, I believe that's correct.
` Q. Is that the date you completed working on
`your declaration?
` A. Yes.
` Q. And do you have an estimate of how many
`hours you spent on the case up to the date you
`completed your declaration?
` A. I really don't recall. I mean, I'd have
`to go back and take a look at how much time was
`
`202-220-4158
`
`Henderson Legal Services, Inc.
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`
`UTC-2002.011
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
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`March 24, 2017
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`spent. It was an intermittent period of time,
`continuous.
` Q. Are you able to ballpark, roughly?
` A. Numbers of hours? Just a guess. 30
`hours, 40 hours. I don't know. It's been a while
`back. A lot of water under the bridge since then.
` Q. And did you do anything to prepare for
`this deposition?
` A. Yes.
` Q. And what did you do?
` MR. MARANDO: Just caution you not to
`disclose any communications with counsel, but you can
`answer the question.
` THE WITNESS: Sure. I reviewed these
`documents again, since these are documents that we're
`discussing.
`BY MR. RASH:
` Q. Anything else?
` A. No.
` Q. Did you meet with your counsel?
` MR. MARANDO: Same caution. You can
`answer that question, but don't disclose any
`
`202-220-4158
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`Henderson Legal Services, Inc.
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`
`UTC-2002.012
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
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`March 24, 2017
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`communications.
` THE WITNESS: Yes, we did meet.
`BY MR. RASH:
` Q. And approximately how long did you spend
`reviewing documents and meeting with your counsel?
` A. It was a few hours over the course of a
`couple of days.
` Q. Now, you have a master's and a Ph.D. in
`inorganic chemistry, is that right?
` A. Correct.
` Q. Do you have any other advanced degrees?
` A. No.
` Q. Am I correct that inorganic compounds do
`not contain carbon?
` MR. MARANDO: Object to form.
` THE WITNESS: No, not true. Inorganic can
`also include organometallics, which can be as part of
`what I researched was with metal carbonyls, which has
`carbon. Complexes of organometallics typically have
`carbon. Trimethylphosphine, for example, has,
`obviously, carbon in the methyl -- in the methyl
`groups. So even though it's inorganic-based, it's
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.013
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
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`not the same as organic, so to speak, but certainly
`does include organic material. Carbonaceous
`material.
`BY MR. RASH:
` Q. What do you mean it's not the same as
`carbon-based?
` MR. MARANDO: Object to form. Sorry. You
`can answer.
` THE WITNESS: If -- if you differentiate
`-- and this is kind of interesting that you mention
`this, because back at the time when I was working on
`my Ph.D., it was a debate between whether it was
`going to be called organometallics or
`metallo-organics, and I guess I would say the
`inorganics won, because we call it metallo-organics.
` So metal complexes, of which there are
`several, cyclopentadienyl, vanadium, tricarbonyl, for
`example, is -- has a cyclopentadienyl ring, so that's
`organic. But it's considered inorganic from the
`standpoint of transition metal. So certainly crosses
`the border between inorganic and organic.
`BY MR. RASH:
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.014
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`15
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` Q. Was the focus of your master's in
`inorganic chemistry on the metallic organics?
` A. It was not. It was trimethylphosphine
`carbon disulfide adduct chemistry, in which we were
`looking at how such an adduct could be used for
`complexes with diborane. We were looking at
`primarily non-transition metal inorganics.
` So inorganic covers a pretty broad range
`when you look at the periodic chart, as compared to
`organics which pretty much focuses on one element, so
`to speak. Trimethylphosphine, and looked at other
`organic groups on phosphorous in that particular
`research. It's an interesting adduct.
` Q. And your Ph.D., did that focus on the --
`am I saying it correctly, metallic organics?
` A. Organometallic.
` Q. Organometallic. Sorry. Inorganics won.
` A. In that particular case, we were using
`organometallic complexes with organic material,
`norbornadiene. And what we were looking at was from
`the standpoint of dimerization of the material,
`selectively activating it from a catalyst standpoint
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.015
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`16
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`using the organometallics.
` And we were looking at photochemistry,
`photolytic activation. And looking at specifically
`forming dimers that you could predict as a result of
`the complex that would form in the process. So it
`was reaction mechanisms, photochemistry with organic
`compounds, norbornadiene. It's a C7 bicyclic
`compound, and it can form a series of dimers in the
`process.
` We were looking at specific configurations
`in which you could get Exo Exo, Exo Endo, Endo Endo
`dimers. And you could also form trimers. And so it
`was very specific that we were interested in the
`configuration of the organometallic, in this case
`carbonyls that we were looking at.
` It turns out the carbonyls were all toxic,
`so that was all done in the hood and vacuum lines.
`But all the complexes that we generated were safe
`complexes, organic complexes that we were looking at,
`dimers. And we were trying to isolate the
`intermediates. So this is where the borderline
`between organic and inorganic kind of crosses over,
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.016
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`17
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`particularly from a catalyst standpoint.
` Q. Can you turn in your declaration to
`paragraph 7 on page 6.
` A. Okay.
` Q. Do you see about five lines down, you
`refer to a catalytic reactor?
` A. Yes. Catalytic partial oxidation.
` Q. What is a catalytic reactor?
` A. A catalytic reactor is, and can be two
`different forms. Basically, it involves the use of a
`material, a catalyst that will enhance a particular
`reaction rate to a particular product, lowering the
`energy barrier to make that particular product.
` And the reactor is the vessel in which you
`contain it. Can be -- can take the form of several
`different geometries, and could be a heterogeneous
`catalyst, could be a homogeneous catalyst, which
`means, going back to my Ph.D., that would be a
`homogeneous catalyst, because it's all single atomic
`carbonyls.
` Heterogeneous catalyst is typically
`referred to as solid supported catalyst. And in this
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.017
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`18
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`particular case that you're referring to, the
`catalytic reactor used heterogeneous catalyst. So
`therefore, the reactor contained that solid material
`that was the catalyst used in expediting the
`reaction.
` This was looking at gasoline partial
`oxidation in particular, and in this case, the intent
`was to generate hydrogen, hence partial oxidation.
`And as close to the stoichiometric configuration of
`air and fuel to form maximum amount of hydrogen and
`no carbon.
` The choice between a catalytic reactor and
`a non-catalytic reactor is, in the case of a
`non-catalytic reactor, as was found prior to my
`involvement in this project, was the limitation on
`the air/fuel ratio, beyond which you would form a
`carbon. And with a catalyst, you can improve that
`performance without forming carbon.
` Q. Would it be correct to refer to a
`catalytic reactor as a fuel cell?
` MR. MARANDO: Object to form.
` THE WITNESS: No, although "fuel cell" is
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.018
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`09:23:45
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`kind of a strange term. I remember early on in fuel
`cell work, people who were familiar with vehicles and
`automobile racing referred to fuel cells as simply
`the reservoir for the fuel. And so that was pretty
`early on before people began understanding what fuel
`cells were, from the standpoint of electrolysis or
`electrochemistry.
` But this particular catalytic reactor and
`the partial oxidation would not be a fuel cell. It
`could be a feed to a fuel cell, because it provides
`the hydrogen for catalytic reaction in the fuel cell.
`BY MR. RASH:
` Q. And am I correct in reading this that you
`were working on the catalytic reactor during your
`time at Caltech at the Jet Propulsion Laboratory?
` A. Yes, this was one of the first projects
`after my post doc there. And this was a project
`initially directed toward use in automobile.
`Generating hydrogen and CO, both of which are
`combustible materials fed into the engine, IC engine.
`And the purpose was to allow the engine to run leaner
`than a typical gasoline air/fuel ratio would allow.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.019
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`20
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`Probably go to about 300 percent theoretical air.
`The idea was to reduce NOx in this particular case by
`running fuel lean.
` Q. And so during the period from 1974 through
`1990 that you referred to in your declaration, was --
`was that basically focused on -- or generally focused
`on catalytic reactor design?
` A. Catalytic reactor design -- excuse me --
`and primarily the catalysts associated with it. So
`it becomes integral in this particular case, because
`you want to be able to increase product formation,
`decrease temperature for materials purposes, as well
`as lifetime. And the catalyst lifetime is important.
`And so much of the work was oriented toward catalyst
`configuration. This, of course, overlaps into the
`engineering, fluid dynamics of the system, in order
`to reduce the back pressure. And again, improve the
`overall effectiveness of the reactor design.
` So it's a combination of chemistry of the
`fuel, chemistry of the catalyst, and the reaction
`mechanisms, the catalyst formulation, and the
`incorporation of the catalyst within the reactor, and
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.020
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`21
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`the reactor design, from the standpoint of thermal
`management of the system.
` Q. And when you used the term "fuel" there,
`are you referring to gasoline fuel?
` A. In this particular -- in the early work,
`it was gasoline. We looked at other fuels in the
`process of that, because partial oxidation had, we
`found, broader application than just the initial NASA
`project was directed toward. While that was toward a
`vehicle, and the controls associated with it, et
`cetera, from a system standpoint, overall system
`operation. It expanded into its application for
`aircraft and stationary sources, so it's a broader
`application.
` For example, if you were to apply this to
`stationery operation of a gas turbine for utilities,
`it allows you to also -- excuse me -- run leaner,
`more efficient. Give you a broader operating range
`of your turbine. And so it's -- we found -- and were
`funded subsequently by several different
`organizations as we pursued these various options of
`catalytic partial oxidation.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.021
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`09:29:25
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`09:29:29
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` Q. And when you say "aircraft," what type of
`aircraft are you referring to?
` A. Combination of piston and turbine. Again,
`as I mentioned -- and turbine. As I mentioned,
`turbine even with respect to utilities allows you the
`flexibility of a broader range of operation,
`efficiently. And so it's applicable to both.
` Q. Further down in the paragraph, do you see
`where you refer to catalytic systems for two-stage
`combustion for gas turbines?
` A. Yes.
` Q. What do you mean by a "two-stage
`combustion for gas turbines"?
` A. In that particular case -- excuse me -- if
`you -- if you look at operating, and it's very
`similar to what I mentioned earlier, in terms of
`partial oxidation, which is just air and fuel versus
`the use of a catalyst, you have a limit as to how far
`you can go before you begin to form gas phase carbon.
` And with a catalyst, you can change that
`range. So if you can operate your catalytic partial
`oxidation unit to give you a lower temperature,
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.022
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`23
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`maximum hydrogen production, and you can feed that
`into an engine, that allows the engine on -- which is
`operating near stoichiometric or right in that
`combustion region, to operate leaner and still
`efficiently, because your hydrogen and CO will change
`your flame speed, and therefore, your operating
`conditions of that engine.
` And so if you have, on the one hand,
`partial oxidation of some of the fuel to form a
`hydrogen-rich gas stream, and you feed that into the
`combustion chamber where your raw fuel and air is
`coming in, you can lean that out and reduce your NOx,
`for one thing. Operate more efficiently over a wider
`range of operation. "Turn down" is typically the
`term that's used.
` And so it gives you much greater
`flexibility in the operating conditions of the
`engine. So two-stage combustion means, on the one
`hand, partial oxidation, part of the fuel. That's
`the first stage of combustion, fed into the engine
`for then final second stage of combustion of the
`fuel.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.023
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
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` Q. And what type of application is that
`referring to, when you say a two-stage combustion for
`gas turbines?
` A. As I mentioned, that applies to virtually
`anything that has a turbine engine in it. As I
`mentioned, utilities and turbines used there.
`Airplanes. Missiles. Anything where a turbine is
`applied.
` Q. Was your work specific to any particular
`application?
` MR. MARANDO: Object to form. Go ahead.
` THE WITNESS: It was very broad. As I
`mentioned, we looked at -- as we got into it and
`found how much development we created in this
`project, that it had a broader application than the
`initial.
` The initial application was for what was
`called a NASA clean car project. And it was -- and
`this is before emission catalysts and so on that came
`later on in the vehicles. And the concern,
`particularly in California, was NOx. And by
`operating an engine in a fuel lean mode, you can
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.024
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`25
`
`09:33:52
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`reduce the overall NOx temperature operating
`conditions by operating leaner.
` That was the original intent. But as we
`developed the technology, we found that there were,
`as I mentioned, much broader applications of that.
`And so we looked at and were funded by several
`different agencies in order to pursue this, ranging
`all the way from engines even to fuel cells.
` I might add that we expanded that effort
`to include going beyond just partial oxidation, where
`you're using air and fuel only, to include steam
`which then became known as autothermal reforming.
`Autothermal reforming then allows you to be -- to
`operate and generate hydrogen in greater quantities
`more efficiently, because the total amount of air
`that's required and measured in diluent that you can
`reduce by using autothermal reforming.
` And so your hydrogen yield is much
`greater. You still have the benefits of rapid start,
`a wide range of operating conditions. These were all
`engineering advantages to generating hydrogen. So
`then the applicability expanded, as I mentioned
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2002.025
`
`
`
`Voecks, Dr. Gerald
`
`Case No. IPR2016-01301
`
`March 24, 2017
`
`09:35:47
`
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