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`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE SOUTHERN DISTRICT OF IOWA
`
`EASTERN DIVISION
`
` 4 -----------------------------------------------------
`
` 5 NUHN INDUSTRIES, LTD.,
`
` 6
`
` 7
`
`Plaintiff,
`
`-vs- Case No. 3:22-CV-00015-SMR-HCA
`
` 8 BAZOOKA FARMSTAR, LLC,
`
` 9
`
`Defendant.
`
` -----------------------------------------------------
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`* * * * * *
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`VIDEO DEPOSITION OF REIDAR OLOFSSON
`
`TAKEN ON THE 5TH DAY OF SEPTEMBER, 2024
`
`AT MERCHANT & GOULD, P.C.
`
`MINNEAPOLIS, MINNESOTA
`
`9:04 A.M.
`
`* * * * * *
`
`Taken before Shannon Caflisch, RPR
`
`APPEARANCES:
`
`Veritext Legal Solutions
`
`www.veritext.com
`
`888-391-3376
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 1 of 325
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`Page 1
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`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE SOUTHERN DISTRICT OF IOWA
`
`EASTERN DIVISION
`
` 4 -----------------------------------------------------
`
` 5 NUHN INDUSTRIES, LTD.,
`
` 6
`
` 7
`
`Plaintiff,
`
`-vs- Case No. 3:22-CV-00015-SMR-HCA
`
` 8 BAZOOKA FARMSTAR, LLC,
`
` 9
`
`Defendant.
`
` -----------------------------------------------------
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`* * * * * *
`
`VIDEO DEPOSITION OF REIDAR OLOFSSON
`
`TAKEN ON THE 5TH DAY OF SEPTEMBER, 2024
`
`AT MERCHANT & GOULD, P.C.
`
`MINNEAPOLIS, MINNESOTA
`
`9:04 A.M.
`
`* * * * * *
`
`Taken before Shannon Caflisch, RPR
`
`APPEARANCES:
`
`Veritext Legal Solutions
`
`www.veritext.com
`
`888-391-3376
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 1 of 325
`
`
`
`Page 2
`
`SCOTT YACKEY, of the firm of HARNESS IP, 2801 Network
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` Boulevard, Suite 600, Frisco, Texas 75034, appeared remotely
`
` via Zoom representing the Plaintiff.
`
`MICHAEL KELLA, of the firm of HARNESS IP, 7700 Bonhomme
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` Street, Suite 400, Clayton, Missouri 63105, appeared remotely
`
` via Zoom representing the Plaintiff.
`
`THOMAS LEACH, of the firm of MERCHANT & GOULD, P.C.,
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` 150 South Fifth Street, Suite 2200, Minneapolis, Minnesota
`
` 55402, appeared representing the Defendant.
`
`ALSO PRESENT: Max Orenstein - videographer
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`www.veritext.com
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`888-391-3376
`
`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 2 of 325
`
`
`
` INDEX
`
`Page 3
`
` EXAMINATION PAGE
`
` Of Reidar Olofsson
`
` By Mr. Leach . . . . . . . . . . . . . . . . 5,249
`
` By Mr. Yackey . . . . . . . . . . . . . . 190,250
`
` OBJECTIONS
`
` By Mr. Yackey . . . 30,36,38,39,40,41,43,44,45,47,
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` 50,51,53,54,55,56,57,59,60,62,63,64,68,70,77,78,79,80,81,
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` 83,84,86,87,88,91,96,100,102,103,104,105,106,108,111,112,
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` 113-114,115,119,121,123,124,125,127,128,129,131,133,136,
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` 149,152,153,154,155,156,157,160,161,163,164,165,169,171,
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` 172,173,175,176,178,179,180,181,184,185,186,189
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` By Mr. Kella . . . . . . . . . . . . . . . . . . 75
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` By Mr. Leach . . . 191,192,193,194,195,196,197,199,
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` 200,204,205,209,210,212,213,215,217,221,224,225,226,232,
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` 234,236,237,238,239,240,243,246
`
` DEFENDANT'S EXHIBITS
`
`Exhibit 15 Dorotea Mekaniska AB Truxor model history
`
`Exhibit 16 Dorotea Mekaniska AB retailer price list 2009
`
`Exhibit 17 BAZ15_0026657-0026665
`
`www.veritext.com
`
`888-391-3376
`
`Veritext Legal Solutions
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`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 3 of 325
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`
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`Page 4
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` Exhibit 18 BAZ15_0026649-0026656
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` Exhibit 19 Photos - TRUX1-8
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` Exhibit 20 Photo - TRUX242
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` Exhibit 21 Photo - TRUX243
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` Exhibit 22 Drawing - TRUX124
`
` Exhibit 23 Drawing - TRUX244
`
` Exhibit 24 Drawing - TRUX241
`
` Exhibit 25 Truxor DM 5000 Foreword - Section 1
`
` Exhibit 26 Truxor DM 5000 Spare Parts
`
` Exhibit 27 Truxor DM 5000 Spare Parts - Tools & Accessories
`
` Exhibit 28 12-16-10 email with attachments from Johan Svensson
`
` Exhibit 29 3-29-11 email from Johan Svensson
`
` Exhibit 30 2 satellite views of Dorotea, Sweden
`
` Exhibit 31 Video
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` Exhibit 32 Three-ring binder of the declaration of Reidar
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` Olofsson and Exhibits A-J
`
` * NOTE *
`
` (Original exhibits were attached to original transcript;
`
` copies to transcript copies.)
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`Veritext Legal Solutions
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`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 4 of 325
`
`
`
`Page 5
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` VIDEOGRAPHER: Good morning. We are now on
`
` the record. This is Media Unit 1 of the video
`
` recorded deposition of Reidar Olofsson taken by
`
` counsel for the plaintiff (sic) in the matter of
`
` Nuhn Industries, Ltd. versus Bazooka Farmstar, LLC
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` filed in the United States District Court, Southern
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` District of Iowa, Eastern Division, Case No.
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` 3:22-CV-00015-SMR-HCA. The location of the
`
` deposition is Merchant & Gould.
`
` My name is Max Orenstein. I'm representing
`
` Veritext. I'm the videographer. Our court
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` reporter is Shannon Caflisch from the firm
`
` Veritext. She is the --
`
` Will court reporter please swear in the
`
` witness? And then the counsel may proceed.
`
` MR. LEACH: One -- one quick clarification.
`
` This is the deposition by the Defendant Bazooka
`
` Farmstar, LLC of the witness.
`
` REIDAR OLOFSSON,
`
` after having been first duly sworn on oath by
`
` Shannon Caflisch, deposes and testifies as follows:
`
` EXAMINATION
`
` BY MR. LEACH:
`
` Q Good morning, Mr. Olofsson.
`
` A Morning, morning.
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`888-391-3376
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`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 5 of 325
`
`
`
` Q Can you please state your full name -- full legal name
`
` for the record?
`
` A Yeah. My name full is Sven Erik Reidar Olofsson.
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`Page 6
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` Q And do you go by Reidar?
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` A Reidar is my name, yes.
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` Q And how old are you, sir?
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` A I'm born '58, so I'm 65 now.
`
` Q And where do you currently live?
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` A I live up north in Sweden, 600 kilometers north
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` Stockholm, a place called Dorotea, a small place.
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` THE COURT REPORTER: Could you please that?
`
` THE WITNESS: Dorotea, D-o-r-e-a-t-a (sic).
`
` Q (By Mr. Leach, continuing) And are you here today to
`
` voluntarily provide facts about the Truxor amphibious
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` multi-tool vehicle, and specifically the Truxor DM 5000?
`
` A Yes.
`
` Q And you understand you were just sworn in, that your
`
` testimony here is the same as if it was in a courtroom
`
` in front of a judge or jury?
`
` A Okay. Yes.
`
` Q And given that your English is very good, are you
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` comfortable proceeding in English today?
`
` A Yeah, I think so.
`
` Q Just to go over a few kind of formalities, if my
`
` questions aren't clear at any time, please ask for me to
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`888-391-3376
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`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 6 of 325
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` re -- rephrase them or maybe clarify. But if you
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` answer, I'll assume you understood the question; is that
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`Page 7
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` fair?
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` A Okay.
`
` Q And you understand that your testimony will be recorded
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` today by a court reporter?
`
` A Yeah.
`
` Q And also the deposition will be videotaped by a
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` videographer, correct?
`
` A Yes.
`
` Q And so given that the court reporter is going to take
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` everything that's said on the record today down, we need
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` you to provide verbal answers so she can hear -- hear
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` the answer. And, also, I'll ask -- I won't speak over
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` you, I'll try to go slow; and I ask that you don't speak
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` over me, so the court reporter can get everything that's
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` said.
`
` A Okay.
`
` Q Is there any reason, such as any medication that you're
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` on, that you couldn't understand my questions and
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` provide truthful responses?
`
` A No.
`
` Q Can you briefly provide me with your education?
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` A Yeah. Usually school in Swedish -- or Sweden are 1st
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` grade to 9th. And after that, you go to gymnasium, and
`
`www.veritext.com
`
`888-391-3376
`
`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 7 of 325
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` then I go two years in gymnasium.
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` Q And what did you study in gymnasium?
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` A It was mechanical maintenance of cars you say.
`
` Q Okay. And are you currently employed?
`
` A No. I am retired.
`
` Q And when did you retire?
`
` A For last year in July.
`
` Q So would that be July 2023?
`
` A Yes.
`
` Q And where did you work before you retired?
`
` A Yeah. I work at what they -- now they call Truxor
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` Environment.
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` Q Is it Truxor Wetland --
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` A Truxor Wetland Environment, yeah. And before that, I
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` was -- it was Dorotea Mekaniska AB.
`
` Q Okay. And we can spell that.
`
` A It's D-o-r-o-t-e-a M-e-k-a-n-i-s-k-a A-B.
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` Q And -- and the -- the current company, I think you said
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` it was Truxor Wetland --
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` A Equipment.
`
` Q -- Equipment --
`
` A Yeah.
`
` Q -- AB. Okay.
`
` A Yes.
`
` Q Okay. So that's -- that's the company, Truxor Wetland
`
`www.veritext.com
`
`888-391-3376
`
`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 8 of 325
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` Equipment, that purchased Dorotea Mekaniska?
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` A Yes.
`
` Q Okay. And do you know when that purchase took place --
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`Page 9
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` A I think --
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` Q -- about?
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` A -- about six years ago.
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` Q Okay. And so for the last about 30 years, have you
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` worked at Dorotea Mekaniska and then Truxor Wetland
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` Equipment?
`
` A Yes.
`
` Q Okay. And they're basically the same company --
`
` A Yeah.
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` Q -- correct?
`
` A Yes.
`
` Q And so is it okay if I just call the company going
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` forward in the depo Truxor?
`
` A Yeah, that's okay.
`
` Q And that's spelled T-r-u-x-o-r?
`
` A Yes.
`
` Q And so you worked at -- at these two companies
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` continuously since about 1994?
`
` A Yeah, that's correct.
`
` Q And then after that, you retired about -- in July of
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` 2023?
`
` A Yes.
`
`www.veritext.com
`
`Veritext Legal Solutions
`
`888-391-3376
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 9 of 325
`
`
`
`Page 10
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` Q Okay. Can you explain -- or can you tell me what your
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` responsibilities were at Truxor when you started?
`
` A Yeah. I started, some would say, in '94 and I helped
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` the -- the owner then that's called Torbjorn Hallin who
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` runs the Dorotea Mekaniska.
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` Q And can you spell his name, please?
`
` A T-o-r-b-j -- you don't have -- O dot dot, and, r-n.
`
` After name, H-a-l-l-a-n -- i-n.
`
` Yeah, I help Torbj rn with -- he was -- have many
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` ideas about what we could do for making -- cutting
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` the -- the weeds in the -- and helping clean -- get
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` clean water from the lakes.
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` And so I help him with the -- develop -- develop
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` these ideas he had, and I make the drawings. And -- and
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` from the beginning, I also make the -- the prototypes
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` and all the way to -- to a product that we can --
`
` Q Okay. So --
`
` A -- produce and sell.
`
` Q -- would it be fair to say that your responsibilities at
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` Truxor were for design, development, and testing of
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` Truxor's products?
`
` A Yes.
`
` Q And did that include the Truxor 4700 and the Truxor
`
` DM 5000?
`
` A Yes.
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`www.veritext.com
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`888-391-3376
`
`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 10 of 325
`
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`Page 11
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` Q And so can you briefly explain what your
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` responsibilities were for the Truxor DM 5000 product?
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` A Yeah. So all the same from the ideas from Mr. Torbj,
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` rn how he wants to -- to make -- make the product
`
` better. And we -- for that example, we changed the
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` hydraulic system to make it -- make more hydraulic power
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` to -- can put on different tools. And I have also
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` contact with suppliers for -- to get him there.
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` Q So when you say contact suppliers, do you mean
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` purchasing, like, the engines, the -- the parts for the
`
` -- to build it?
`
` A Yeah, the parts hydraulics and --
`
` Q Okay.
`
` A -- systems.
`
` Q And so is it fair to say that you were intimately
`
` involved in the design, development, and production of
`
` the Truxor DM 5000?
`
` A Yes, I was.
`
` Q And did you also support that product in its life cycle
`
` when it was sold?
`
` A Yes. It goes on, yes.
`
` Q And so would it be fair to say that through your
`
` personal experience designing, developing, and testing
`
` and supporting the Truxor DM 5000 amphibious vehicle,
`
` did you become personally familiar with the vehicle and
`
`www.veritext.com
`
`888-391-3376
`
`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 11 of 325
`
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`Page 12
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` its functions?
`
` A Yes.
`
` Q Are you also personally familiar with the design,
`
` functionality, parts, and tools that are used on the
`
` Truxor DM 5000?
`
` A Yes, I am.
`
` Q And can you -- can you just briefly explain how you're
`
` familiar with how the product functions, its design,
`
` maintenance, parts, tools generally?
`
` A Yeah. I -- because I was from -- from the beginning,
`
` from the idea, I take it further. So I make the
`
` drawings, and also sometimes I even make all the
`
` prototypes and then testing. So I been with this
`
` product all the chain.
`
` Q Okay. And when you say with this product the whole
`
` chain, do you mean from inception to --
`
` A For production.
`
` Q -- through production.
`
` A Yes.
`
` Q Okay. And when you say "this product", we're talking
`
` about the Truxor DM 5000, correct?
`
` A Yes.
`
` Q Okay. And with respect to -- well, let's step back.
`
` The -- the Truxor DM 5000, can you briefly explain
`
` what that vehicle is?
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`Veritext Legal Solutions
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`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 12 of 325
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`Page 13
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` A Well, it's a -- it's an amphibian machine that you can
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` drive on the hard surface and the wetlands and down --
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` and even to waters.
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` Q Okay. So it's an amphibious vehicle.
`
` Does it carry any tools to -- to do work?
`
` A No. You -- you don't have -- if you have tools to do
`
` some work, you can -- must put on some tools. Because
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` the -- only the Truxor 5000 don't -- you don't -- can't
`
` do any work without any tools.
`
` Q Okay. Let me see if I -- I may have --
`
` A They call it a tool carrier.
`
` Q Okay. So -- so the Truxor 5000 -- the -- the Truxor DM
`
` 5000 amphibious vehicle has a number of different tools
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` that can be attached to it to, say, cut weeds, to dredge
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` ponds or lakes and ditches --
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` A Yes.
`
` Q -- and a number of other things, correct?
`
` A Yeah -- yes.
`
` Q And so again just briefly, the Truxor DM 5000 product,
`
` it was an amphibious vehicle, correct?
`
` A Yes.
`
` Q And can you just briefly describe, you know, did it have
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` an engine? Did it have tracks or wheels? How did it
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` float? Can you provide --
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` A Yeah. It's -- it was, what you say, a type of
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`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 13 of 325
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` catamaran. You have two pontoons that floats -- it
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` floats on. And around these pontoons, it was drive
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` belts with what we call drive plates. And with these
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` plates, it goes on hard surface and in water it pedals
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` it forwards and backwards.
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` And it's the frames that connect these pontoons so
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` it make a whole machine. And then it -- in the top, we
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` have what we call the sledge where the driver's seat and
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` the engine compartment and the hydraulic pumps, and then
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` the hoses goes from this sledge to the hydraulic motors
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` that works in the back of the -- each pontoon to drive
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` this belt.
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` Q Okay. And when you said the -- the -- there's a sledge
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` that the operator and the engine are on, does that
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` sledge move backwards and forwards?
`
` A Yes. You can -- you can do it -- and you make it go
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` forward and backward by -- by hydraulic.
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` Q And what is the reason to have the operator seat and the
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` engine move forward and backwards on the --
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` A It's --
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` Q -- on the amphibious boat?
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` A It's a kind of weight distribution. Because you have --
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` in the front, you have the lift on where you put every
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` tools. And when -- especially when you -- so you put on
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` the rake to collect the things you have cut on the
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`www.veritext.com
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`Veritext Legal Solutions
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`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 14 of 325
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`
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` surface, then you collect more and more and then it
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` becomes very heavy. And if you can't put the weight
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` less backwards, then it will tilt and tip and goes on
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`Page 15
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` its the nose, you say.
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` Q Okay.
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` A So you drive the whole sledge backwards to get it going
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` even in the water.
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` Q And so would you say it was designed to keep the center
`
` of gravity in the center of the machine?
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` A Yeah, depending on how much -- how heavy you have in the
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` lift arms, yes.
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` Q And so if you put a heavier tool on the front of the
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` machine, you could move the seat and engine back a
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` little bit to -- to make the center of gravity in the
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` center of the vehicle?
`
` A Yes. Yes.
`
` Q I think earlier you mentioned that the Truxor DM 5000
`
` was an improvement from the Truxor 4700.
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` Can -- can you explain a little bit about what the
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` improvements were from the Truxor 4700 to the Truxor
`
` DM 5000?
`
` A Yeah. The Truxor 4700 have separate hydraulic pumps,
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` one for each belt -- drive belt. And in the area, there
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` was a smaller hydraulic pump for -- for the lift arm.
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` And the -- in that -- in that case we only have a cutter
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`Veritext Legal Solutions
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`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 15 of 325
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` -- cutter -- hydraulic cutter in the lift arm so you
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`Page 16
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` need so -- so much hydraulic flow.
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` Q And is that in the 4700?
`
` A Yes, the 4700.
`
` Q Okay.
`
` A And the engine was a little bit smaller. So you can use
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` different tools than -- that needs more hydraulic flow,
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` then we came up with this Truxor 5000 that have a bigger
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` engine and only one hydraulic pump for make supply to
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` every outlets -- hydraulic outlets with oil and even
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` the -- the drive bands, also.
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` Q And so in the Truxor DM 5000, the engine drove a
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` hydraulic pump and that hydraulic pump drove the wheels
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` and the -- the tool --
`
` A Yes.
`
` Q -- tools?
`
` A Yes.
`
` (Deposition Exhibit 15 was marked for
`
` identification.)
`
` Q (By Mr. Leach, continuing) I'm handing you what's been
`
` marked as Defendant's Exhibit 15, and it bears the Bates
`
` No. TRUX0000245.
`
` Can you please take a look at this document, sir?
`
` A Yes.
`
` Q Scott, are you able to pull that up?
`
`www.veritext.com
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`Veritext Legal Solutions
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`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 16 of 325
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` MR. YACKEY: Yes. You said 245?
`
` MR. LEACH: Yes.
`
` MR. YACKEY: Yep.
`
` Q (By Mr. Leach, continuing) Mr. Olofsson, are you
`
` familiar with Truxor's recordkeeping? Like how it keeps
`
` documents that it uses in its business or it generates
`
` in its business?
`
` A Yes, I am.
`
` Q Can you tell me what Defendant's Exhibit 15 is?
`
` A Yeah. It's -- it's a document that say from what type
`
` of -- say what name of the Truxors and where they start
`
` to sell and how long it -- you can -- it was on the
`
` market.
`
` Q And how are you familiar with this document?
`
` A Yeah, I made this document.
`
` Q And so this document shows when the various Truxor
`
` products were -- started being sold and stopped being
`
` sold --
`
` A Yes.
`
` Q -- is that correct?
`
` A Yes.
`
` Q And so if we look at the Truxor 5000 in the Column
`
` f.o.m, what date did that -- did the Truxor 5000 start
`
` being sold by Truxor?
`
` A As it says, 2009 in March, I see.
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`www.veritext.com
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`Veritext Legal Solutions
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`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 17 of 325
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` Q Okay. And so the Truxor 5000 was on sale as of March
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`Page 18
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` 2009?
`
` A Yes.
`
` (Attorney Michael Kella joined the Zoom link).
`
` Q (By Mr. Leach, continuing) What does -- in the top of
`
` that column, what does f.o.m stand for?
`
` A This from and to.
`
` Q Okay. And so when -- when was the Truxor 5000
`
` discontinued or sold?
`
` A It's 2018 --
`
` Q Okay.
`
` A -- in July.
`
` Q And so in the column To, it says, for the Truxor 5000,
`
` 201807. Is that July 2018?
`
` A Yes.
`
` Q Mr. Olofsson, is this document a document -- and when I
`
` say "this document", is -- is Defendant's Exhibit 15 a
`
` document prepared and kept in the ordinary course of
`
` Truxor's business?
`
` A Yes.
`
` Q Is this a record that is made or updated to track when
`
` certain products are introduced or discontinued?
`
` A Yes.
`
` Q Is this document, DX 15, made or updated at the time
`
` these products were offered or discontinued?
`
`www.veritext.com
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`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 18 of 325
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`
` A Yes. Yes, it was.
`
` Q And I think so you mentioned this, but you created this
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`Page 19
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` document?
`
` A Yes.
`
` Q And did you obtain this document from Truxor's business
`
` records?
`
` A Yes.
`
` Q And from the location where you kept it in the ordinary
`
` course of Truxor's business?
`
` A Yes.
`
` (Deposition Exhibit 16 was marked for
`
` identification.)
`
` Q (By Mr. Leach, continuing) Mr. Olofsson, I'm handing you
`
` what's been marked Defendant's Exhibit 16 and it bears
`
` the Bates No. TRUX0000246 and 247.
`
` Can you please take a look at this document, sir?
`
` MR. LEACH: Scott, do you have that document
`
` up?
`
` MR. YACKEY: Yes.
`
` Q (By Mr. Leach, continuing) Okay. Can you tell me what
`
` Defendant's Exhibit 16 is?
`
` A Yeah. This is -- what's it say -- price list from 2009
`
` retailer price list from 2009. And then in the top
`
` there, we see the item numbers and description. And at
`
` that time, we sell the 4700 and the 5000 Truxor.
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`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 19 of 325
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` Q Okay. And so this is a document showing the price list
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`Page 20
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` for the Truxor DM 5000?
`
` A Yes. And it's tools also.
`
` Q And the tools that were sold along with it?
`
` A Yeah.
`
` Q If -- if you go down to accessories for tool carrier
`
` Truxor DM 5000, what is the first product listed there?
`
` A Yeah, that's the Doro pump -- the hydraulic Doro pump
`
` that can be used for Truxor 5000.
`
` Q Okay. And what type of pump is that?
`
` A It's a centrifugal water pump, a dredge pump.
`
` Q Okay. And how do you recognize what this document is?
`
` How do you recognize this document as Truxor's 2009
`
` retailer price list?
`
` A I'm not sure what you really -- what you really ask for.
`
` Q Sure. I'm asking is this a document that was kept in
`
` the ordinary course of Truxor's business?
`
` A Yes, sir.
`
` Q And is this a document you recognize through your work
`
` at Truxor?
`
` A Yes. I have seen them before --
`
` Q Okay.
`
` A -- yes.
`
` Q Okay. And -- and you understand the information in the
`
` document?
`
`www.veritext.com
`
`888-391-3376
`
`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 20 of 325
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` A Yeah. I know it usually updates every -- every year,
`
` yes.
`
` Q Okay. And was this document obtained from where it
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`Page 21
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` normally is kept at Truxor?
`
` A Yeah.
`
` Q And -- and who normally keeps the price list document?
`
` A It was the -- the salesman.
`
` Q And -- and, again, is Exhibit DX 16 kept in the ordinary
`
` course of Truxor's business?
`
` A Yes.
`
` Q And is this a record that is routinely made or updated
`
` to provide product pricing for each year?
`
` A Yes.
`
` Q And is it typically made or updated around 2009 or maybe
`
` just before?
`
` A Yes.
`
` Q Do you know who created this document?
`
` A I don't have the name on.
`
` Q Okay. But someone in sales likely?
`
` A Yeah, probably maybe it would have been Torbj rn, the
`
` former -- former owner.
`
` Q Okay. And is the person who made and maintained this
`
` record a person who had knowledge about the information
`
` contained in the document?
`
` A Yeah, yeah.
`
`www.veritext.com
`
`888-391-3376
`
`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 21 of 325
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` Q And so as of 2009, how much was the Truxor DM 5000 being
`
`Page 22
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` sold for in euros?
`
` A In euros, it say 65,802 euros.
`
` Q And in 2009, how much was the Doro pump hydraulic dredge
`
` pump being sold for?
`
` A It was sold for 6,018 euros.
`
` Q And the Doro pump was one of the tools made to be used
`
` on the Truxor DM 5000?
`
` A Yes. It was developed at the same time Truxor DM 5000
`
` and this Doro pump hydraulic version.
`
` Q If you go down a ways under the heading where it says
`
` Accessories for tool carrier Truxor DM 5000 and Truxor
`
` DM 4700 B --
`
` A Yeah.
`
` Q -- if you go down towards the bottom, maybe the sixth
`
` item up it says telescopic arm.
`
` Can you describe what that was?
`
` A Yes. Telescopic arm was made for lowering and -- and
`
` highs the -- the dredge pump up from -- from the wat --
`
` down in the water and up from the water to reach long --
`
` deeper.
`
` Q And was that operated hydraulically?
`
` A Yes.
`
` Q Going up from there, there's an item listed as the Doro
`
` cutter Mod 3090.
`
`www.veritext.com
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`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 22 of 325
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` Can you tell me generally what that was?
`
` A The Doro cutter Model 3090. Was that you say?
`
` Q Yes.
`
` A Okay. That was the -- the ordinary cutter. It looks
`
` like a T -- up and down T. You have cutter knives on
`
` both sides and also a vertical cutter. So that was
`
` the -- the first tool for cutting weeds in the -- in the
`
` ponds.
`
` Q Okay. And going up from there, it says a dredge pump
`
` Model 2500. Can you describe what that was?
`
` A Yeah. That was the first type of dredge pump that we
`
` used.
`
` Q And was that mainly for the --
`
` A 4700, yes.
`
` Q Okay.
`
` A But it could also be used at the 5000 model.
`
` Q Okay. And the dredge pump Mod 2500, did that have a
`
` separate engine?
`
` A Yeah, this is a Briggs & Stratton separate engine.
`
` Q To -- to drive the pump?
`
` A To drive the pump, yes.
`
` Q Okay. But the Doro pump, which is listed under
`
` Accessories for tool carrier Truxor DM 5000 and -- and
`
` not the 4700, the Doro pump hydraulic dredge pump, that
`
` was a -- a different pump, right?
`
`www.veritext.com
`
`888-391-3376
`
`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 23 of 325
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` A Yeah, that's -- because the 4700 don't have this
`
` hydraulic power to -- to -- so can't move -- can't use
`
` this hydraulic dredge pump.
`
` Q Okay. And so the Doro pump hydraulic dredge pump for
`
` the Truxor DM 5000, that didn't have a separate engine.
`
` It used the engine from the Truxor DM 5000 --
`
` A Yeah.
`
` Q -- to power it?
`
` A Hydraulic power, yes.
`
` Q Yes. Okay.
`
` (Deposition Exhibits 17 and 18 were marked for
`
` identification.)
`
` Q (By Mr. Leach, continuing) Mr. Olofsson, I'm going to
`
` hand you Defendant's Exhibits 17 and 18. It's DX 17,
`
` which is BAZ15_0026657 through 26665; and Defendant's
`
` Exhibit 18, which is Bates numbered BAZ15_0026649
`
` through 26656.
`
` Can you please take a look at these documents for
`
` me, sir?
`
` A Yep. Yeah. This is the documents of -- when -- when
`
` they start mount the Truxor together from -- from
`
` different pre-made constructions. And this is -- in,
`
` you see, No. 18 in the top it says Model Truxor 5000 and
`
` then you have the number -- the chass -- what do you
`
` call it, chassis number 945031.
`
`www.veritext.com
`
`888-391-3376
`
`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 24 of 325
`
`
`
`Page 25
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` Q Okay. Let's start with DX 17.
`
` A 17, okay.
`
` Q Okay. And let's just go through that document.
`
` On DX 17, the first page, BAZ15_0026657, what was
`
` the model -- first off, what is the top BAT
`
` specification? Is that -- what does that mean?
`
` A Yeah, yeah, it's a specification how the -- the Truxor
`
` model -- how it -- how it looks. And the specification
`
` lower down, you see the hydraulic motors and -- and the
`
` valves and how the specification of the -- of the Truxor
`
` is.
`
` Q Okay. Kind of the specific design of it or the -- the
`
` specific features it had?
`
` A Yeah. And they take, what you say, serial number of
`
` the -- the engine or the hydraulic pumps and -- and
`
` write -- write in so you can -- afterwards maybe have a
`
` problem, okay, we know the serial number of the
`
` hydraulic pump, so we can reclaim maybe to the
`
` reseller -- reseller.
`
` Q Okay. And so if you turn to the next page, what -- what
`
` is the next page showing?
`
` A It's -- it's what -- what kind of tools that this
`
` customer wants together with the Truxor.
`
` Q And -- and what tools were on this -- well, strike this.
`
` Is this -- is this group of documents, DX 17, is
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`www.veritext.com
`
`888-391-3376
`
`Veritext Legal Solutions
`
`Exhibit 1110
`Bazooka v. Nuhn - IPR2024-00098
`Page 25 of 325
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` this kind of a -- showing this -- like the -- the
`
` packing list or sale of -- of the document?
`
` A Yeah. That -- this document go out -- go out to the
`
` people who -- who put Truxor together. So they know
`
` how -- what we use and how will it be we specified in
`
` the end.
`
` Q Okay. So what tools it would have and -- and then they
`
` track kind of what hydraulic motor was put on --
`
` A Yes.
`
` Q -- in terms of the serial number and that kind of thing?
`
` A Yes.
`
` Q Okay. And -- and then does this ultimately -- did this
`
` group of documents
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