U N I T E D S T A T E S P A T E N T A N D T R A D E M A R K O F F I C E
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` B E F O R E T H E P A T E N T T R I A L A N D A P P E A L B O A R D
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` C A T E R P I L L A R , I N C .
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` P e t i t i o n e r
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` v .
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` W I R T G E N A M E R I C A , I N C .
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` P a t e n t O w n e r
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` C a s e I P R 2 0 1 8 - 0 1 0 9 1
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` P a t e n t 8 , 3 0 8 , 3 9 5
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` D E P O S I T I O N O F R A L P H V . W I L H E L M , P H . D .
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` W a s h i n g t o n , D . C .
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` T h u r s d a y , M a y 3 0 , 2 0 1 9
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` 9 : 0 0 a . m .
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`J o b N o . : P A 3 4 0 3 8 9 6
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`P a g e s 1 - 9 8
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`R e p o r t e d B y : J o a n V . C a i n
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`CATERPILLAR EXHIBIT 1048
`CATERPILLAR v. WIRTGEN
`IPR2018-01091
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` B E F O R E T H E P A T E N T T R I A L A N D A P P E A L B O A R D
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`Page 1
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` C A T E R P I L L A R , I N C .
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` P e t i t i o n e r
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` v .
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` W I R T G E N A M E R I C A , I N C .
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` P a t e n t O w n e r
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` C a s e I P R 2 0 1 8 - 0 1 0 9 1
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` P a t e n t 8 , 3 0 8 , 3 9 5
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` D E P O S I T I O N O F R A L P H V . W I L H E L M , P H . D .
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` W a s h i n g t o n , D . C .
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` T h u r s d a y , M a y 3 0 , 2 0 1 9
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` 9 : 0 0 a . m .
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`J o b N o . : P A 3 4 0 3 8 9 6
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`P a g e s 1 - 9 8
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`R e p o r t e d B y : J o a n V . C a i n
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`CATERPILLAR EXHIBIT 1048
`CATERPILLAR v. WIRTGEN
`IPR2018-01091
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`Page 1 of 118
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` Deposition of RALPH V. WILHELM, PH.D., held
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`at the law offices of:
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` STERNE KESSLER GOLDSTEIN & FOX, PLLC
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` 1100 New York Avenue, Northwest
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` Suite 600
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` Washington, D.C. 20005
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` (202) 371-2600
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` Pursuant to Notice, before Joan V. Cain,
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`Court Reporter and Notary Public in and for the
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`District of Columbia.
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` A P P E A R A N C E S
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`Page 3
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` O N B E H A L F O F P E T I T I O N E R :
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` C H R I S T O P H E R P . I S A A C , E S Q U I R E
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` F I N N E G A N H E N D E R S O N F A R A B O W
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` G A R R E T T & D U N N E R , L L P
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` T w o F r e e d o m S q u a r e
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` 1 1 9 5 5 F r e e d o m D r i v e
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` R e s t o n , V A 2 0 1 9 0 - 5 6 7 5
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` T e l e p h o n e : ( 5 7 1 ) 2 0 3 - 2 7 0 0
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` E - m a i l : c h r i s . i s a a c @ f i n n e g a n . c o m
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` O N B E H A L F O F P A T E N T O W N E R :
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` J A S O N A . F I T Z S I M M O N S , E S Q U I R E
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` R I C H A R D D . C O L L E R , I I I , E S Q U I R E
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` S T E R N E K E S S L E R G O L D S T E I N & F O X , P L L C
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` 1 1 0 0 N e w Y o r k A v e n u e , N o r t h w e s t
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` S u i t e 6 0 0
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` W a s h i n g t o n , D . C . 2 0 0 0 5
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` T e l e p h o n e : ( 2 0 2 ) 3 7 1 - 2 6 0 0
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` E - m a i l : j f i t z s i m m o n s @ s t e r n e k e s s l e r . c o m
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` r c o l l e r @ s t e r n e k e s s l e r . c o m
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` C O N T E N T S
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`EXAMINATION OF RALPH V. WILHELM, PH.D. PAGE
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` By Mr. Isaac 5, 90
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` By Mr. Fitzsimmons 89
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`PREVIOUSLY MARKED EXHIBITS REFERENCED
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` (Retained by Counsel.)
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`EXHIBIT 1001 U.S. Patent No. 8,308,395 59
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`EXHIBIT 1005 U.S. Patent Application 69
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` Publication No. US
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` 2002/0154948 A1
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`EXHIBIT 2004 Declaration of Ralph V. 34
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` Wilhelm, Ph.D. in Support
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` of Patent Owner's Response
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` and Contingent Motion to
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` Amend
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` P R O C E E D I N G S
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` RALPH V. WILHELM, PH.D.
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`having been duly sworn under penalties of perjury by
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`the Notary Public, was examined and did testify as
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`follows:
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` EXAMINATION BY COUNSEL FOR PETITIONER
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`BY MR. ISAAC:
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` Q Dr. Wilhelm, my name is Chris Isaac. I'm
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`with the Finnegan law firm who represents
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`Caterpillar.
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` Do you understand that we're here today to
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`take your deposition in -- relating to a declaration
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`you filed in an IPR on the '395 patent?
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` A Yes, I do.
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` Q Okay. Have you had your deposition taken
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`before?
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` A Yes, I have.
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` Q Can you tell me about how many times?
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` A This will be my ninth deposition.
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` Q At this point in time, how much of your
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`professional time is -- percentage-wise is devoted
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`to experting in legal matters?
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` A This year it's about 90 percent of my
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`working time. The previous years it's quite
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`different. If I went back two years, it would be
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`flip-flopped, and the majority of my work would have
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`been then typical consulting with suppliers,
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`automotive.
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` Q How many times have you acted as a
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`consultant or an expert in connection with the
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`Sterne law firm?
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` A With Sterne? This is the first case.
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` Q Can you tell me how you came about to be
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`engaged on this matter?
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` A I was approached by an attorney Wade Sims
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`from the Patterson law firm.
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` Q What did Mr. Sims say?
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` A He wanted to know -- I think it was by
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`e-mail -- if I could talk, and he had a case he'd
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`like to discuss with me, and we had a discussion on
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`the phone, and I corresponded with him by e-mail.
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` Q And what was the nature of that
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`correspondence?
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` A It was the nature of, yes, I'd be glad to
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`be interviewed for the case.
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` Q And did you ultimately get interviewed for
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`the case?
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` A Yes, I did.
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` Q And who interviewed you?
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` A The two gentlemen to my right from Sterne
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`Kessler I believe were on the phone. Those are the
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`only two I can recall the names.
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` Q Then you were retained after a phone call?
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` A Yes, sir.
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` Q What did you do to prepare for today's
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`deposition?
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` A For the deposition, I read -- reread the
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`deposition [sic] a number of times, referred to a
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`number of the references that are referred to in
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`there and had conversations with the legal team.
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` Q Who's the legal team?
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` A Ed Patterson and also add -- but primarily
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`add Sterne Kessler.
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` Q So it's Mr. Coller and Mr. Fitzsimmons, and
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`then who else?
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` A Trevor.
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` Q Trevor, the gentleman that was in here when
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`I came in?
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` A Yes, sir.
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` Q He's with what firm?
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` A Yes, sir.
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` Q No. I'm sorry. He's with what firm?
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` A I'm sorry. He's with Sterne Kessler.
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` Q He's with Sterne Kessler. Okay. So did
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`you meet with lawyers in preparation for today's
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`deposition?
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` A Yes, I did.
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` Q And when did you meet with those lawyers?
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` A I met with the lawyers on Tuesday and
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`Wednesday of this week.
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` Q Were they full-day meetings?
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` A Tuesday was a little more than a half-a-day
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`meeting, and Wednesday was a full-day meeting.
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` Q When you talked about reading the
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`materials, the preparation for the deposition, was
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`that done in connection with the day-and-a-half
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`meetings, or did you do that on your own prior to
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`those meetings?
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` A Both.
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` Q Okay. So how much time have you devoted --
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`I have your declaration that you filed in the case,
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`which is dated March 9th of 2019. So that would be
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`this year. How much time have you spent between the
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`time you submitted this declaration and today's date
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`working on this matter?
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` A Up until this morning, a bit over 50 hours.
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` Q That would be 50 hours during that window,
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`though? I just want to be clear.
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` A Yes, sir.
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` Q Okay. Okay. How much time did you spend
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`prior to that? And what I mean is, how much time
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`did you spend preparing and drafting your
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`declaration?
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` A A bit more than 70 hours.
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` Q So you have about 120 hours total?
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` A Roughly, yes.
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` Q Okay. You've been deposed roughly nine
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`times, right?
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` A This will be my ninth deposition, yes.
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` Q Do you understand that I'm here to ask
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`questions and you're here to answer them to the best
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`of your abilities?
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` A Yes, I do.
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` Q Is there any reason you cannot give
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`truthful, comprehensive answers today due to, for
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`example, medication or a health condition?
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` A Not to my knowledge, no.
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` Q Okay. All right. So let's talk about your
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`background a little bit, Dr. Wilhelm. Do you have
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`any academic education in connection with milling
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`machines?
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` A I have academic education with regard to
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`control systems that have general application to
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`machine systems, but, no, with respect to milling
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`machines I do not.
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` Q So you have no specific experience --
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`academic experience with milling machines, correct?
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` A Yes.
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` Q You said you had experience with control
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`systems --
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` A Yes.
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` Q -- that were -- did you say applicable to
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`milling machines?
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` A Generally, control systems are generically
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`set up with sensor inputs and computers and
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`actuators sometimes that are closed loop, sometimes
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`open loop, and actually sense surroundings and
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`actually control various parts of the system.
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` Q Okay. So the control systems that you've
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`just described, what machines were they used on when
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`you worked with them?
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` A Those systems were primarily automotive or
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`vehicular.
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` Q Okay. So automotive, cars. Vehicular,
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`what does that mean? Is that broader than cars?
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` A Yes, it is.
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` Q How much broader?
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` A It would include control systems for, for
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`example, a Segway that you've probably seen police
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`ride in the street.
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` Q I've driven them.
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` A Okay. Good. Or it would include heavy
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`trucks like 18-wheelers for infotainment and
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`telematic systems that go into -- for the
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`Freightliner company.
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` Q Okay. So those control systems that you've
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`worked on for those vehicles, would they also have
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`potential applicability in, for example, road
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`construction machines?
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` A In terms of the art of road milling
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`machines, no, they do not.
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` Q You have no experience with control systems
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`that would be applicable to road milling machines?
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` A I have control experience, but not
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`specifically with road milling machines, correct.
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` Q Right. I understand you have -- I
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`understand you've worked with control systems for
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`automotive and vehicles, but my question is: Do you
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`have any experience, academic experience -- let's
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`start with that -- any academic experience in
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`control systems that have applicability to road
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`milling machines?
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` A No, I do not.
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` Q Okay. Do you have any non-academic
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`experience in connection with control systems that
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`would have applicability to road milling machines?
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` MR. FITZSIMMONS: Objection, form.
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` THE WITNESS: None that I'm aware of, no.
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`BY MR. ISAAC:
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` Q Have you ever worked in the field of road
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`milling machines?
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` A I have self-educated in terms of reading
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`documents and visiting the Antioch facility that
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`Wirtgen has, but, no, I have not worked, per se.
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` Q Okay. So leaving aside what you describe
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`as your self-education, also described that way in
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`your declaration --
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` A Yes.
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` Q -- leaving that aside, do you have any
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`experience working in the field of road milling
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`machines?
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` A No, I do not.
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` Q Okay. Have you ever designed a road
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`milling machine?
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` A No, I have not.
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` Q Have you ever operated a road milling
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`machine?
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` A Define operate, please.
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` Q Basically milled the road.
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` A No, I have not milled a road.
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` Q Do you have a different definition of
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`operation that maybe would say you did it?
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` A No. That is correct. I have not operated
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`a road milling machine.
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` Q Okay. Do you have any experience in
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`operating or designing motor graders?
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` MR. FITZSIMMONS: Objection, form.
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` THE WITNESS: No, I do not.
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`BY MR. ISAAC:
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` Q Do you have any experience in operating or
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`designing pavers?
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` A No, I do not.
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` Q Do you have any experience in operating or
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`designing compactors?
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` MR. FITZSIMMONS: Objection, form.
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` THE WITNESS: No, I do not.
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`BY MR. ISAAC:
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` Q Do you have any experience in operating or
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`designing any type of control systems for the
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`machines we've just discussed?
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` MR. FITZSIMMONS: Objection, form.
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` THE WITNESS: The previous list of machines
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`that you itemized? No, I do not.
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`BY MR. ISAAC:
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` Q Okay. How many times have you actually
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`inspected a road milling machine?
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` A Up close I've -- with my trip to Antioch,
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`over a couple of hours on that one trip.
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` Q Okay. So just the one time. I'm going to
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`leave aside, you know, driving by a road
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`construction site and just seeing it off to the
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`side.
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` So leaving those types of experiences
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`aside, is it true that you've inspected a road
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`milling machine just one time?
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` A On one day for approximately 2 hours or a
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`bit more, yes. Correct.
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` Q And that machine was located where?
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` A Antioch.
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` Q When you say Antioch, that's --
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` A I'm sorry. Tennessee.
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` Q Okay. Was it a Wirtgen facility?
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` A Yes, it was.
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` Q And when you inspected that machine, did it
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`actually mill the road?
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` A It was not milling the road, no.
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` Q Was it milling anything? Was it a parking
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`lot or something? Was it milling anything?
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` A It was in the parking lot. It was turned
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`on, but, no, it was not milling.
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` Q It was turned on. Was the rotor engaging
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`the surface?
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` A It was electrically turned on.
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` Q Okay. But I just want to be clear. The
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`rotor wasn't engaging the surface? There was no
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`milling that was going on; is that true?
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` A The milling drum was not turning, to my
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`knowledge. I didn't examine it, but I would expect
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`it was not turning.
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` Q You didn't notice if the milling drum -- is
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`that what you're saying: You didn't notice that the
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`milling drum was turning?
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` A I didn't look at the milling drum, no.
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` Q Okay. Who accompanied you to your visit to
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`the Wirtgen facility in Tennessee?
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` A Three lawyers from Sterne Kessler and a
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`lawyer from Patterson Intellectual Law, and we met
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`with an instructor and trainer and operator of the
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`milling machines at Wirtgen.
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` Q Okay. You say an instructor, trainer, and
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`operator. Is that one person that does all three,
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`or are those three different people?
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` A No. It's one person.
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` Q Okay. Who is that person?
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` A I don't know his name. I've forgotten.
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`visit?
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` A No, I did not.
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` Q The four lawyers that were with you, was it
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`Mr. Fitzsimmons?
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` A Yes.
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` Q Mr. Coller?
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` A Yes. Trevor.
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` Q Which Trevor? Do you know Trevor's last
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`name?
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` A I've just forgotten it. I'm sorry.
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` Q That's all right. And the fourth lawyer
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`was from Patterson?
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` A Yes.
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` Q Do you know his name or her name?
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` A His name, Gary -- I've lost his last name.
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` Q I think I know who you mean. We expected
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`to see him here today. Okay. So those four lawyers
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`were with you the entirety of your visit to the
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`Wirtgen facility in Tennessee?
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` A To my memory, yes, they were.
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` Q Okay. All right. Can you describe for me
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`what you did during your visit to the Wirtgen
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`facility?
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` A We met in the Patterson office for a while
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`discussing this case but also primarily discussing
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`road milling machines. We also then took the trip
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`and spent the two-plus hours at the Wirtgen facility
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`and went into the facility at first and then found
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`the trainer/operator, and he escorted us to one of
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`the large road milling machines.
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` And we had a very long discussion outside
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`walking around the road milling machine, but
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`primarily looking and discussing the Level Pro,
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`L-E-V-E-L P-R-O, control system that was located on
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`the side of the road milling machine that is very
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`typical and very close to the '395 patent claims.
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` We had discussions about various control
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`mechanisms and buttons and displays. Also ample
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`discussions about the way the machine operated, both
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`the operator on the ground working with the Level
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`Pro and the operator at the top of the machine that
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`was looking forward and driving the machine and
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`worrying more about not just driving it, but also
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`the dump trucks and the chute and other functions at
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`the top.
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` We spent time, not just with the trainer at
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`the side of the machine with Level Pro, but also
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`climbed up to the top and were able to see the
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`duplicate controls, among other controls, at the top
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`of this road miller. With road milling operation,
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`there are quite a number of different screens on a
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`display that can not only show video forward and aft
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`and to the side, but also can show diagnostics and a
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`number of other type screens that came up to help
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`inform the driver.
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` Q Okay. I want to go back to ask you a few
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`questions about what you just described. You said
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`that the Level Pro was close to or typical of the
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`'395 patent.
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` Was that accurate? Did I understand that
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`correctly?
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` A Yes. That's correct.
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` Q Do you have an opinion whether or not the
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`'395 patent covers the Level Pro system?
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` MR. FITZSIMMONS: Objection, scope.
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` THE WITNESS: I haven't formed an opinion
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`on that, no.
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`BY MR. ISAAC:
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` Q Okay. And you said you met at the -- let's
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`go back to the beginning.
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` You met at the Patterson law office. Do
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`they have a law office in Tennessee right next to
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`the Wirtgen facility?
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` A Yes. Nashville, yes.
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` Q Nashville, okay. Then you drove to the
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`Wirtgen facility, right?
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` A Yes, sir.
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` Q Then you spent two hours there talking with
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`this single person that you characterize as an
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`instructor or trainer or an operator, right?
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` A He's primarily a trainer, but he is an
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`operator. He began as a worker and an operator, but
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`now he is primarily a trainer to train their
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`customers in the use of that road milling machine.
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` Q And you don't know that person's name?
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` A I don't. I did at one point; I don't now.
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` Q And the lawyers that you described that
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`accompanied you on this trip, were they with you
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`during the two-hour inspection of the Wirtgen
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`machine?
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` A Yes, they were.
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` Q Okay. And did they get involved in asking
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`questions of the operator in discussion with you?
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` A Some, but most of the discussion was
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`between me and the trainer.
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` Q You characterized, in your declaration,
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`that trip to the Wirtgen facility as part of your
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`what you call self-education; am I correct?
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` A Yes, sir.
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` Q Okay. I characterize that as Wirtgen
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`education. Is that a fair assumption? Is that a
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`fair characterization?
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` MR. FITZSIMMONS: Objection.
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`Mischaracterizes the witness's testimony.
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` THE WITNESS: I wouldn't characterize it as
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`Wirtgen. I would characterize it as road milling
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`machines because we not only talked about Wirtgen
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`machines, but we occasionally talked about what
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`other machines might have done at the current time.
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`We also talked about what was on road milling
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`machines prior to the '395 patent, for example, and
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`what had changed over the decades prior to that.
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`BY MR. ISAAC:
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` Q Okay. But the information that was
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`provided to you all came from a Wirtgen employee; is
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`that correct?
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` A Are you talking about on that site trip?
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` Q Yes, sir. Yes, sir.
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` A On that site trip, I believe that to be
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`true.
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` Q Okay. Now, in addition to that part of
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`your education, you also did what else to prepare
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`yourself to render an opinion in this matter?
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` A Besides reading prior art and references
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`and reading and writing the declaration, we also
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`spent time, for example, with some of the art
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`reading the asphalt reclamation manual and also the
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`Wirtgen manual for control.
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` Q Okay. So the two manuals that you identify
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`in your declaration?
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` A That's correct.
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` Q Is there anything in the Wirtgen manual
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`that informed your opinion that you rendered in this
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`case?
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` MR. FITZSIMMONS: Objection, form.
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` THE WITNESS: It informed me in terms of
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`the way that the Level Pro and the -- specifically
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`the design of how to switch sensors in and out of
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`the machine control system worked. It informed me
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`quite a bit about how road milling machines operate.
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`BY MR. ISAAC:
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` Q Okay. So I just want to be clear. Your
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`opinion in this case was influenced by your view of
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`how the Wirtgen machine switched sensors?
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` A Among other things, yes.
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` Q Okay. Okay. Was there anything in the
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`asphalt manual that informed your opinion in this
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`case?
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` MR. FITZSIMMONS: Objection, form.
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` THE WITNESS: Much more in terms of
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`background and understanding the art of road milling
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`and the issues with regard to reclamation and
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`recycling of asphalt. For example, the demands on
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`road milling machines and how in, particularly road
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`construction, the use of the art of a road milling
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`machine is -- how critical it was to actually get a
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`road done well and milled well given the different
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`artifacts that would appear in general in using the
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`construction equipment.
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`BY MR. ISAAC:
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` Q Okay. So your education that we've talked
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`about thus far includes your inspection at the
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`Wirtgen facility, your review of the two manuals; am
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`I correct?
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` A It also includes my conversation with the
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`trainer.
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` Q I intended to include that with the
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`inspection trip. Okay. So are we in agreement that
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`so far that's what we've talked about as far as what
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`your education was that led to your opinion in this
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`case?
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` A Yes, including talking to the one specific
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`lawyer at the Patterson Intellectual Law firm that I
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`had quite a bit of experience with Wirtgen and also
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`road milling machines.
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` Q Okay. All right. And that's the
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`individual -- that's Gary?
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` A Yes.
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` Q Okay. And you relied in part on what Gary
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`told you when you were forming your opinion in this
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`case?
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` A Yes.
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` Q Okay. You also reviewed the Schmidt
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`declaration that was submitted in this case; is that
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`correct?
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` A Yes, I did.
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` Q Okay. If there is something in the Schmidt
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`declaration that is incorrect as far as the amount
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`of sensor faults that are encountered, would that
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`change your opinion?
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` MR. FITZSIMMONS: Objection, calls for
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`speculation.
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` THE WITNESS: Could you ask the question
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`another way?
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`BY MR. ISAAC:
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` Q Okay. The Schmidt declaration talks about
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`sensor faults and how often they occur. Did you
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`rely upon that in forming your opinions in this
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`case?
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` A I believe that Mr. Schmidt talked about
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`sensor failures. Is that what you mean?
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` Q Yes. I used the word "fault." Did that
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`throw you?
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` A Sorry.
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` Q Okay. That's all right. Let me go back
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`and rephrase it then. Mr. Schmidt talks about
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`sensor failures and how often they occur.
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` A Yes.
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` Q Did that inform your in this case?
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` A It informed my opinion because of my
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`background -- my background in terms of running
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`design groups to design control systems and sensors
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`and transducers that are applicable in the
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`automotive industry, vehicular industry that are
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`required to last at least 100,000 miles and roughly
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`ten years. And when I looked at the design of the
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`sensors specifically and the connections and the
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`umbilical cords, et cetera, on the road milling
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`machine and read Mr. Schmidt's declaration, it fit
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`very much with what my experience has been in
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`designing robust systems for use for heavy equipment
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`and also for heavy use over a long period of time.
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` Q I want to go back and ask the question
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`again and see if I can get just a yes or no from
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`you, Dr. Wilhelm.
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` The question was: Mr. Schmidt talks about
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`sensor failures and how often they occur in his
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`declaration. Did that testimony inform your opinion
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`in this case?
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` MR. FITZSIMMONS: Objection, asked and
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`answered.
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` THE WITNESS: I can't give you a straight
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`yes or no. It informed my opinion, but I already
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`had an opinion, looking at the road milling machines
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`and also realizing how rugged and how difficult that
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`application is. So it lined up with my opinion that
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`if I was responsible for designing control systems
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`and sensors and actuators for road milling machines,
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`I would use my approach in the vehicular design
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`area.
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`BY MR. ISAAC:
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` Q But Mr. Schmidt's declaration went to how
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`often sensors fail and what happens when sensors
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`fail in the road milling context. Now, in those
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`areas, you had no prior experience, right?
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` A That's not necessarily correct, no. With
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`regard to road milling machines I don't. With
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`regard to heavy-duty and high-use and the design of
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`systems for vehicular machines, heavy-duty equipment
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`like Freightliner trucks and/or vehicular traffic, I
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`have quite a bit of experience with regard to how
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`you design actuators and sensors and
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`interconnections.
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` For what it's worth, the major failing
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`point primarily in vehicles is -- electrically is
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`the fact that connectors and sensors fail, and
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`that's where so much effort goes in in order to make
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`entire vehicles so robust. And when I saw the road
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`milling machine and also read Mr. Schmidt's
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`application [sic], I felt that it was very similar
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`to what my background was.
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` Q Mr. Schmidt gives opinions as to what
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`occurs in road milling when a sensor fails. He
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`provides opinions as to road -- for example, the
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`road milling operations stop. Did you have any
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`experience at all in that area?
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` A Yes, unfortunately I have.
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` Q Okay. You've had experience in a situation
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`where in a road milling operation a sensor fails,
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`what happens next?
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` A No. My experience is with equipment that's
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`similar, but with vehicular designs and having
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`sensors fail in a vehicle, whether it's heavy-duty
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`or not, not in a road milling machine.
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` Q What equipment is similar to road milling
`
`machines?
`
` A Heavy-duty trucks are very similar,
`
`heavy-duty vans where the expectation is that
`
`they're going to last for ten years.
`
` Q Is that because they work in the same
`
`general environment of construction?
`
` MR. FITZSIMMONS: Objection, form.
`
` THE WITNESS: No. It's because they're
`
`used for -- by untrained operators who push vehicles
`
`and they test the design of equipment.
`
`BY MR. ISAAC:
`
` Q So the problems that occur with control
`
`systems and sensors in the environments you just
`
`described, which are heavy-duty trucks for example,
`
`those same problems occur in road milling machines
`
`you believe?
`
` MR. FITZSIMMONS: Objection to form.
`
` THE WITNESS: I wouldn't generalize it like
`
`that. I would suggest that sensor failures occur in
`
`both areas, both areas of endeavor, and in both
`
`areas strive very hard to design systems such that
`
`failures are few and far between because of the
`
`costs of those systems and because of the
`
`expectations of their customers.
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`Page 27 of 118
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`BY MR. ISAAC:
`
` Q Well, it sounds to me like -- correct me if
`
`I'm wrong, but it sounds like the sensor failure
`
`situations that you've encountered in your
`
`background are similar to the sensor failure
`
`situations that occur in road milling. Is that what
`
`you're saying?
`
` A I'm saying that my background has informed
`
`me and, in effect, biased me in terms of the
`
`requirements that are needed for the robust design
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`of sensors, transducers, actuators for vehicular
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`traffic that's designed to last a long time.
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` Q Okay. So let me go back to not talking
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`about sensor failure, per se, but what happens when
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`a sensor failure o
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