1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`-----------------------------------x
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`TOYOTA MOTOR CORPORATION and
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`DENSO CORPORATION,
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` Petitioners, Case No.
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` vs. IPR2017-01497
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`INTELLECTUAL VENTURES II, LLC,
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` Patent Owner. Patent No. 7,067,952
`
`-----------------------------------x
`
` DEPOSITION OF GERALD JOHN MICKLOW, Ph.D.
`
` Washington, D.C.
`
` March 21, 2018
`
` 9:00 a.m.
`
`REPORTED BY:
`Tina Alfaro, RPR, CRR, RMR
`Job No. 53768
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`-----------------------------------x
`
`TOYOTA MOTOR CORPORATION and
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`DENSO CORPORATION,
`
` Petitioners, Case No.
`
` vs. IPR2017-01497
`
`INTELLECTUAL VENTURES II, LLC,
`
` Patent Owner. Patent No. 7,067,952
`
`-----------------------------------x
`
` DEPOSITION OF GERALD JOHN MICKLOW, Ph.D.
`
` Washington, D.C.
`
` March 21, 2018
`
` 9:00 a.m.
`
`REPORTED BY:
`Tina Alfaro, RPR, CRR, RMR
`Job No. 53768
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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`2
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` Deposition of GERALD JOHN MICKLOW, Ph.D.,
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`held at the offices of:
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` Finnegan Henderson Farabow Garrett &
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` Dunner, LLP
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` 901 New York Avenue, NW
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` Washington, D.C. 20001
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` Taken pursuant to notice before Tina M.
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`Alfaro, a Notary Public within and for the District
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`of Columbia.
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
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`
`
`GERALD JOHN MICKLOW, Ph.D.
`
`3
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` APPEARANCES:
`
` ON BEHALF OF INTELLECTUAL VENTURES II, LLC:
`
` MINTZ LEVIN COHN FERRIS GLOVSKY AND POPEO
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` One Financial Center
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` Boston, Massachusetts 02111
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` BY: PATRICK DRISCOLL, ESQ.
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` PTDriscoll@mintz.com
`
` ON BEHALF OF TOYOTA MOTOR CORPORATION:
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` FINNEGAN HENDERSON FARABOW GARRETT & DUNNER
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` 901 New York Avenue, NW
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` Washington, D.C. 20001
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` BY: TYLER AKAGI, ESQ.
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` tyler.akagi@finnegan.com
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` ON BEHALF OF DENSO CORPORATION:
`
` DLA PIPER
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` One Fountain Square
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` 11911 Freedom Drive, Suite 300
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` Reston, Virginia 20190
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` BY: GIANNI MINUTOLI, ESQ.
`
` gianni.minutoli@dlapiper.com
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
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`
`
`GERALD JOHN MICKLOW, Ph.D.
`
`4
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` APPEARANCES: (Cont'd)
`
` ON BEHALF OF HONDA MOTOR COMPANY:
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` STEPTOE & JOHNSON
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` 1300 Connecticut Avenue, NW
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` Washington, D.C. 20036
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` BY: LI GUO, Ph.D., ESQ.
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` lguo@steptoe.com
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
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`
`
`GERALD JOHN MICKLOW, Ph.D.
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`5
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` I N D E X
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` EXAMINATION
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` WITNESS PAGE
`
` GERALD JOHN MICKLOW, Ph.D.
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` By Mr. Driscoll 6
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` EXHIBITS
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` PETITIONER'S EXHIBITS PAGE
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` Exhibit 1006 54
` Nakahara patent
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` Exhibit 1015 46
` 169 Patent
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` Exhibit 1024 49
` Declaration
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
`
`6
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` (Witness sworn.)
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` WHEREUPON:
`
` GERALD JOHN MICKLOW, Ph.D.,
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` called as a witness herein, having been first duly
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` sworn, was examined and testified as follows:
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` EXAMINATION
`
` BY MR. DRISCOLL:
`
` Q. Good morning.
`
` A. Good morning.
`
` Q. It's good to see you again.
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` A. Good to see you too, sir.
`
` Q. How are you?
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` A. Quite well. Thank you.
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` Q. Thanks again for being here today.
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` A. You're welcome.
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` Q. Could you please state your full name for
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` the record.
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` A. Gerald John Micklow.
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` Q. Dr. Micklow, we covered this yesterday. So
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` I'm just going to remind you that I'm going to ask
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` you a series of questions. You should answer those
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` questions fully and completely to the best of your
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` ability unless, of course, counsel directs you not
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`7
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` to answer. Okay?
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` A. Yes.
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` Q. And, as you know, this conversation is
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` being transcribed and I ask that you provide your
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` answers verbally and if a question is not clear,
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` please let me know. Okay?
`
` A. Yes.
`
` Q. What's your understanding of why you're
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` here today?
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` A. I'm being deposed associated with a
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` declaration that I wrote in a matter between Toyota
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` Motor Company and Denso Corporation and Intellectual
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` Ventures.
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` Q. What is your understanding as to the nature
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` of your testimony today?
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` A. The nature of my testimony today is related
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` to a patent and I am presenting grounds to
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` invalidate that patent.
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` Q. Did you prepare for your testimony today?
`
` A. Yes, I did.
`
` Q. Did you prepare by yourself?
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
`
`8
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` A. Yes.
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` Q. When did you prepare by yourself?
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` A. I've been preparing for this for the last
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` several weeks.
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` Q. About how long would you say you prepared?
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` A. I don't have an exact hour figure, but like
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` I said, it's been ongoing on a part-time basis over
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` the last several weeks.
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` Q. Did you prepare with anyone?
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` A. Part of the time, yes.
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` Q. Who?
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` A. With the attorneys at Finnegan.
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` Q. And when was that?
`
` A. Several weeks ago I was here for two days,
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` and that was not the entire discussion for those two
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` days. And then three days prior to the sequence of
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` depositions I was here also to partially discuss
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` this testimony today.
`
` Q. Were those days full days?
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` A. Yes, they were, but as I stated, it was not
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` entirely emphasizing this particular declaration.
`
` Q. Did you review any documents as part of
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
`
`9
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` your preparation?
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` A. I reviewed the documents in my references,
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` yes.
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` Q. Did you discuss this matter or testimony
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` with anyone other than counsel?
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` A. No, I have not.
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` Q. Did you prepare your declaration?
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` A. Yes, I did.
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` Q. Did you prepare the first draft?
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` A. I prepared the rough draft, yes.
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` Q. How did you perform your patent invalidity
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` analysis in this case?
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` MR. AKAGI: Objection to form.
`
` BY THE WITNESS:
`
` A. Well, if I recall, discussing that with the
`
` attorneys because I'm not by any means a legal
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` expert associated with patent invalidity we chose
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` the grounds of being obvious.
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` Q. Did you find any of the references?
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` A. It's my knowledge -- my recollection that I
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` think the references were provided to me by counsel.
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` I don't recall at this point if I did supply any of
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` the references.
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` Q. Did you work with anyone besides counsel?
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` A. No, I did not.
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` Q. Did you receive any assistance from anyone
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` else?
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` A. Other than discussions with counsel, no, I
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` did not.
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` Q. About how much time did you spend preparing
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` your declaration?
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` A. Well, this has been -- when we initiated
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` discussions approximately one year ago we had
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` several telephone conversations and I began to
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` prepare the declaration in this matter and two other
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` matters and it was ongoing for two to three weeks,
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` and, if I recall, part of that time was when I was
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` off from the university. So I was probably putting
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` in anywhere from 20 to 40 hours per week at that
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` time.
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` Q. Do you know what a toroid is?
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` A. I think I know what it is, yes.
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` Q. What is it?
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` A. It will be a structure, a three-dimensional
`
`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` structure with a circular cross-section that
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` reproduces upon itself. That's the basic definition
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` that the Board came up with. My definition of a
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` toroid would be a repeating three-dimensional
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` structure which goes around -- goes essentially 360
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` degrees and comes back upon itself, and under that
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` definition I will have the opinion that it does not
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` have to be a circular cross-section.
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` Q. Do you know what a hexagon is?
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` A. Yes, I do.
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` Q. What is a hexagon?
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` A. It's a six-sided structure.
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` Q. So yesterday you told me that we -- that
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` you have disassembled and assembled hundreds of
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` electric motors, correct?
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` A. I would say over the last 40 years that's
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` probably a reasonable figure, yes.
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` Q. And you also told me that you've redesigned
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` electric motor components, correct?
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` A. I've substituted other bearings and issues
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` with rewinding stators, et cetera.
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` Q. And a component of an electric motor is a
`
`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
`
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` stator assembly, correct?
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` A. That's a component of a electric motor,
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` yes.
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` Q. And a stator assembly includes windings
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` wound around a stator, correct?
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` A. That's true, but in the general engineering
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` public I think that some may just say stator, some
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` may say stator assembly and have the same meaning.
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` I put the stator in the electric motor and they
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` won't necessarily say stator assembly, and under
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` that term it could include the windings also.
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` Q. Have you ever wound a stator?
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` A. Yes, I have.
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` Q. How many times?
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` A. 10, 20, 30 times over the last 40 years.
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` Q. What types of stators?
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` A. These were stators normally in electric
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` motors for laboratory applications or starter motors
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` for automobiles, things like that.
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` Q. Were any stators exterior-facing poles?
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` MR. AKAGI: Objection to form.
`
` BY THE WITNESS:
`
`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` A. I'm not saying that I have not, but I don't
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` recall any. So when you say "exterior-facing
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` poles," can you be more definitive, please.
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` Q. What does "exterior-facing pole" mean to
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` you?
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` A. It appears to be indefinitive to me. As I
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` sit here today, I'm thinking about it right now,
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` exterior-facing poles, I would need a more
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` definitive definition. If I just think about
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` exterior, I think it's on the exterior part of the
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` motor. So if they're exterior facing, then the next
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` question I would have to ask is what are they
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` facing?
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` Q. Maybe my terminology's a little off. Does
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` a stator have pole faces?
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` A. Yes, it does.
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` Q. And can those pole faces be on the exterior
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` side of the stator?
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` MR. AKAGI: Objection to form and
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` foundation.
`
` BY THE WITNESS:
`
` A. So if we're talking the radial direction,
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
`
` you're talking that it would be at a farther radius
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` than the center line of the motor?
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` Q. Correct.
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` A. Then the answer is yes, that could happen.
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` Q. Have you wound any stators with the pole
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` faces in the further radial direction?
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` A. Like I said, I don't recall any at this
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` point in time, but it may have happened over the
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` last 30 or 40 years. But I don't recall any at this
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` point in time.
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` Q. Can the pole faces be in the interior
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` radial direction?
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` A. Yes.
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` Q. Have you ever wound any stators with
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` interior-facing poles?
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` A. Yes.
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` Q. How many?
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` A. Those are the ones I said might have been
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` 20 or 30 times over the last 40 years or so. It
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` became cost ineffective after a certain point. So
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` probably 20 or 30 times.
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` Q. Did you wind those stators by hand?
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` A. Yes, I did.
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` Q. What tools did you use?
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` A. These were with inward-facing stator poles.
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` So these were just wound by hand around the stator
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` cores.
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` Q. Did you use any tools?
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` A. I had to have tools to disassemble the
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` electric motor, yes.
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` Q. About what size were these stators?
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` A. Physical size? You'd have to, once again,
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` be more definitive. So are we talking about the
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` physical size of the electric motor itself, the
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` power-producing capability of the electric motor?
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` Q. The physical size of the stator.
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` A. Of the stator itself? One inch.
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` Q. Typically how many pole teeth would these
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` stators have?
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` A. Well, it would depend upon the application.
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` So 4, 8, 12 could be there or even -- once again,
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` depends on the application.
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` Q. So about how long would it take you to hand
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` wind one of these stators?
`
`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` A. A long time. Depending on the number of
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` poles, we're talking about a day probably to do
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` that.
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` Q. Do you know if winding a stator can be done
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` by a machine?
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` A. Oh, most definitely it can be done by a
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` machine, yes.
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` Q. And how long would it take a machine to
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` wind a stator?
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` A. Well, we didn't have that available in our
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` laboratories, but it would be a lot less than a day.
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` Q. Do you know what a segmented stator is?
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` A. Yes, I do. At least I can interpret what
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` you're saying, yes.
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` Q. What's your understanding of a segmented
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` stator?
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` A. There would be different segments of the
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` stator which will be at a later point in time
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` somehow put together to form the entire stator.
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` Q. Have you ever wound a segmented stator?
`
` A. Not that I recall at this point in time,
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` no.
`
`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
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`GERALD JOHN MICKLOW, Ph.D.
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` Q. Have you ever seen a segmented stator
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` wound?
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` A. I'm trying to think if I've seen one
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` physically. I've seen them in the patents that I've
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` used as references for my declaration today.
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` Q. Have you ever seen one physically?
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` A. The answer's probably. I'd have to -- when
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` I look at what I've seen in the patents I'm familiar
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` with it, but I can't recall if I've seen one
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` recently, let's put it that way.
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` Q. So you don't recall today whether you've
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` seen one?
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` A. Yeah. I would have to think about it in
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` more detail. Most of the work that we were doing on
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` rebuilding the stators were probably 10 or 15 years
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` ago, and, like I said, it's more cost effective now
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` to just buy another motor.
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` Q. And why is that?
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` A. Because of the technology which comes into
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` this country from other countries.
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` Q. So if I understand you, it's cheaper to buy
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` a new motor than to spend a day winding a stator,
`
`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` correct?
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` A. Depends if it's my time or one of my
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` student's time.
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` Q. Fair enough.
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` Do you know what a bobbin is?
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` A. Yes, I do.
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` Q. What's your understanding of a bobbin?
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` A. It's part of the stator upon which you
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` would wrap the windings.
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` Q. Have you ever wound a bobbin for an
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` electric motor?
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` A. If we go along with the definition that I
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` just gave you, the answer would be yes.
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` Q. What are bobbins made out of?
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` A. Well, it's if a stator core, typically it
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` would be made out of a steel or iron composition.
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` Q. Have you ever redesigned bobbins in an
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` electric motor?
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` A. Well, I don't think I've redesigned them,
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` but I've re-encapsulated them with polymers and
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` stuff and switched out the polymers when we were
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` doing that. So I guess that could be considered
`
`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` redesigned.
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` Q. I want to make sure I understand. The
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` bobbins themselves are encapsulated; is that
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` correct?
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` A. Well, the core of the stator is normally
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` insulated from the windings. In the old days it was
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` paper and then before thermal plastic injection you
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` painted them with polymers or even paint, enamels.
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` Q. I think you defined bobbin as what you --
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` the part of the stator that you wind; is that
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` correct?
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` A. Like I said, I haven't used the term bobbin
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` before. I just normally talk about stator core. So
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` if I recall, one of the patents referred to the term
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` as bobbins and that's what I'm looking for as we
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` speak in my declaration. That's what I'm looking at
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` right now. I'm on page 28 of my declaration and I
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` see figure 3B, Nakahara, and he has figure 3B as the
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` coil bobbin.
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` Okay. On this one he's defining the coil
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` bobbins as being made of an insulated material.
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` Like I said, that material wasn't immediately
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` familiar to me, but now once I read my declaration,
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` Nakahara refers to the bobbins as the insulating
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` material, not the coil itself. It says "In general
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` Nakahara teaches that the coil bobbin should be made
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` of insulating material, but they need not be made of
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` resin."
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` Q. So applying that definition, have you ever
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` redesigned bobbins in an electric motor?
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` MR. AKAGI: Objection to the form.
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` BY THE WITNESS:
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` A. The ones that I rewound personally did not
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` have a bobbin as defined by Nakahara. However, as I
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` stated, we would paint them with polymers which
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` would essentially be the same as the insulating
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` features of the coil bobbin.
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` Q. When you say "paint with polymers," what do
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` you mean?
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` A. Well, there's -- you can go to a standard
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` electrical supply house and buy polymer material
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` that you can indeed paint the stator cores with.
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` There are different polymer materials to be able to
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` insulate the polymers from degeneration of the
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` wires. So you could do that or you could even paint
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` them with polymer paints in a spray can, et cetera,
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` depending on the detail that you want to put into
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` the redesign/rebuild of the electric motors.
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` Q. A polymer is an electrical insulator,
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` correct?
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` A. It's not an electrical insulator. The
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` polymers in this fashion are insulators for heat
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` generation by the wires. The wires themselves have
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` insulators on them.
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` Q. Would you agree that the polymers are
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` selected for their heat insulation properties?
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` MR. AKAGI: Objection to form.
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` BY THE WITNESS:
`
` A. That's why you're applying them, yes, and
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` also to protect the stator core from corrosion. So
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` that's another aspect of it. If you have either an
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` iron core or a steel alloy core, of course, they can
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` corrode and you can cover them with a polymer so
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` that you can cut down the corrosion of that material
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` also. Heat generated by the wires, corrosion of the
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` stator core are two things that come to mind
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` immediately.
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` Q. Is a polymer a resin?
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` A. A resin can be a polymer, yes. A polymer
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` doesn't have to be a resin, but -- well, normally a
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` resin is chemically treated to create a polymer. So
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` you can do it organically -- or you can take an
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` organic resin or a synthetic resin and you can
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` convert it to a polymer.
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` Q. Is a polymer a thermoplastic?
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` A. A polymer can be a thermoplastic, yes.
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` Q. Is a polymer a phase change material?
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` A. A polymer can be a phase change material,
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` yes.
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` Q. Are there any other factors that you would
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` consider when selecting a polymer material?
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` MR. AKAGI: Objection, form and foundation,
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` scope.
`
` BY THE WITNESS:
`
` A. There could be many other things that I
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` could think of when you're talking about the
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` selection of a polymer.
`
` Q. Have you ever conducted performance testing
`
`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` on an electric motor?
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` A. Yes, I have.
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` MR. AKAGI: Give me time to object, please.
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` THE WITNESS: I'm sorry.
`
` BY MR. DRISCOLL:
`
` Q. Who did you perform that testing for?
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` A. Part of it was for my own benefit. I don't
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` think I officially did it for pay. So it was
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` associations with a company that I have been hired
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` as a consultant to look at the effectiveness of
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` different lubricants.
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` Q. When was that?
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` A. When we were doing that work it was in a
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` wind tunnel application that we had actually built
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` when I was at the University of Florida and we had
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` selected electric motors. We were looking to
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` improve the performance of those motors to be able
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` to get a higher velocity in the tunnel. So I'm
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` thinking that must have been in 1990, '91, '92, '93,
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` et cetera. We had a very limited budget creating a
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` subsonic wind tunnel. We were doing performance
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` aspect testing of the motors which were available to
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` us at that time.
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` Q. What were those performance tests?
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` A. Well, we were doing before and after tests
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` with the lubrication on the bearings inside of the
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` motor. So we were -- we had amp cages on the wires
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` coming into the motor, we were looking at current
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` draw from the motor --
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` THE REPORTER: I'm sorry. We were looking
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` at --
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` BY THE WITNESS:
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` A. We had engineering equipment to be able to
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` measure the current draw on the motor, voltage input
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` to the motor, and also we had temperature guns to
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` look at the temperature distribution on the motors
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` too. So we did before and after testing with
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` different lubricants which were available to be able
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` to improve the -- increase the velocity of the air
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` in the wind tunnel. So we did this over a period of
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` a couple weeks, disassembling the motor and making
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` sure everything was correct, reassembling, injecting
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` different lubricants into the bearings to look at
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` performance associated with the air velocity in the
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` wind tunnel.
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` Q. Do you recall the different lubricants you
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` were using?
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` A. Well, they were all from one particular
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` company except for the initial lubricant which was
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` recommended by the manufacturer.
`
` Q. Have you ever performed any stress testing
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` on an electric motor?
`
` MR. AKAGI: Objection, form; objection,
`
` scope.
`
` BY THE WITNESS:
`
` A. Well, we've looked at failure modes of
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` electric motors and they've failed because of -- one
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` of the reasons is because of stress, but only
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` cursory engineering analysis on that. In fact, it's
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` ongoing right now. We are utilizing a motor drive
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` with a very high-pressure pump in one of my research
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` projects, and we are concerned with the loads we're
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` putting on the motor to drive that pump. So, you
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` know, even as much as two weeks ago we were making
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` load calculations on the electric motor to drive the
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` pump. So it's an ongoing thing that happens over
`
`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
`
`26
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` years where you investigate failures of your
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` electric motors. Like I said, just several weeks
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` ago we were doing side loading on the motor to run a
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` very high-pressure pump for a very special
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` application.
`
` Q. And what do you mean by a stress test?
`
` MR. AKAGI: Objection, form, scope,
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` foundation.
`
` BY THE WITNESS:
`
` A. Well, a stress test can be many different
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` things. A very basic stress test would be is the
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` engine going to fail or not if we do certain load
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` applications on it. So it can be experimental
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` testing, it can be computational testing, but one of
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` the things that you normally do when you're doing
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` motor selection is to look at the loads on the motor
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` and then, of course, you're looking at stresses of
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` the electric motor for the application upon which
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` it's intended. So that's one of the first things
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` that you would do and I would consider that to be a
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` stress test.
`
` Q. Have you ever performed testing for heat
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`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
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` dissipation on an electric motor?
`
` A. One more time, please. I missed the last
`
` word.
`
` Q. Have you ever tested an electric motor for
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` heat dissipation?
`
` A. Actually, as I stated a moment ago, we were
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` looking at temperature distributions in these
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` electric motors when we were looking at the
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` different lubricants that we were using inside of
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` the motor, and we were shooting with temperature
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` guns and looking at how the temperatures in the
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` bearings and the housing changed as a function of
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` the lubricant being used. So yes, we were doing
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` tests associated with heat dissipation.
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` Then we could even take that another step
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` further too because when we're talking about hard
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` drives in the old days when we used to do high-
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` performance computational work and we were working
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` with IBM and Silicon Graphics on some of their most
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` advanced workstations that they had available --
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` MR. AKAGI: Dr. Micklow, you need to slow
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` down for the court reporter trying to keep up with
`
`DAVID FELDMAN WORLDWIDE, INC. - A VERITEXT COMPANY
`330 Old Country Road - Ste. 300, Mineola, NY 11501 1.800.727.4396
`
`
`
`GERALD JOHN MICKLOW, Ph.D.
`
`28
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` you.
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` BY THE WITNESS:
`
` A. And so we were running into problems with
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` the hard drives. So this is back in the day and I'm
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` smiling because we started computational fluid
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` dynamics and doing some of the most advanced
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` calculations in the world and this gets right down
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` to heat dissipation, because we were working then --
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` nowadays you can buy a computer for a thousand,
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` $2,000 and that's a lot of money. These machines,
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` which were being donated to my research program from
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` IBM and Silicon Graphics, were between 2- and
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` $300,000 each and when we ran numerical intensive
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` computing upon them they would overheat. In the
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` middle of a computation they would go down and we
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` would lose three days of computational work.
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` So we would open up the case on them, we
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` would bring fans in and blow fans across the hard
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` drives on these machines to look at the heat
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` dissipation, and we had temperature guns in there
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` looking at the temperature gradients. So we were
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` working directly with IBM, particularly with IBM,
`
`DAVID FEL
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