Case 1:17-cv-00770-JDW Document 221-20 Filed 10/05/23 Page 1 of 8 PageID #: 17162
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`Exhibit 20
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`Case 1:17-cv-00770-JDW Document 221-20 Filed 10/05/23 Page 2 of 8 PageID #: 17163
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`CONTAINS CONFIDENTIAL BUSINESS INFORMATION
`SUBJECT TO THE PROTECTIVE ORDER
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`UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`
`Before the Honorable David P. Shaw
`Administrative Law Judge
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`
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`In the Matter of
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`CERTAIN ROAD MILLING MACHINES
`AND COMPONENTS THEREOF
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`Investigation No. 337-TA-1067
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`REBUTTAL WITNESS STATEMENT OF MR. ERIC ENGELMANN
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`RX-0993C.0001
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`RX-0993C
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`Case 1:17-cv-00770-JDW Document 221-20 Filed 10/05/23 Page 3 of 8 PageID #: 17164
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`CONTAINS CONFIDENTIAL BUSINESS INFORMATION
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`A:
`
`Yes, these are electrical schematics for the 2018 Product Updates to the Ride Control
`feature.
`
`Q24. How long will it be until the finalized design can enter production?
`A:
`The timing for this design would depend on supplier lead time for the valves, harnesses,
`and other parts needed for this change, which can vary depending on capacity constraints.
`Based on typical supplier lead times for these components, I would estimate about three
`months from the time of release of the design to production.
`
`III. Caterpillar’s Drum Exposure Concept
`
`Q25. Mr. Engelmann, are you familiar with Caterpillar’s reverse travel shutoff feature in
`the PM300, PM600, and PM800 series machines?
`
`A:
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`Yes, I am familiar with that feature.
`
`Q26. Can you describe generally how this feature works?
`A:
`The fundamental goal of the reverse travel shutoff feature is to make sure that the rotor is
`not exposed when the machine is backing up and the rotor is operating. Under this
`design, we want a rotor shutoff to occur at any point when the drum becomes exposed
`during reverse travel, regardless of whether the drum and drum enclosure are high above
`the ground or near and about to contact the ground. To achieve this goal, we use a control
`system with sensors that ensure that the moldboard and side plates are below the bottom
`surface of the rotor any time the machine is in reverse with the rotor drive clutch
`engaged. Essentially, the sensors are monitoring the position of the side plates and
`moldboard relative to an imaginary plane tangent to the bottom of the rotor. Any time
`any one of the side plates or moldboard is raised above that plane for more than 0.5
`seconds while the machine is in reverse with the rotor engaged, the control system sends
`a signal to shut the drum off―regardless of where the drum is positioned relative to the
`ground at that time.
`
`Q27. What is measured by the sensors you just mentioned?
`A:
`The sensors measure the positions of the side plates and the moldboard relative to the
`machine frame.
`
`Q28. Does this feature measure the distance between the drum and the ground?
`A:
`No, the reverse travel shutoff feature has nothing to do with the distance between the
`drum and the ground. Any time any one of the side plates or moldboard is raised above
`the bottom of the drum for more than 0.5 seconds while the machine is in reverse with the
`rotor engaged, the control system sends a signal to shut the drum off. This can occur at
`any distance between the drum and the ground.
`
`Q29. Why is Caterpillar’s reverse travel shutoff feature designed to be able to shut off the
`rotor at any distance to the ground?
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`6
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`RX-0993C.0007
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`CONTAINS CONFIDENTIAL BUSINESS INFORMATION
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`A:
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`Because our design is a rotor exposure design, not a distance-to-the ground design. By
`preventing the rotor from being exposed below the side plates or rear door during reverse
`travel regardless of the distance to the ground, our system prevents injuries that
`potentially could occur even when the rotor is raised high above the ground. That is why
`our reverse travel shutoff feature does not measure or take into consideration the distance
`between the drum and the ground—that distance it is not relevant to the decision of
`whether to shut off the drum.
`
`Q30. Why does this feature only operate when the machine is going in reverse?
`A:
`The feature only operates in reverse because this is the best way to integrate the safety
`requirement with the reality of milling operation. The side plates and moldboard do not
`need to be raised when travelling in reverse, but they may need to be raised when
`performing milling in the forward direction.
`
`Q31. I’d like you to look at a few video exhibits: RPX-0037C (2018 Model Video-5), RPX-
`0038C (2018 Model Video-6), RPX-0039C (2018 Model Video-7), RPX-0040C (2018
`Model Video-8), RPX-0041C (2018 Model Video-9), RPX-0042C (2018 Model Video-
`10), RPX-0043C(2018 Model Video-11), RPX-0044C (2018 Model Video-12), RPX-
`0045C (2018 Model Video-13), RPX-0046C (2018 Model Video-14), and RPX-0047C
`(2018 Model Video-15). Do you recognize these videos?
`
`A:
`
`Yes, I do. These are videos taken to demonstrate the reverse travel shutoff feature we
`have been discussing.
`
`Q32. Where were these videos taken?
`A:
`The videos were taken at a Caterpillar Research & Development facility in Minnesota.
`
`Q33. What machine is depicted in these videos?
`A:
`This is a Caterpillar PM622 machine, the same machine that has the 2018 Product
`Updates that I described earlier. However, as I already discussed, the 2018 Product
`Updates did not change anything about the reverse travel shutoff feature. Therefore, the
`reverse travel shutoff feature in these videos is representative of this feature in all the
`PM600 and PM800 series machines.
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`Q34. Do you know who took these videos?
`A:
`Yes, I do. These videos were taken by Paul Koenen and Jacob Simmer.
`
`Q35. Do these videos show accurately how the drum exposure concept functions on the
`PM300, PM600 and PM800 Series machines?
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`A:
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`Yes, they do. These videos show several general scenarios that illustrate Caterpillar’s
`drum exposure concept.
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`Q36. What is the first scenario shown in these videos?
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`RX-0993C.0008
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`CONTAINS CONFIDENTIAL BUSINESS INFORMATION
`SUBJECT TO THE PROTECTIVE ORDER
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`A:
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`The first scenario is shown in RPX-0037C, RPX-0038C, and RPX-0040C. In these
`videos, the moldboard and side plates are lowered below the level of the drum, and the
`machine travels in reverse when the drum is still rotating. When the left side plate is
`raised above the drum, the reverse travel shutoff feature is activated because the rotor has
`become exposed, and the drum shuts off.
`
`Q37. What is the next scenario shown in these videos?
`A:
`The next scenario can be seen in RPX-0043C, RPX-0044C, and RPX-0046C. In these
`videos, the moldboard and side plates are lowered below the drum and set high above the
`ground, and the machine travels in reverse when the drum is still rotating. When the
`scraper blade is raised above the drum, the reverse travel shutoff feature is activated
`because the rotor has become exposed, and the drum shuts off.
`
`Q38. What is the next scenario shown in these videos?
`A:
`The next scenario can be seen in RPX-0045C. In this video, the moldboard and side
`plates are lowered below the drum and set just above ground level, and the machine
`travels in reverse when the drum is still rotating. When the scraper blade is raised above
`the drum, the reverse travel shutoff feature is activated because the rotor has become
`exposed, and the drum shuts off.
`
`Q39. What is the fourth scenario shown in these videos?
`A:
`The next scenario can be seen in RPX-0039C. In this video, the moldboard and side
`plates are lowered below the drum and set just above ground level, and the machine
`travels in reverse when the drum is still rotating. When the left side plate is raised above
`the drum, the reverse travel shutoff feature is activated because the rotor has become
`exposed, and the drum shuts off.
`
`Q40. Are there any other scenarios shown in these videos?
`A:
`Yes, another scenario can be seen in RPX-0047C. In this video, the moldboard and side
`plates are lowered below the drum and set above ground level, and the machine travels in
`reverse when the drum is still rotating. As the machine is travelling in reverse, the entire
`drum assembly, including the side plates and the moldboard, are lowered toward the
`ground. The moldboard reaches the ground and makes contact, but remains below the
`level of the rotor. When the moldboard makes contact, the drum continues to rotate
`because it is still not exposed.
`
`Q41. Any more scenarios shown in these videos?
`A:
`Yes, there are several more scenarios illustrated in the videos. For example, in RPX-
`0046C, the machine can be seen travelling in reverse with the drum rotating, but not
`exposed. In this video, the drum never shuts off because it never becomes exposed. In
`RPX-0041C, the side plates and moldboard were initially below the level of the drum, but
`before the machine begins travelling in reverse, the left side plate is raised to expose the
`drum. At this point the drum is still rotating, but when the machine begins travelling in
`8
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`RX-0993C.0009
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`CONTAINS CONFIDENTIAL BUSINESS INFORMATION
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`reverse, the drum shuts off because it is exposed in the reverse direction. Finally, in RPX-
`0042C, the same scenario can be seen, but in this case, the scraper blade is raised instead
`of the left side plate.
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`Q42. Are there any differences in the physical design of the reverse shutoff feature
`between the PM300, PM600, and PM800 Series machines?
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`A:
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`There are some minor differences between the design in the PM300 and the design in the
`PM600 and PM800. In the PM600 and PM800, each side plate has two cylinders with
`position sensors integrated to detect their position, and the rear moldboard has two
`magnetic switches that are used to detect the position based on switch logic. On the
`PM300, each side plates still has two cylinders with position sensors integrated to detect
`their position, but the moldboard has only one cylinder with a PSC position sensor in it
`used to detect its height. Therefore, the only physical difference is how we sense the
`height on the moldboard.
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`Q43. Are you familiar with the source code for the reverse travel shutoff feature in the
`PM300, PM600, and PM800 series machines?
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`A:
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`At a high level, yes.
`
`Q44. Are there any differences in the source code between the PM300 and the PM600 and
`800?
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`A:
`
`Yes, there are also some differences in the source code between these machines. For
`example, on PM600 and PM800, the code looks at the individual sensors on the front and
`rear of side plate. If the measurement from either sensor either gets above a threshold
`point, it will shut the drum off. In the PM300, the system uses the two sensors on each
`side plate to calculate the side plate positions at the centerline of the drum. Those
`calculated values for the side plate heights are used in determining whether the rotor is
`exposed for reverse travel or not. So, where the PM600 and PM800 look at four
`individual values when determining whether the drum is exposed below the side plates,
`the PM300 is looks at two calculated values when determining whether the drum is
`exposed below the side plates. But these two calculated values are obtained by analyzing
`information from the four side plate sensors on the PM300.
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`Q45. I’m handing you RX-0083C (Caterpillar Source Code). Do you recognize this?
`A:
`Yes, this is a copy of source code printouts for various Caterpillar cold planers.
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`Q46. Does it have the drum exposure code you just discussed?
`A:
`Yes, it does. Relevant code for the PM600 and PM800 machines is on pages
`CAT_SourceCode_001037-001055, and in particular, on page
`CAT_SourceCode_001054. Relevant code for the PM300 series machine is on pages
`CAT_SourceCode_001022-001036, and in particular, on pages
`CAT_SourceCode_001035-001036.
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`RX-0993C.0010
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`CONTAINS CONFIDENTIAL BUSINESS INFORMATION
`SUBJECT TO THE PROTECTIVE ORDER
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`IV. Caterpillar’s Leg Sensors
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`Q47. Mr. Engelmann, I’d like to talk about the sensors in the leg columns on
`Caterpillar’s machines. Are you familiar with these sensors?
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`A:
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`Yes, I am.
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`Q48. Can you describe these sensors generally?
`A:
`Yes. The sensor itself has a body, or head, with a rod that protrudes from it. The head of
`the sensor is housed inside the head end of the hydraulic cylinder and the sensor rod
`protrudes into a hole that is bored into the rod of the hydraulic cylinder. In addition to the
`sensor, there is a separate ring magnet which is the target of the sensor.
`
`Q49. I’m handing you RX-0146C (PM620 Parts Manual). Do you recognize this
`document?
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`A:
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`Yes, this is the Parts Manual for the PM620 Cold Planer.
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`Q50. Turning to page RX-01246C.0569, do you recognize the figure on this page?
`A:
`Yes. This is an illustration of the leg cylinder I just mentioned, and specifically shows the
`ring magnet, labelled 4, and the linear position sensor, labeled 5.
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`RX-01246C.0569
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`Q51. Why are the ring magnet and linear position sensor labeled separately in this
`drawing?
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`A:
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`Because they are separate parts. The magnet is what the sensor is looking for. As you can
`see in that illustration, the magnet surrounds the rod, and that is what the sensor is
`detecting. The sensor isn’t connected on two ends—it is only connected to the cylinder
`on one end, and there is a clearance to the target. Further, from a serviceability
`standpoint, the magnet is called out as a separate component from the sensor because
`these are different replaceable components. As you can see on this page, the magnet is
`Part No. 217-3311, while the sensor is Part No. 384-3767.
`
`Q52. If you order Part No. 384-3767, will it come with a ring magnet?
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`10
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`RX-0993C.0011
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`Case 1:17-cv-00770-JDW Document 221-20 Filed 10/05/23 Page 8 of 8 PageID #: 17169
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`CONTAINS CONFIDENTIAL BUSINESS INFORMATION
`SUBJECT TO THE PROTECTIVE ORDER
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`RPX-0034C
`RPX-0037C
`RPX-0038C
`RPX-0039C
`RPX-0040C
`RPX-0041C
`RPX-0042C
`RPX-0043C
`RPX-0044C
`RPX-0045C
`RPX-0046C
`RPX-0047C
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`2018 Swiveling Actuator Retract
`2018 Model Video-5
`2018 Model Video-6
`2018 Model Video-7
`2018 Model Video-8
`2018 Model Video-9
`2018 Model Video-10
`2018 Model Video-11
`2018 Model Video-12
`2018 Model Video-13
`2018 Model Video-14
`2018 Model Video-15
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`A:
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`Yes, they do.
`
`Q60. Does this statement contain your own answers to the questions from counsel?
`A:
`Yes, it does.
`
`Q61. Are your answers to the questions from counsel true and correct to the best of your
`knowledge and belief?
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`A:
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`Yes, they are.
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`Date: March 27, 2018
`
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`Eric S. Engelmann
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`13
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`RX-0993C.0014
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