Gregory W. Davis, Ph.D. - April 14, 2021
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________
`BAYERISCHE MOTOREN WERKE )
`AKTIENGESELLSCHAFT and
`)
`BMW OF NORTH AMERICA,
`)
`LLC,
`
`))
`
` vs.
`
` Case
`Petitioners, ) IPR2020-01299
`)
`) Patent 8,630,761
`)
`PAICE LLC and THE ABELL )
`FOUNDATION, INC.,
`)
`)
`)
`Patent Owners.
`____________________________)
`
`The Virtual Deposition of
`
`GREGORY W. DAVIS, Ph.D.
`
`Date: April 14, 2021
`
`The virtual deposition of GREGORY W. DAVIS,
`
`Ph.D., called by the Patent Owners for examination,
`
`pursuant to the applicable rules, taken
`
`stenographically by Sandra L. Rocca, CSR, RMR, RDR,
`
`CRR, on the 14th of April, 2021, at the hour of
`
`9:00 a.m.
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`PAICE 2034
`BNW v, Paice
`IPR2020-01299
`
`
`
`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________
`BAYERISCHE MOTOREN WERKE )
`AKTIENGESELLSCHAFT and
`)
`BMW OF NORTH AMERICA,
`)
`LLC,
`
`))
`
` vs.
`
` Case
`Petitioners, ) IPR2020-01299
`)
`) Patent 8,630,761
`)
`PAICE LLC and THE ABELL )
`FOUNDATION, INC.,
`)
`)
`)
`Patent Owners.
`____________________________)
`
`The Virtual Deposition of
`
`GREGORY W. DAVIS, Ph.D.
`
`Date: April 14, 2021
`
`The virtual deposition of GREGORY W. DAVIS,
`
`Ph.D., called by the Patent Owners for examination,
`
`pursuant to the applicable rules, taken
`
`stenographically by Sandra L. Rocca, CSR, RMR, RDR,
`
`CRR, on the 14th of April, 2021, at the hour of
`
`9:00 a.m.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
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`PAICE 2034
`BNW v, Paice
`IPR2020-01299
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`
`
`Gregory W. Davis, Ph.D. - April 14, 2021
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`Page 2
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` APPEARANCES: (All parties appeared remotely)
`
` CROWELL & MORING
` By: MR. SCOTT L. BITTMAN
` 590 Madison Avenue, 20th Floor
` New York, New York 10022-2544
` 212.895.4223
` sbittman@crowell.com
`
` -and-
`
` CROWELL & MORING
` By: MR. VINCENT J. GALLUZZO
` 1001 Pennsylvania Avenue, N.W.
` Washington, D.C. 20004-2595
` vgalluzzo@crowell.com
`
` appeared on behalf of the
` Petitioners;
`
` FISH & RICHARDSON
` By: MR. BRIAN J. LIVEDALEN
` 1000 Maine Avenue SW
` Washington, D.C. 20024
` 202.638.6557
` Livedalen@fr.com
`
` appeared on behalf of
` the Patent Owners.
`
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`Gregory W. Davis, Ph.D. - April 14, 2021
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`Page 3
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` I N D E X
`
`WITNESS PAGE
`
`GREGORY W. DAVIS, Ph.D.
`
`EXAMINED BY
`
` Mr. Livedalen 4
`
` EXHIBITS
`
`NUMBER MARKED FOR ID
`
`Exhibit BMW1054
`
` C.P. Quigley reference, "Predicting
` the Use of a Hybrid Electric
` Vehicle" 6
`
` (Exhibit not attached.)
`
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`Gregory W. Davis, Ph.D. - April 14, 2021
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` GREGORY W. DAVIS, Ph.D.,
`
`having been first duly sworn, was examined and
`
`testified as follows:
`
` EXAMINATION
`
`BY MR. LIVEDALEN:
`
` Q Good morning, Dr. Davis.
`
` A Good morning.
`
` Q Will you please state your name for the
`
`record?
`
` A Sure. It's Dr. Gregory W. Davis.
`
` Q You understand you're providing testimony
`
`for IPR2020-01299 today?
`
` A Well, I guess that's the number. I don't
`
`have the numbers memorized on these things.
`
` MR. BITTMAN: I can confirm that that's
`
`correct.
`
` A Okay, thank you.
`
` Q And I guess, Dr. Davis, what do you have in
`
`front of you in terms of paper documents?
`
` A Sure, I've got my declaration and then a
`
`copy of the patent. I think I have a file history
`
`here and actually it might be in another notebook.
`
`A few of my exhibits. Do you want me to read
`
`through all my tabs I have for you? Would that be
`
`helpful?
`
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`
`Gregory W. Davis, Ph.D. - April 14, 2021
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`Page 5
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` Q That's fine. We could send you electronic
`
`documents through the chat, but if you want to look
`
`at the hard copies, that's fine as well.
`
` A Yeah, I like the hard copies. Quite often
`
`that can work out a little bit nicer.
`
` Q Okay. All right. So I think we've
`
`established that you -- your deposition today is for
`
`IPR2020-01299. Is that right?
`
` A Yes.
`
` Q Okay. And Dr. Davis, you consider that your
`
`expertise is the same or greater than a person of
`
`skill in the art for this particular proceeding, is
`
`that right?
`
` A Yes, I do.
`
` Q Okay. Dr. Davis, as to a person of skill in
`
`the art, what is a parameter to you?
`
` MR. BITTMAN: Objection, form.
`
` A Can you point me to maybe something in my
`
`declaration where I use that? That might -- it's
`
`broad. It depends on the context sometimes.
`
` Q Sure. So I will send you a document. How
`
`about that? One second. I guess we'll -- we'll
`
`just mark these as the regular exhibits. I think
`
`that's probably easier. So this is BMW 1054, which
`
`is the Quigley reference.
`
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`Gregory W. Davis, Ph.D. - April 14, 2021
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`Page 6
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` MR. BITTMAN: Yeah, that works.
`
` (BMW Exhibit 1054 marked for
`
` identification.)
`
` Q Dr. Davis, I guess let me know when you have
`
`it in front of you either electronically or
`
`physically.
`
` A I've got a hard copy here.
`
` Q Okay. If you look at the abstract, it says,
`
`I guess at the fifth line down it says, "This paper
`
`presents work to attempt to predict these parameters
`
`at the start of the journey using intelligent
`
`classification techniques and the knowledge base of
`
`previous journey histories."
`
` So in the context of Quigley, what is a
`
`parameter?
`
` MR. BITTMAN: Objection, form.
`
` Q According to one of skill in the art.
`
` A I think here you could look at -- they're
`
`looking at operating variables, indicators of the
`
`operation.
`
` Q Okay. And if you'd go to page -- it's --
`
`let's see, page 133 on the bottom is the number. I
`
`think it's the -- just the fifth page in the
`
`document.
`
` A Yes.
`
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`Gregory W. Davis, Ph.D. - April 14, 2021
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`Page 7
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` Q And if you read at the top left-hand corner
`
`it says, "If it is a weekday and the time is between
`
`7:00 and 8:00 a.m., then there's a high expectation
`
`of a journey of 1,000 to 1,300 seconds duration with
`
`a distance around 14 kilometers."
`
` Do you see that?
`
` A Yes, I do.
`
` Q So is it your opinion that Quigley predicts
`
`the duration and the distance of a journey?
`
` MR. BITTMAN: Objection, form.
`
` A Well, I think this is just an indication of
`
`some of the parameters that it's predicting. So for
`
`example, if you go back to page 130, where you look
`
`under the right-hand column under the section
`
`"Hybrid Power Train Control," for example, if you
`
`look under "1st Generation Control," you can look
`
`at -- you know, the essence of this type of control
`
`is that all information would only be available
`
`internally to the vehicle from transducers belonging
`
`to the vehicle. A control of this type, if
`
`implemented, would use signals derived from
`
`technology already present in modern day vehicles,
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`e.g., electronic tachometer, engine management
`
`system. Such information would include the driver's
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`operational inputs, throttle, brakes, et cetera.
`
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`Gregory W. Davis, Ph.D. - April 14, 2021
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`Page 8
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`And then time of day, year, engine management data
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`like engine speed, et cetera, and road speed. So
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`that would be some of the parameters, for example,
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`that the -- that Quigley would be predicting and
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`also using as part of his prediction.
`
` Q So all right. I don't think -- let's talk
`
`about the results that are on page 133 at the top we
`
`talked about in terms of whether there's a high
`
`expectation of a journey of 1,000 to 1,300 seconds
`
`duration with a distance of around 14 kilometers.
`
`Do you see that discussion?
`
` A Yes, I do.
`
` Q And Quigley uses a GPS logger to obtain that
`
`information, right?
`
` A Well, that was part of their vehicle
`
`experiments where I think they were trying to prove
`
`that they could, in fact, recognize a journey.
`
` Q But none of the experiments use anything
`
`besides a GPS logger, isn't that right?
`
` A Well, no, we don't -- we don't know that
`
`because they are here predicting the occurrence of a
`
`journey. They already have available the idea of
`
`measuring the driver's inputs, for example throttle
`
`and brake. Those other variables are already being
`
`measured as they talk about earlier.
`
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`Gregory W. Davis, Ph.D. - April 14, 2021
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` Q But none of the data that's reported or any
`
`of the graphs use any internal inputs such as
`
`throttle or brake, isn't that right?
`
` MR. BITTMAN: Object to form.
`
` A No, that's not true. What they're doing
`
`here is a presentation to basically prove the
`
`concept that we can, in fact, predict a journey and
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`the frequency, the expectation of a journey. So the
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`easiest way to kind of present that data so that you
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`could see that frequency and the idea that there is
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`a journey is by looking at, for example, the time
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`period, the time of day, the distance. And I think
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`then they were looking at the counts. But that's
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`certainly not all that they would be predicting
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`there. This is just their way of showing you, yes,
`
`you can predict this journey here.
`
` Q All right. Let's -- I want to limit my
`
`questions to the experiment. So does the experiment
`
`track anything beyond GPS?
`
` MR. BITTMAN: Objection, form.
`
` A I think it does because of course you're
`
`trying to predict --
`
` Q Okay. Where in the document does it say
`
`that the -- that the experiment includes things
`
`other than GPS?
`
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`Gregory W. Davis, Ph.D. - April 14, 2021
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` MR. BITTMAN: Objection, form.
`
` Q Please show me.
`
` A Well again, as I previously said, they're
`
`already talking about for the first generation
`
`control, for example, on the right-hand column of
`
`page 130, the idea that they already have these
`
`other variables present, driver's input, throttle,
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`brake, speed of the engine, speed of the vehicle,
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`time of day, different values like that. And then
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`under the vehicle experiments, they were using the
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`GPS navigation system in order to see if, in fact,
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`they would have repeatable journeys that you would
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`tend to see.
`
` Q The experiment --
`
` A The --
`
` Q The experiment itself --
`
` MR. BITTMAN: Counsel, please.
`
` Q -- is that right?
`
` (Stenographer interruption.)
`
` A Can I finish my answer then now?
`
` Q Yeah, let's focus on the experimentation. I
`
`don't think you've actually answered my question.
`
` A Okay. Well, actually I'm under the section
`
`now -- Section 3 entitled "Vehicle Experiments."
`
` Q All right. Let's talk about that.
`
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`Gregory W. Davis, Ph.D. - April 14, 2021
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` A And if you look at that, "Data is required
`
`throughout the project for investigation into
`
`methods of vehicle use prediction." Okay. Vehicles
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`use, not just, you know, time of day, things like
`
`that. They were using the data logger based around
`
`a GPS navigation system in order to see if, in fact,
`
`there is some repeatable driving patterns.
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` And for example, even though they don't
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`disclose it on the figures, say Figure 7, they
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`actually have listed under 1st generation control
`
`parameters, time of departure, journey time, speed
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`over ground derived from latitude and longitude.
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`They're not actually presenting that in those
`
`figures. So they're monitoring, as always, more
`
`parameters than just that.
`
` Here, this is a proof of concept to show
`
`that yes, in fact, there is some repeatability.
`
`They actually talked about careful consideration has
`
`gone into the selection of subjects. They're being
`
`chosen so that the main vehicle user represents a
`
`subset of the UK driving population. And so they
`
`were trying to find out is there some sort of
`
`repeatability that they could determine and that
`
`they could extract so that they could predict a
`
`particular journey.
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` And so they're just presenting that data to
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`show you that there is, in fact, a predictable
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`journey. But they're, of course, keeping track of
`
`the other parameters of the vehicle.
`
` Q Where in Quigley does -- do the authors use
`
`the other parameters of the vehicle to predict
`
`anything?
`
` A I think you misunderstand. One of ordinary
`
`skill in the art would understand that the
`
`importance here is that by being able to predict a
`
`repeatable kind of a journey, you know the throttle
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`-- average throttle inputs, the driver's use of the
`
`brake pedal, the road load. You know these things
`
`in your controller and now you're being able to
`
`predict that yes, there's a high likelihood we're
`
`entering that particular operating condition for the
`
`vehicle. And so then we can then use that, as they
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`talk about, to optimize the vehicle so they can get,
`
`you know, better fuel economy or emissions, for
`
`example.
`
` Q So my question --
`
` A The point of the project is to do that -- is
`
`to do that. What they're merely doing at the end
`
`here on their preliminary findings is showing us
`
`graphically that yes, indeed you can predict a
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`journey here. There's a very repeatable journey.
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` But of course, there's more to that journey
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`than just the figures, those histograms let's say in
`
`Figure 7. That's just an indication, yes, there is
`
`a predictable journey there. But they're of course
`
`monitoring and keeping track of all the other
`
`parameters because that's what they're going to use
`
`to optimize the system.
`
` Q All right. I want to be clear. When I ask
`
`a question about what is literally in a document, I
`
`want you to try to find something in a document. If
`
`I ask you about what someone skilled in the art
`
`understands, that would be a different question.
`
` So I want to ask you in terms of what is
`
`literally written in the document, what does Quigley
`
`predict using the throttle and brake?
`
` MR. BITTMAN: Objection to form.
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` A That's part of the journey. And literally
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`in the document, as I read before, that's part of --
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`the most important part of the document is the
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`section "Hybrid Power Train Control." And so that's
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`part of what would be present in a particular
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`journey would be the driver's operational inputs,
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`for example; engine speeds, the road speeds, things
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`like that.
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`Gregory W. Davis, Ph.D. - April 14, 2021
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` So the vehicles experiment is just to verify
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`that we can, in fact, predict a journey where we
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`will know, we'll have an idea of what these -- these
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`driver's inputs, for example, would be over the
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`course of that journey. So that experiment is just
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`a validation of the fact that they can, in fact,
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`predict a journey.
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` Q All right. But what information is actually
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`predicted in Quigley based on the brake and throttle
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`inputs?
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` MR. BITTMAN: Objection to form, asked and
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`answered.
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` A Again, as I said, they're monitoring all
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`those because that's the essence of what they're
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`going to use in their hybrid control. So for
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`example, if we go under the preliminary findings
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`section on page 132, just below Figure 5, you can
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`see they're talking about a summary of initial data
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`analysis is presented. So it's just a summary of
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`the initial data analysis, i.e., journey duration,
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`journey distance, and ground locations visited.
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` The data is considered to develop rules to
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`assist in journey prediction. The essence of the
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`journey though is the operating parameters of the
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`vehicle, not simply just a distance or a time.
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`Gregory W. Davis, Ph.D. - April 14, 2021
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` Q Dr. Davis, did you look for additional
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`papers and findings from these authors to confirm
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`whether or not they did additional studies?
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` A I guess I don't feel the need to here
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`because one of ordinary skill in the art would
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`understand from reading this paper in its entirety
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`what it's doing.
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` Q It's a yes or no, just a "yes" or "no"
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`question. Did you or did you not look for
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`additional studies or papers or research from these
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`authors subsequent to this paper?
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` MR. BITTMAN: Objection, form, asked and
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`answered.
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` A As I said, I think one of ordinary skill in
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`the art reading this paper wouldn't feel the need to
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`look at some additional papers. So I don't recall
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`looking for any additional -- I'm just going back to
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`double-check the authors. Although I do believe
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`I've probably seen something else by Dr. Jones. But
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`you know, I've probably seen other reports from
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`University of Warwick.
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` Q So you yourself, not a hypothetical person,
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`but you yourself did not look for any additional
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`papers subsequent to Quigley from these authors, is
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`that right?
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`Gregory W. Davis, Ph.D. - April 14, 2021
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` A In regards to this, I don't remember feeling
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`the need to go out and look for anything else. I
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`think this paper is very self-explanatory.
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` Q Okay. So that means you did not?
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` MR. BITTMAN: Objection to form.
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` A So I said -- I think I said I didn't feel
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`the need to, so of course I'm not going to just go,
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`you know, looking for something I don't really need.
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`So no.
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` Q Okay. All right. If you can go to
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`page 130, which is the second page. And if you go
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`down to the second paragraph on the left-hand column
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`below the figure. Are you there?
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` A Yes.
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` Q It says, "To enable a hybrid electric power
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`train controller to adapt to a wide variety of
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`vehicle operation, many parameters not normally used
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`in vehicle control systems would be required, e.g.,
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`journey duration, journey distance, time of
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`departure, journey destination."
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` Do you see those?
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` A Yes, I do.
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` Q And these are examples of journey parameters
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`that Quigley predicts, is that right?
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` A Again it goes on to say, "Unfortunately,
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`Gregory W. Davis, Ph.D. - April 14, 2021
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`most of these parameters are known only upon
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`completion of a given journey. Therefore, a means
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`of intelligently estimating these parameters based
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`on the controller's past experience is needed."
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` Q Right. So Quigley is trying to
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`intelligently estimate the journey parameters of
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`journey duration, journey distance, time of
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`departure, and journey destination, right?
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` A They're trying to recognize the journey so
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`that then they would know things about the road load
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`requirements because they know that -- they
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`recognize let's say journey A, for example. So they
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`know what let's say the average power requirements
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`or road load requirements are for that particular
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`journey. Is it an urban commute or is it some other
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`journey? Journey B would be a different journey.
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`So their intention is to recognize these different
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`journeys so that they therefore can operate their
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`control system in an optimum manner.
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` Q Are there any other parameters besides
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`journey duration, journey distance, time of
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`departure and journey destination that Quigley
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`explicitly says are intelligently estimated?
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` A Again, they do go on to talk about the
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`control inputs that are already present. They would
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`Gregory W. Davis, Ph.D. - April 14, 2021
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`be used as part of this journey, right, because one
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`of ordinary skill in the art would understand that
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`the only way you can intelligently modify the
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`controller is based on an understanding of the load
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`requirements of the vehicle.
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` And so they're recognizing a journey so that
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`they can then categorize that journey as maybe a
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`journey that requires higher load requirements or is
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`a commuting type journey a short stop-and-go
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`journey.
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` But of course, one of ordinary skill in the
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`art would understand that going right along with
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`that as part of the journey is they're looking at
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`these control parameters for the vehicle because
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`that's what they're going to be modifying in order
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`to optimize the control.
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` Q All right. In the actual document itself,
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`what other things are intelligently estimated beyond
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`the parameters of journey duration, journey
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`distance, time of departure and journey destination?
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` A Well, they're going to estimate based on the
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`driver's operational inputs of throttle and brake,
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`et cetera. They're going to be estimating what the
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`road load requirements would be for that particular
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`journey, okay, because otherwise, if you go back to
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`Gregory W. Davis, Ph.D. - April 14, 2021
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`just even the abstract of the paper, the overview,
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`if you will, the abstract say, "This paper outlines
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`the initial stages of a project to analyze the
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`requirements and then design an intelligent
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`controller for hybrid electric vehicles. Such a
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`controller would be required to manage energy flow
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`through the hybrid drive train and for optimum
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`control would require a number of parameters
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`normally available only upon journey completion.
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`This paper presents work to attempt to predict these
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`parameters at the start of the journey using
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`intelligent classification techniques and a
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`knowledge base of previous journey histories."
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` So they're talking about the controller
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`would be required to manage the energy flow through
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`the hybrid drive train for the optimum control and
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`that requires specifically a knowledge of more than
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`just, you know, 14 kilometers and this time of day.
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`That's requiring the knowledge of the road load
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`requirements or the power requirements during that
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`journey.
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` Q Okay. Can you show me somewhere in Quigley
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`where it says that the controller predicts anything
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`related to road load other than saying that it's
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`your opinion that it's an input to the controller?
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`Gregory W. Davis, Ph.D. - April 14, 2021
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`Page 20
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` MR. BITTMAN: Objection to form.
`
` A Otherwise if you didn't do that, you
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`couldn't manage the energy flow through the hybrid
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`drive train for optimum control. You just couldn't
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`do that unless you're predicting what the
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`requirements are because then you're apportioning
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`the control to the various elements. So one of
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`ordinary skill in the art, this is pretty typical of
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`what you're doing, okay.
`
` Let me find some more here. They talk about
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`-- on page 130, they talk about -- under the figure
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`on the left, Figure 1, which is just a simple
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`description of a parallel hybrid electric vehicle,
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`they talk about towards the end of that first
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`paragraph, "It was concluded that fuzzy control
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`could provide benefits" -- they're talking about
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`some prior work -- "over a limited range of
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`operation, but in order to obtain better performance
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`over the complete range of operation, a method of
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`adapting the fuzzy rules would be required."
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` Again, they're looking at this idea of how
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`you apportion the power requirements of the vehicle
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`to the motor and to the engine for this parallel
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`drive hybrid vehicle. And you can't do that. One
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`of ordinary skill in the art would know that the
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`Gregory W. Davis, Ph.D. - April 14, 2021
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`only way you can do that is by understanding what
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`those road load requirements are.
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` Q So it's your opinion that Quigley inherently
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`predicts road load information, is that your
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`opinion?
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` MR. BITTMAN: Objection to form.
`
` Q And one of skill in the art would know you
`
`can't do it any other way?
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` A I'm not a lawyer, but I do recognize that
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`inherently as kind of a term of the law, so I don't
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`know that I want to go down that road. But I'm --
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`what I mean saying is one of ordinary skill in the
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`art when reading this paper, would fully understand
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`that you're trying to recognize these journeys
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`precisely so you know what the power and the road
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`load requirements are for the vehicle so that you
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`can then intelligently optimize your control system,
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`as they say is their goal in the abstract of the
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`paper.
`
` Q Okay. But you can't point me to any place
`
`in Quigley that actually says that anything with
`
`respect to road load is predicted other than your
`
`point that there's an input of brake and throttle,
`
`isn't that right?
`
` MR. BITTMAN: Objection to form,
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`Gregory W. Davis, Ph.D. - April 14, 2021
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`mischaracterizes testimony, asked and answered.
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` A So again, I guess if we go under that
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`Section 2, Hybrid Power Train Control, "As
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`previously" -- it starts out in the very first
`
`paragraph, "As previously stated, the proposed
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`controller will allow journey parameters to be
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`reliably estimated upon journey departure. In order
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`to do this, the information available to the
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`controller could take one of two forms."
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` Talking about the 1st generation controller,
`
`they talk about the types of sensors, the parameters
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`that they're going to be measuring, driver's
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`operational input, throttle, brake. So that's all
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`part of reliably trying to estimate or predict
`
`what's going to occur.
`
` Q So what does Quigley predict what's going to
`
`occur?
`
` A A particular journey. And again, as they
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`say, under the Hybrid Power Train Control, this is
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`the goal here, right. "As previously stated, the
`
`proposed controller will allow journey parameters to
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`be reliably estimated upon journey departure. In
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`order to do this, the information available to the
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`controller could take one of two forms." And when
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`they look under the 1st generation control, they
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`Gregory W. Davis, Ph.D. - April 14, 2021
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`include technology that's already present on the
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`vehicle, the electronic tachometer, information from
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`the engine management system, driver's operational
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`inputs. So all of those are what they're using as
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`part of their prediction for, you know, when they
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`recognize they're entering a different journey,
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`let's say journey A. Those are the things that
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`they're measuring in order to make the prediction
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`and those are also the things they are then
`
`predicting once they know that.
`
` Q All right. Let's go back to -- this is
`
`page 132. I think you said earlier that the
`
`experiment used these inputs to calculate road
`
`speed. But isn't it the case looking at the
`
`left-hand column and the graphs below that Quigley
`
`uses the GPS data to calculate road speed?
`
` MR. BITTMAN: Objection, form,
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`mischaracterizes testimony.
`
` A Again, they're implementing a data recorder
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`that has a GPS base in order to just capture that
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`data independent of what let's say their 1st
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`generation controller has so that they're able to
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`then show that there is a high likelihood that
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`people would predict a journey.
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` Q The simple question is are the graphs on the
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`Gregory W. Davis, Ph.D. - April 14, 2021
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`left-hand side of page 132, are those derived by GPS
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`data, yes or no?
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` MR. BITTMAN: Objection to form. Please let
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`me him finish his answer if he's not done. I don't
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`think he was complete before.
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` A So the graphs in Figure 5 is the raw data
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`that it got from the GPS data -- data logger which
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`is what they're using to verify their prediction of
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`a journey that they actually can do this. I think
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`what would clear it up a little bit perhaps is if we
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`go to page 131 where --
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` Q Hold on. I just have a simple question
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`though. So the speed is calculated from this data,
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`right? As it says, speed over ground and bearing
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`are derived from this data, isn't that right?
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` A Yes, yes, because again they're verifying
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`that they can, in fact, with their let's say 1st
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`generation control actually predict a journey. And
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`so they're using an external system, right. The 1st
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`generation control is not even going to use a GPS,
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`right. So they're using the GPS as a separate means
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`of detecting the location of the vehicle, is there a
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`journey that is repeatable here.
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` So they're using that as a means of
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`verifying what their 1st generation, their
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`controller would actually do. That data logger
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`isn't going to be present in the actual operating
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`vehicle. That's just an experimental device to help
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`you confirm what you're trying to do with the actual
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`vehicle. Do you understand what I mean?
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` It's like when I run an engine in my lab,
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`right. I add extra transducers. They're
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`independent of the transducers used by the control
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`system of the engine. Why do I do that? Because
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`I'm trying to verify that, in fact, the control
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`system of the engine is functioning the way I think
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`it is or the way it was intended to function. So
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`this is an external verification using a GPS data
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`logger.
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` Q So none of the experiments have results that
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`are from the actual first generation control
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`parameters, right?
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` A I'm not sure I understand your question
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`there.
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` Q So I think you just said that the
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`experiments used something other than the 1st
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`generation control parameters, right?
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` A No. What I'm saying -- no, what I'm saying
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`the data logger is your device to confirm that, in
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`fact, your system is operating as intended. So it's
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`Gregory W. Davis, Ph.D. - April 14, 2021
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