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`Jaguar Land Rover Ltd.
`Exhibit 2004
`Bentley v. Jaguar
`IPR2019-01502
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`Ex. 2004-0001
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`and gone, some shadily imported and shoddily federalized, others
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`seized and impounded at the docks.
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`Enter Porsche specialist and car dealer Bruce Canepa of Santa Cruz,
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`driven no more than 2500 miles per year, they’d be legal."
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`everyone happy. We formulated a law—that if 500 or fewer cars were I
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`California. Through his company, Canepa Design, (831) 423—5704, he
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`builds custom Suburbans and aerodynamic big rigs. Still, his love is
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`Vintage Porsche race cars, like the ’81 Le Mans-winning 936 he recently
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`acquired, or the Interseries 917/10 he raced at Lime Rock’s Rennsport -
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`Reunion. Canepa imported a pair of 9595 for Microsoft founders Bill
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`Gates and Paul Allen in the early 19905, but the cars never made it past
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`US. Customs officials in Oakland, California. Little did Canepa know it
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`would be the first step of a frustrating and confusing, but ultimately
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`rewarding, decade—long project.
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`His initial instinct was to declare himself a manufacturer to facilitate
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`the federalization process. He quickly discovered that route was
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`mined. "Had we decided to become a manufacturer, the feds should
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`have allowed it. But politically the car was a hot potato. So they
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`stonewalled us."
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`Gates, who was becoming increasingly frustrated at having his 959
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`eternally tied up in the Port of Oakland’s "free trade zone," suggested to
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`Canepa that perhaps they could federalize the car by buying a number
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`of sacrificial 959s to "crash and test." But Canepa felt that wouldn’t
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`solve the problems.
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`No stranger to a courtroom, Gates suggested the legal approach, but
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`even his attorney couldn’t untangle the mess. In the intervening two
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`years, Canepa’s exhaustive research on the problem led him to believe
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`Washington, DC, attorney Warren Dean might help the cause.
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`Representing Canepa, Chandler, Ralph Lauren, Gates and Allen, "Dean
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`went to EPA, NHTSA and all the major manufacturers, to keep
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`produced, if they weren’t currently produced, if they were never U.S.-
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`legal, and if they were rare—you could import them Without having to
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`pass DOT standards. As long as they met EPA standards and were
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`https://autoweek.com/node/1232531/printable/print
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`Ex. 2004-0002
`Ex. 2004-0002
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`Attached to miscellaneous bills, the supercar rider failed passage two
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`years in a row before Dean maneuvered it into a Senate transportation
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`bill he knew was a guaranteed winner. In April 1998, the supercar
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`proviso became law when President Clinton signed off on it. After
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`eight years of struggle, the real hassles were about to begin for the 959
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`project. "The next step was to reduce the bill to writing so DOT could
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`administer it. At first they weren’t happy about it. Their attitude was
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`‘We’re short—staffed as it is, so how are we going to deal with this?’ But
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`the government worked diligently to help our cars pass inspection."
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`Two more years passed before the feds drafted a procedural document
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`in 2000 to implement the supercar law. Piling forms on top of forms,
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`they not only insisted on insurance policies stipulating 2500-mi1e— use
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`restrictions, they also made owners submit documents confirming the
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`same thing.
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`Since Canepa was going to have to re—engineer the car’s intake and
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`exhaust to meet federal emissions requirements for model year 1988,
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`he decided to upgrade the engine’s performance. "We figured our
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`emissions mods would drop output from 450 hp to 400 hp. So as long
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`as we were gonna do this car emissions legal, [we decided to] see if we
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`can bring the power up and fix what’s obsolete. After all, you can buy
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`lots of production cars with 450 hp these days."
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`Besides, Canepa’s personal experience confirmed the sequential turbos
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`promoted lag. Friendly sources at Porsche’s Weissach engineering
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`center confirmed the 959 engine and chassis to be good for 600 hp;
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`Canepa made that his emissions-legal goal. For the past four years,
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`former IMSA crew chief Jim McCrocklin has overseen the
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`federalization project that required the cars to meet 1988 emissions
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`standards plus a 10 percent improvement.
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`Canepa retained the Northern California Diagnostic Laboratory in
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`Napa to oversee the emissions testing. NCDL, managed by Michael
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`Spencer Smith, is a state—licensed, federally recognized lab that has
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`performed similar tasks for motorcycle manufacturers Indian, Aprilia and Victory.
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`Ex. 2004-0003
`Ex. 2004-0003
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`The 959s were required to meet tougher emissions standards than those imposed on any other
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`1988 Porsche. From a performance and smog viewpoint, the car’s standard KKK turbos were
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`obsolete. So too were its solid-state ignition and digital fuel injection. KKK promised to
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`redesign updated turbos, but it failed to come through with the goods.
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`After several supplier dead-ends, Canepa settled on Garrett turbos. McCrocklin re—engineered
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`the turbos, the car’s main wiring harness, electronic management system and catalytic
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`exhaust.
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`Canepa used Chandler’s car as the test mule. The most difficult part of the process was
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`making the new electronic brain communicate with the 959’s myriad sensors. Porsche
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`supplied catalytic converters for the conversion, as well as GT2 air pumps to burn up exhaust
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`residue. "We use a healthy number of Porsche parts here," says Canepa, "because Porsche still
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`loves these cars as much as I do." The company provided Canepa with the production
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`numbers and specifications required for federal verification.
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`Because Porsche designed the 959’s engine case and innards for the 956, McCrocklin knew it
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`would withstand the modifications he envisioned. "This motor has fabulous combustion
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`chambers," McCrocklin said. "Everything is magnesium—the case, the intake manifold, even
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`the valve covers." Without changing a thing inside the long block, McCrocklin upgraded the
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`battery, rebuilt the alternator for increased output and replaced the water pump seals as a
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`factory—recommended upgrade. His redesign of the intake plumbing eliminated one of
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`Porsche’s dual wastegates. He relocated the remaining one next to the left side of the engine,
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`changing its springs and spacers but keeping it otherwise stock.
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`He bolted the 90,000-rpm Garrett M24 twin turbos to custom support struts and manifolds. He
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`retained the stock twin Behr intercoolers. He also retained Porsche’s dual fuel pumps, but
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`changed the delivery nozzles on the secondaries to provide more than twice as much fuel at
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`full boost.
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`When McCrocklin finished the work on Chandler’s car, he
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`and Canepa took it to engine builder Ryan Falconer’s dyno in Salinas, California, Where it
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`produced 600 hp out of the box. Since torque was more important than horsepower, they
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`reduced turbo size. The engine produces 575 hp at 6000 rpm, and 501 lb—ft of torque at 4500
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`rpm. The stock 959 made 450 hp at 6500 rpm and 380 lb-ft at 5500 rpm. Full boost of 1.4 bar
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`occurs at just 1500 rpm.
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`Once engine specs were finalized Canepa took Chandler’s mule to NCDL. McCrocklin put the
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`revamped Porsche through its paces, testing for hydrocarbons, NOX, carbon monoxide and
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`https://autoweek.com/node/1232531/printable/print
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`Ex. 2004-0004
`Ex. 2004-0004
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`carbon dioxide in both cold and hot start modes. The car failed because the catalysts were
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`slow to reach operating temperature after cold start.
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`Two months later, the team was back for a retest after relocating the catalysts closer to the
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`engine case, and securing them to the turbos for extra heat buildup. This time, the 959
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`breathed easy and passed. Not only that, but Canepa Design achieved an extra 25 lb—ft of
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`torque with the technical changes. Finally, after 10 long years, Bruce Canepa was ready to go
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`into production on the 959.
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`Walk into his Santa Cruz shop and you’d think you were in Weissach, circa 1988. A handful of
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`workers piece together Wiring harnesses and turbo ancillaries on three 959s. Six more cars sit
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`under plastic wraps in an adjacent building.
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`From 1987 to 1988 Porsche built 226 959s, plus another four from parts in 1992, for a total of
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`230. Of that, 26 were S models having no hydraulic suspension, no radio or air conditioning
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`and no leather. Canepa has replaced the adjustable ride height suspension on standard 9595
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`with the Bilstein shock and spring system of the 9598. He is having springs made to spec
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`because the S’s conventional suspension, he says, bests the standard setup.
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`So far, three 959s have been shipped to the Northern California lab for certification. Fourteen
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`more await federalization. All are pre—sold. He also expects to wave his wand over another 10
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`that have been unsuccessfully modified by other companies.
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`Original partners Gates and Lauren have taken delivery of their cars. Ironically, when Allen
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`moved to Europe he took his nonfederalized car with him. Meanwhile, Canepa is canvassing
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`the globe looking for unmolested, low-mileage 959s. "The average car we buy has less than
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`1000 miles on it, has gone through no Winters and costs between $275,000 and $300,000. We
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`charge $85,000 for the work we do, so the finished product goes out of here for $400,000 to
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`$425,000." Yes, there is some profit in those numbers...
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`For four hundred large you want your money’s worth. Canepa has undertaken back-to—back
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`tests with his modified 959 and a new RUF GT2. The RUF turned 0 to 60 mph in 3.7 seconds
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`and took 11.9 seconds to reach 100 mph. The 959 goes from a standstill to 60 mph in 3.3
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`seconds and reaches 100 mph in 11.4 seconds. Top speed of the 959 is 215.
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`"We’re maintaining a McLaren F1 GTR," says Canepa. "And after driving both cars, there’s just
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`no comparison. The McLaren skips and jumps all over the
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`Ex. 2004-0005
`Ex. 2004-0005
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`place. The 959 just squats and goes."
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`And finally, after all these years, it can do it on these shores.
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`lnline Play
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`Source URL: https://autoweek.com/article/car-news/lang-last—federalizing—parsche-gig-has-been-/ong-road—naw-Ieast-it-can—
`be-tra versed
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`Ex. 2004-0006
`Ex. 2004-0006
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