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`Case 1:17-cv-00770-JDW-MPT Document 120-19 Filed 11/17/22 Page 2 of 29 PageID #:
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`
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`WIRTGEN AMERICA, INC.
`
`
`Plaintiff/Counterclaim-Defendant,
`
`v.
`
`CATERPILLAR INC.
`
`
`Defendants/Counterclaim-Plaintiff.
`________________________________
`
`C.A. No.: 1:17-cv-00770-JDW-MPT
`
`DECLARATION OF RICHARD W. KLOPP, Ph.D., P.E., F.A.S.M.E. IN SUPPORT
`OF CATERPILLAR INC.’S REPLY CLAIM CONSTRUCTION BRIEF
`
`I, Richard W. Klopp, Ph.D., P.E., F.A.S.M.E. declare as follows:
`
`
`I.
`
`INTRODUCTION AND QUALIFICATIONS
`
`1.
`My opinion concerns U.S. Patent No. 9,975,538 issued to James A. Aardema,
`titled “Milling Machine Fuel Efficiency Control System.” I will refer to this patent as “the ’538
`Patent.”
`
`2.
`I understand that the parties dispute the construction of the term “variable
`transmission” that appears in the asserted claims of the ’538 Patent. I understand the parties
`proposed constructions to be those listed below:1
`
`Term
`“a variable transmission”
`
`Caterpillar’s Construction
`“a transmission that can
`change transmission ratios”
`
`’538 patent, Claims 1, 6
`
`Wirtgen America’s
`Construction
`“a stepless transmission that
`can change transmission
`ratios seamlessly”
`
`
`
` See, e.g., Disputed Constructions listed in Caterpillar’s Opening Claim Construction Brief and Wirtgen America’s
`Answering Claim Construction Brief.
`
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`3.
`I also understand that one of Wirtgen’s retained experts, Dr. Stein, has offered a
`declaration (“the Stein Declaration”)2 stating his opinion on the construction of “variable
`transmission” and his opinion on who is a person of ordinary skill in the art (“POSA”) of the
`’538 Patent.
`
`4.
`I have been retained on behalf of the Plaintiff in this matter. Among other things,
`I have been asked to offer my opinions on Dr. Stein’s construction for “variable transmission”
`and, if I disagree with Dr. Stein’s construction, provide my own opinions as to the meaning of
`the disputed term. I have also been asked to provide my opinions on who is a POSA of the ’538
`Patent.
`
`5.
`I have reviewed the ’538 Patent, its related file history, the Stein Declaration and
`the Exhibits cited in the Stein Declaration.
`
`6.
`I am over 18 years of age, I have personal knowledge of the facts stated in this
`Declaration, and I could testify competently to them if asked to do so.
`
`7.
`I am a trained mechanical engineer and hold licenses as a Professional Engineer
`in the states of California, Nevada, Washington, Michigan, and Texas. I am also a Fellow of the
`American Society of Mechanical Engineers and have been practicing in the field for more than
`40 years.
`
`8.
`For the past 23 years, I have provided engineering services as a full-time
`employee at Exponent, based in the Menlo Park office. Exponent is a publicly traded engineering
`and scientific consulting firm (NASDAQ symbol “EXPO”). I hold the title of Principal Engineer
`in Exponent’s Mechanical Engineering practice. Prior to my work at Exponent, I worked for 14
`years at SRI International as a Postdoctoral Fellow and Research Engineer.
`
`9.
`I have extensive training and experience in the engineering and application of
`engine-driven powertrains across heavy equipment, marine, stationary power generation,
`
`
`2 Declaration of Jeffrey L. Stein, Ph.D.. in Support of Plaintiff /Counterclaim-Defendant Wirtgen America Inc.’s
`Responsive Claim Construction Brief Regarding U.S. Patent No. 9,975,538.
`2
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`compressors, agriculture, and transportation. I also have extensive training and experience in the
`engineering and application of mechanical power transmission components, including clutches,
`rigid and flexible couplings, gearboxes, belt drives, chain drives, shafts, bearings, and vibration
`mounts.
`
`10.
`I have used my mechanical engineering expertise to help resolve various
`problems involving engine failures, engine vibrations, gearbox failures, coupling failures,
`bearing failures, shaft misalignment, shaft fracture, chain drive failures, dredge hoist gear
`vibrations, and V-belt tension. I have tensioned, maintained, designed, and installed countless
`V-belt, poly-vee belt, flatbelt, and toothed belt drive components over the past 50 years.
`
`11.
`I have extensive experience with heavy equipment engineering and analysis,
`including tractor wheel scrapers, mining drills, riding trowels, tunnel boring machines, stackers,
`reclaimers, skid-steer loaders, telehandlers, and dredges. This work has involved personal injury
`claims, machine performance claims, product recalls, product defect allegations, and
`construction contract disputes.
`
`12.
`Around two-thirds of my current work relates directly to commercial disputes.
`The remainder is split between reactive failure analyses and proactive engineering work
`supporting, specifically, product design, product improvement, and the prevention of failures.
`
`13.
`I received my undergraduate degree in mechanical engineering from Lehigh
`University; two master’s degrees, in engineering and applied mathematics, from Brown
`University; and a Ph.D. in engineering, also from Brown University. I currently mentor the local
`high school robotics team, teaching them aspects of mechanical engineering design, metal
`fabrication, and machine shop practice.
`
`14.
`A copy of my curriculum vitae, including my publication history for the past ten
`years (and beyond) is attached hereto as Exhibit A, and a list of my trial and deposition
`testimony over the last four years is attached hereto as Exhibit B. A list of the materials which I
`have reviewed while preparing this declaration is attached as Exhibit C.
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`15.
`In forming my opinions, I rely on my knowledge, training, and experience in the
`field and on documents and information referenced in this Declaration. I hold my opinions to at
`least a reasonable degree of engineering certainty. This means I hold my opinions to a standard
`of at least more likely than not and base them on logical reasoning from the evidence. My
`opinions are based on the information available. I understand that the underlying dispute is
`ongoing. I reserve the right to supplement this opinion based on new information as the matter
`proceeds.
`
`16. My employer, Exponent, is being compensated by the Defendant at the rate of
`$585 per hour in 2022, which is Exponent’s standard hourly consulting rate for my time spent on
`this matter. Neither Exponent’s nor my compensation is contingent on the substance of my
`opinions or on the outcome of the above referenced matter. Neither Exponent nor I have a
`conflict of interest with respect to the Defendant or the Plaintiff.
`
`II.
`
`BACKGROUND ON THE LAW
`
`17.
`I am an engineer, not an attorney. Nevertheless, my analysis needs to be
`considered in light of U.S. Patent Law. My understanding of the law is based on discussions with
`Wilson Sonsini Goodrich and Rosati and my prior experience in patent litigation matters.
`
`18.
`The scope of a patent depends on the meaning of the claims. As parties in a patent
`dispute often have different ideas on scope, the meanings of the claims are often in dispute. I
`understand that in a Federal Court patent litigation, a Court determines the meaning or
`construction of any disputed claim terms via a Markman hearing and ruling. I understand that the
`Court has not yet held a Markman hearing or issued a claim construction ruling. If and when the
`Court issues a claim construction ruling, I will adopt the Court’s constructions.
`
`19.
`I understand that when interpreting the claims of a patent, one must defer to
`“intrinsic evidence” which includes the claim language, the patent specification, as well as the
`prosecution history. I further understand that patents cited as prior art within the patent
`specification are also considered to be intrinsic evidence. However, within this group I
`understand that the patent specification, including the claims, is considered to be “the single best
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`guide to the meaning of a disputed term.”3 I further understand that “extrinsic evidence” such as
`dictionaries, technical publications, and inventor or expert testimony may also be considered
`when interpreting the claims of a patent; however, such extrinsic evidence is considered to be of
`secondary relevance to any pertinent intrinsic evidence.
`
`20.
`I understand that when interpreting the claims of a patent, I must also do so based
`on the perspective of a hypothetical person of ordinary skill in the art (“POSA”) at the relevant
`priority date. The POSA is a hypothetical person presumed to have known the relevant art at the
`time of the invention but is unaware of the patent at issue. My understanding is that the priority
`date of the ’538 Patent is May 18, 2015.
`
`21.
`In my view, as of May 18, 2015, a POSA of the technology at issue would have a
`Bachelor of Science degree in mechanical engineering, applied physics, or a related degree and
`at least two years of engineering experience with mechanical power transmission and the
`application of heavy-duty engines.
`
`22.
`I am at least a POSA because, as of 2015, I held a BS in mechanical engineering
`for 24 years and had even more years of experience with heavy-duty engine applications in
`construction equipment, marine, stationary, and transportation applications, and similar years of
`experience with mechanical power transmission engineering including flexible couplings, V-belt
`drives, and gearboxes.
`
`23.
`
`Dr. Stein has opined that a POSA4
`
`… would have had a bachelor’s degree in mechanical engineering or an
`equivalent degree and two to five years of experience working on designing or
`developing machine powertrains in which a controller controls a powertrain’s
`internal combustion engine, coupled transmission and other powertrain
`components. Additional education may substitute for lesser work experience and
`vice versa. Also, a POSITA may have worked as part of a multidisciplinary team
`and drawn upon not only their own skills, but of others on the team, e.g., to solve a
`given problem. For example, an electrical or computer engineer may have been
`part of the team.
`
`
`3 Phillips v. AWH Corp., 415 F.3d 1303, 1324 (Fed. Cir. 2005), 1315-1316.
`4 Stein Declaration ¶19.
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`24.
`Dr. Stein states, “a POSITA (POSA) may have worked as part of a
`multidisciplinary team…” (emphasis added). This is an empty statement because it does not set a
`requirement for a POSA. As of the priority date of the ’538 Patent, a POSA under my definition
`would have necessarily understood the end function of controllers for mechanical power
`transmission and the application of heavy-duty engines. I would not expect a POSA to
`understand, say, underlying electronic component function in such a controller, and it is not
`necessary to do so to understand the technology.
`
`25.
`Nonetheless, I have often worked (and continue to work) with multidisciplinary
`teams including members whose skills include electrical and computer engineering. Regardless
`of which POSA definition is adopted for the’538 Patent, I qualify as more than a POSA and my
`opinions regarding the ’538 Patent would not change.
`
`III.
`
`“VARIABLE TRANSMISSION”
`
`A. Dr. Stein is Incorrect to Assert That a “Variable Transmission” Must be
`Stepless
`
`26.
`Dr. Stein opines that the term “variable transmission” should be construed as “a
`stepless transmission that can change transmission ratios seamlessly.” I disagree because this
`construction is inappropriately limiting, unsupported by the’538 Patent specification or the
`intrinsic evidence and would not help a trier of fact understand the scope of the claims. Dr. Stein
`is importing limitations from the ’538 Patent specification into the claims, which I understand is
`improper. He is also misreading the intrinsic evidence.
`
`27.
`As described above, I understand that the specification is an important piece of
`intrinsic evidence for construing “variable transmission.” Dr. Stein’s opinion relies almost
`exclusively on other evidence from outside the ’538 Patent specification for his construction.
`Dr. Stein’s declaration fails to discuss in detail how the term “variable transmission” appears in
`the ’538 Patent as a whole, instead only pointing to specific embodiments using a continuously
`variable transmission (CVT) as a sub-part of an overall transmission.5 I understand that a
`
`5 Stein Declaration, ¶39.
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`patent’s claims typically are not limited to disclosed embodiments. By focusing on specific
`embodiments, Dr. Stein reads limitations from the specification into the claims.6
`
`28.
`Dr. Stein relies almost entirely on limited examples of continuously or infinitely
`variable transmissions taken from U.S. Patent 8,645,105 to Parker (herein “Parker”). The
`examples that Dr. Stein cites from the ’538 Patent specification and Parker are just that,
`examples; there is nothing within the ’538 Patent specification which indicates the patentee
`envisioned “variable transmission” to be limited to the types of “stepless” examples Dr. Stein
`cites.
`
`29.
`For example, Dr. Stein cites to the ’538 Patent as support for his assertion that
`“variable transmissions are those ‘which allow for variations in the engine speed without
`affecting rotor speed.’”7 However, Dr. Stein fails to acknowledge the whole passage which he
`cites, which states:
`
`“Some milling machines, such as in U.S. Pat. No. 8,645,105 [sic] (‘Parker’),
`provide variable transmissions which allow for variations in the engine speed
`without affecting rotor speed” (emphasis added)
`
`This passage from the ’538 Patent (cited by Dr. Stein) points out that some milling machines
`provide variable transmissions that allow variations in engine speed without affecting rotor
`speed. Moreover, not all variable transmissions disclosed in Parker are continuously or infinitely
`variable. Accordingly, it is inappropriate for Dr. Stein to assert that the passage cited above
`teaches all “variable transmissions” necessarily require a transmission that allows variations in
`the engine speed without affecting rotor speed.
`
`30.
`Furthermore, Dr. Stein attempts to color the ’538 Patent’s incorporation of Parker
`as dispositive of the limitations he imposes on “variable transmission;” it is not. While Dr. Stein
`is correct that Parker discloses CVTs (continuously variable transmissions) as an “other type of
`transmission that provides a large range of gearing ratios,”8 Dr. Stein fails to mention that Parker
`
`6 I recognize that, in the case of “mean-plus-function” claiming, the claims may be limited to structure disclosed in
`the specification and equivalents, but, as far as I am aware, Wirtgen does not assert “variable transmission” is a
`means-plus-function term.
`7 Stein Declaration, ¶36.
`8 Parker, 9:21-24.
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`is comparing CVTs to “infinitely variable transmissions”9 (“IVTs”) as a sub-type of CVTs which
`are, in turn, a sub-type of “variable transmissions.” Indeed, Parker fails to explain how it views
`the difference between “infinitely” and “continuously” variable transmissions, or whether its
`view is any different than that found in Beachley and Frank (Exhibit T). After all, a continuously
`variable transmission can have an infinite number of steps, i.e., is infinitely variable.
`
`31.
`Comparison of Parker independent Claim 1 and its dependent Claim 12,
`independent Claim 22 and its dependent Claim 26, and independent Claim 30 and its dependent
`Claim 31 shows that Parker intends “variable transmission” to have broader scope than
`“continuously variable transmission” or “infinitely variable transmission.” Parker Claims 22 and
`30 claim “a first transmission connected to said engine, said first transmission having a plurality
`of input/output ratios.” This simply limits the first transmission to having two or more ratios, and
`certainly not necessarily an infinity of ratios. Corresponding Parker Claims 26 and 31 claim
`“wherein said first transmission is an infinitely variable transmission (or a continuously variable
`transmission)10.” Parker Claim 1’s relation to Claim 12 is practically identical. Thus, within
`Parker and consistent with the precept that dependent claims narrow the scope of independent
`claims, “variable transmissions” are a broader category of transmissions than continuously or
`infinitely variable transmissions. In fact, as Dr. Stein correctly points out, Parker teaches both
`muti-speed automatic and power shift transmissions as types of transmissions that provide “a
`large range of gearing ratios”11 and that it is within the scope of Parker to use “any transmission
`with a sufficiently large number of input/output ratios….and such transmissions need not be
`infinitely variable,”12 indicating that transmissions such as multi-speed automatic and power shift
`are variable transmissions. Parker Claims 22 and 30 suggest that Parker considers a transmission
`with two input/output ratios (a plurality) to have a sufficiently large number of input/output
`ratios. This is common sense: a two-speed transmission is a variable transmission – its speed
`ratio can be varied.
`
`
`
`9 Parker, 9:18-20.
`10 The phrase in parentheses does not appear in Claim 26, but that is irrelevant here.
`11 Parker, 5:2-4.
`12 Parker, 5:1-7.
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`32.
`This support from Parker effectively undermines Dr. Stein’s assertions that a
`“variable transmission” needs to be stepless or seamless. From a more fundamental perspective,
`both Parker and the ’538 Patent specification reinforce what a POSA would have understood: the
`use of the words “continuously” or “infinitely” modify the word “variable” and are narrower
`examples of the general class of “variable transmissions”; such transmissions include
`transmissions which are variable (e.g., have more than one gear ratio) but do not change gear
`ratios “continuously” or have an infinite number of gear ratios.
`
`33.
`Instead of examining what the full scope of the language “variable transmission”
`means (which includes CVT/IVTs, but is not limited to them), Dr. Stein generally only examines
`references concerning CVT/IVTs. In his analysis of these references, he demonstrates that these
`are indeed variable transmissions, and concludes that all variable transmissions must be
`CVT/IVTs; Dr. Stein’s analysis in this regard commits the logical fallacy of denying the
`antecedent.13 For example, Stein’s declaration cites to other exhibits,14 but those mainly tout the
`benefits of stepless or continuously variable transmissions, and do not resolve the construction of
`“variable transmission.” Exhibit R, namely U.S. Patent 9,864,347 to Laux (“the ’347 Patent”),
`teaches that “[T]ransmissions can principally be integrated in the drive train, for example, shift
`transmissions, so that continuous rotational speed variability of the milling drum is not provided.
`The variation of the rotational speed is then performed in accordance with the shift stages of the
`shift transmission.”15 This teaching suggests that Laux views a transmission with discrete shift
`stages as a variable transmission because there is variation of the output rotational speed that
`drives the milling drum.16
`
`B. A POSA Would Understand “Variable Transmission” to Mean a “Transmission
`that Can Change Transmission Ratios”
`
`34.
`There is ample evidence in the ’538 Patent to support Caterpillar’s construction of
`“variable transmission” as “a transmission that can change transmission ratios.” To wit, a POSA
`
`13 For example, it is a logical fallacy to begin with the knowledge “If A then B”, and then posit “Therefore, not A
`means not B”. Dr. Stein correctly opines that all CVT/IVTs are variable transmissions, but it is a logical fallacy to
`conclude that if a transmission is not a CVT/IVT then it is not a variable transmission.
`14 Stein Declaration, III. Materials Considered.
`15 ’347 Patent, 6:1-6.
`16 ’347 Patent, 5:61-6:24.
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`would have understood “variable transmission” to simply mean that the transmission ratio can be
`varied, which comports with Caterpillar’s construction and is common sense.
`
`35.
`For example, apart from referring to a specific embodiment using a CVT17 (see
`below), the term “variable transmission” is only used within the ’538 Patent specification to
`signify a transmission which can change gear ratios.18 A POSA would interpret this as a teaching
`that a “variable transmission” is simply a transmission that can change transmission ratios. If
`anything, the use of the term “gear ratio” would have suggested to a POSA that “variable
`transmissions” specifically use discrete gears, as opposed to stepless transmissions (such as
`hydrostatic, belt, or traction-based CVTs) where a “gear” is more of a notional construct.
`However, the ’538 Patent does include CVT transmissions as well, teaching embodiments
`wherein “The milling machine 100 may also include an engine 122 as a power source that may
`drive the rotor 118 via a hydrostatic, mechanical, or hydromechanical drive arrangement, such as
`a continuously variable transmission (CVT) 124, or the like”19 (emphasis added).
`
`36.
`The structure of the claims within the ’538 Patent also demonstrates that the term
`“variable transmission” is a broad group of transmissions (any transmission where the
`transmission ratio can be varied) which includes more specialized transmissions such as
`hydrostatic or purely mechanical CVTs. For example, Claim 1 discloses a “method of controlling
`a machine….through a variable transmission, comprising….adjusting a gear ratio of the variable
`transmission based on the engine speed and the desired rotor speed.
`
`37. While the ’538 Patent teaches the specific embodiment with a CVT 124, the ’538
`Patent specification does not describe any functionality of the invention which, in and of itself,
`requires a CVT; to wit, a POSA would have recognized that a wide variety of transmission
`options such as multi-speed automatic or power shift transmissions could also have been
`integrated into the invention as described in the ’538 Patent specification.
`
`17 ’538 Patent, 4:54-59.
`18 ’538 Patent, Abstract; ’538 Patent 1:59-60; ’538 Patent 2:4-5; ’538 Patent 2:16-17
`19 ’538 Patent, 2:63-67.
`
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`38.
`Indeed, the independent claims of the ’538 Patent disclose the use of a generalized
`variable transmission (emphasis and ellipses added):
`
`Independent Claim 1: A controller-implemented method of controlling a machine having
`a rotor coupled to an engine through a variable transmission, comprising:
`…….adjusting a gear ratio of the variable transmission based on the engine speed and
`the desired rotor speed.
`
`Independent Claim 6: A machine comprising: …..a variable transmission operatively
`coupled to an output of the engine; and…..a controller in electrical communication with
`one or more of the engine, variable transmission, and the rotor, the controller being
`configured to….adjust a gear ratio of the variable transmission based on the engine
`speed to maintain a desired rotor speed.
`
`In view of the specification of the ’538 Patent, a POSA would infer that the only requirements of
`the variable transmission of Claims 1 and 6 would be that the transmission would be adjustable
`between two or more gear ratios. A POSA would know that this would have encompassed a wide
`variety of transmissions including multi-speed automatic, power shift, and CVT-type
`transmissions.
`
`39.
`In addition to inventions claiming a general “variable transmission” as in Claims
`1 and 6 of the ’538 Patent, a subset of dependent claims of the ’538 Patent claim more limited
`inventions using transmissions with stepless transitions between gear ratios. Limitations
`comprising a variable transmission with continuously adjustable gear ratios are disclosed within
`Claim 3, which limits Claim 1 through the disclosure of a hydrostatic transmission; Claim 7,
`which limits Claim 6 through the disclosure of a gear set and hydraulic motor within the
`transmission; and Claim 9, which limits Claim 6 through the disclosure of a hydraulic motor
`used in the transmission. A POSA would have recognized that these dependent claims disclose
`stepless CVTs or IVTs with continuously adjustable gear ratios, narrowing the disclosures of
`independent Claims 1 and 6. This means that Claims 1 and 6 are broader and the transmissions
`claimed therein are not limited to CVTs or IVTs.
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`40. My opinions are held to a reasonable degree of engineering certainty, meaning
`they rise to the level of at least more likely than not and are based on logical reasoning from the
`evidence. My opinions are based on the information available to me. If additional information
`becomes available, I reserve the right to supplement this declaration. I declare under penalty of
`perjury that the foregoing is true and correct to the best of my knowledge.
`
`
`
`Dated October 13, 2022
`
`
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`
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`____________________________________
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`Richard W. Klopp, Ph.D., P.E., F.A.S.M.E
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`Case 1:17-cv-00770-JDW-MPT Document 120-19 Filed 11/17/22 Page 14 of 29 PageID #:
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`Exhibit A: Curriculum Vitae
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`Richard W. Klopp, Ph.D., P.E., F.A.S.M.E.
`
`
`Principal Engineer | Mechanical Engineering
`149 Commonwealth Drive | Menlo Park, CA 94025
`(650) 688-6777 tel | rklopp@exponent.com
`
`
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`Professional Profile
`
`Dr. Klopp specializes in mechanical engineering and the mechanics of materials. He has particular
`expertise in laboratory-based testing, mechanical design, failure analysis and prevention, and
`manufacturing. His mechanical engineering background includes extensive experience in machining;
`machinery; analysis of fasteners, gears, and bearings; power generation; mechanical power
`transmission; optical systems; metrology; hydraulic systems; and fluid handling components. His
`mechanics of materials background includes extensive experience in fracture mechanics, high strain
`rate deformation and failure, impact and shock wave loading, mechanical testing and optical
`measurement methods.
`
`Dr. Klopp has applied his expertise to machine tools, industrial machinery, laser systems, electric and
`gas utilities, automobiles, trucks, potable, fire protection, and wastewater system components,
`plumbing, computer equipment, electronic packaging, consumer products, hand and power tools,
`medical equipment and medical devices, toys, recreational products, railroad tank cars, chemical
`storage tanks, underground tunnels, armor/antiarmor, and missile defense. Dr. Klopp has studied the
`mechanical behavior of metals, ceramics, rock, plastics, advanced composites, liquids, and wood.
`
`Dr. Klopp has provided consulting services on matters of industrial problem solving, product recalls,
`product defect litigation, intellectual property disputes, national defense, and insurance issues.
`
`Dr. Klopp is a skilled machinist qualified to set up and operate machine tools such as lathes, milling
`machines and other shop equipment. His personal machine shop is equipped with a computer
`numerical control (CNC) milling machine, a manual milling machine, two toolroom lathes, grinders, and
`a wide variety of supporting tooling and equipment.
`
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`Prior to joining Exponent, Dr. Klopp was a Research Engineer at SRI International and worked as a
`Research Associate at Brown University. He is a Fellow of the American Society of Mechanical
`Engineers.
`
`Academic Credentials & Professional Honors
`
`Ph.D., Engineering, Brown University, 1987
`
`Sc.M., Applied Mathematics, Brown University, 1986
`
`Sc.M., Engineering, Brown University, 1984
`
`B.S., Mechanical Engineering, Lehigh University, 1981
`
`Fellow, American Society of Mechanical Engineers, 2019
`SRI International Postdoctoral Fellowship
`
`University Fellowship, Brown University
`
`Ingersoll Rand Award
`
`Alfred Stenning Award
`
`Pi Tau Sigma
`
`Tau Beta Pi
`
`Licenses and Certifications
`
`Licensed Professional Mechanical Engineer, California, #M31530
`
`Licensed Professional Engineer, Nevada, #024867
`
`Licensed Professional Engineer, Texas, #113452
`
`Licensed Professional Engineer, Washington, #52816
`
`Licensed Professional Engineer, Michigan, # 6201069727
`
`Prior Experience
`
`Research Engineer, SRI International Poulter Laboratory, 1987-1999
`
`Postdoctoral Fellow, SRI International Poulter Laboratory, 1986-1987
`
`2111403.000 - 9669
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`Professional Affiliations
`
`Community Service
`
`Mentor to the FIRST Robotics teams at Woodside High School, Woodside, CA.
`
`Affiliations
`
`American Society of Mechanical Engineers (ASME - Fellow)
`
`ASME B16 Subcommittee L - Gas Shutoffs and Valves
`
`ASME B5 Technical Committee 52 - Machine Tool Performance
`
`ASME B5 Technical Committee 64 – Linear Positioning
`
`ASM International — American Society for Metals
`
`American Water Works Association
`
`Society of Manufacturing Engineers
`
`Peer reviewer for ASM International Journal of Materials Engineering and Performance
`
`Peer reviewer for Proceedings of the iMeche Part E: Journal of Process Mechanical Engineering
`
`Peer reviewer for ASME 2010 International Design Engineering Technical Conferences (IDETC) and
`Computers and Information in Engineering Conference(CIE)
`
`Peer reviewer for ASME 2013 International Design Engineering Technical Conferences (IDETC) and
`Computers and Information in Engineering Conference (CIE)
`
`Peer reviewer for ASME 2015 International Design Engineering Technical Conferences (IDETC) and
`Computers and Information in Engineering Conference (CIE)
`
`Peer reviewer for ASME 2015 International Mechanical Engineering Congress and Exhibition (IMECE)
`
`Community Service
`
`2111403.000 - 9669
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`Mentor and machine tool maintainer and repairman for the FIRST Robotics team at Woodside High
`School, Woodside, CA.
`
`Publications
`
`Spak KS, Klopp RW. Traces of bentonite prevent bonding of electrofusion pipeline joints. Pipeline &
`Gas Journal, pp. 50-52, December 2017.
`
`Klopp RW. Failure analysis of redundant escalator chain pin retention mechanisms. Proceedings of the
`ASME 2011 International Mechanical Engineering Congress & Exposition (IMECE2011), Denver, CO,
`ASME, November 11-17, 2011.
`
`Klopp RW, Dugnani R, Edmonds JS. The role of brush spring kinking in a generator flash-over incident.
`Proceedings, 43rd North American Power Symposium (NAPS2011), Boston, MA, IEEE, August 4-6,
`2011.
`
`Tokheim RE, Cooper T, Lew B, Klopp RW, Groethe MA, Peterson RR, Williamson D, Blanchard JP.
`Computational modeling of Z plasma-radiation-source debris. Journal of Radiation Research
`Engineering 2004; 20(1).
`
`Duffner DH, Klopp RW, Wagner-Jauregg A, Sire RA, Webster EM. Component damage from printed
`circuit board loading. Proceedings, IPC Printed Circuits Expo 2002, Long Beach, CA, IPC, pp. S12-4-1-
`S12-4-8, March 2002.
`
`Kirkpatrick SW, Klopp RW. Hazard assessment for p