Case 1:17-cv-00770-JDW Document 221-32 Filed 10/05/23 Page 1 of 11 PageID #: 17389
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`Case 1:17-cv-00770-JDW Document 221-32 Filed 10/05/23 Page 2 of 11 PageID #: 17390
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`1/3/2018
`
`337-TA-1067
`Highly Confidential - Attorneys' Eyes Only
`
`Timothy Lindholm
`
`Page 1
` UNITED STATES INTERNATIONAL TRADE COMMISSION
` Washington, D.C.
`
`In the Matter of )
` )
`CERTAIN ROAD MILLING )Inv. No. 337-TA-1067
`MACHINES AND COMPONENTS )
`THEREOF. )
`_______________________________)
`
` VIDEOTAPED DEPOSITION OF TIMOTHY J. LINDHOLM
` Maple Grove, Minnesota
` January 3, 2018 - 9:00 a.m.
`
` HIGHLY CONFIDENTIAL
` ATTORNEYS' EYES ONLY
`
`Reported by: Lisa A. Blanks, RPR, CRR
`Certified Reporter No. 50803
` ____________________________________________________
` DIGITAL EVIDENCE GROUP
` 1730 M Street, NW, Suite 812
` Washington, D.C. 20036
` (202) 232-0646
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 221-32 Filed 10/05/23 Page 3 of 11 PageID #: 17391
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`1/3/2018
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`337-TA-1067
`Highly Confidential - Attorneys' Eyes Only
`
`Timothy Lindholm
`
`Page 64
`municipality is requiring a job, they might say they
`need two inches of material milled off the road, and
`that's what defines what they need to do. So it's
`job-site specific.
` Q. Are there -- we talked about certain other
`sensors, I think, with -- at least with the scraper
`blade and the mold board. Are there sensors that are
`involved in detecting the height of each one of those
`lifting columns?
` A. Yes.
` Q. How do those sensors work?
` A. I don't know exactly how they work.
` Q. Do you know what type of sensors they are?
` A. No. I just know that they are
`position-sensing cylinders.
` Q. And another feature is automatic disengagement
`feature. Have you ever heard of that before?
` A. Yes.
` Q. What is your understanding of that feature?
` A. The rotor will automatically disengage if
`certain conditions are met.
` Q. And what are those conditions?
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`Digital Evidence Group C'rt 2018
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`202-232-0646
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`Case 1:17-cv-00770-JDW Document 221-32 Filed 10/05/23 Page 4 of 11 PageID #: 17392
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`1/3/2018
`
`337-TA-1067
`Highly Confidential - Attorneys' Eyes Only
`
`Timothy Lindholm
`
`Page 65
` A. If the machine is traveling in reverse and
`either of the two side plates is lifted above the height
`of the rotor.
` So they hang below. And in normal
`circumstances when they're hanging all the way down, if
`they're lifted above the surface of the rotor that would
`normally expose the rotor, then we would shut it off.
` Q. So when you're traveling in reverse, why would
`you want to shut off the rotor if those conditions are
`met?
` A. It's just a precautionary measure for safety
`reasons for it to protect operator, bystanders.
` Q. So beyond the sensors on the side plates that
`you mentioned, are there any other conditions that must
`be met before the disengagement feature activates?
` A. Not that I'm aware.
` Q. So if those conditions are met based on the
`sensed values there, how does the disengagement actually
`occur?
` A. The clutch disengages and the tensioning
`device for the rotor drive belt disengages.
` Q. Is there anything else that happens besides
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`Digital Evidence Group C'rt 2018
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`202-232-0646
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`
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`Case 1:17-cv-00770-JDW Document 221-32 Filed 10/05/23 Page 5 of 11 PageID #: 17393
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`1/3/2018
`
`337-TA-1067
`Highly Confidential - Attorneys' Eyes Only
`
`Timothy Lindholm
`
`Page 66
`the disengagement of the rotor, if those conditions are
`met?
` A. No.
` Q. Are there any other sensors besides the
`sensors on the side plate that are used in relation to
`the disengagement feature?
` A. No other sensors. I believe if a command to
`raise the mold board is given, that would also disengage
`the rotor. But there's no sensors. It's just if a
`machine sees a command for a raise.
` Q. So when it's traveling in reverse, there's no
`sensor on that back mold board that would also serve to
`detect the height of the casing?
` A. No.
` Q. And that, again, is functionality that's in
`the PM600 series and the 800 series?
` A. Yes.
` Q. How about the ride control feature, have you
`ever heard of that term?
` A. Yes.
` Q. What's your understanding of that?
` A. I don't know a lot of the details.
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`Digital Evidence Group C'rt 2018
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`202-232-0646
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`Case 1:17-cv-00770-JDW Document 221-32 Filed 10/05/23 Page 6 of 11 PageID #: 17394
`
`1/3/2018
`
`337-TA-1067
`Highly Confidential - Attorneys' Eyes Only
`
`Timothy Lindholm
`
`Page 138
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` A. Yes.
` Q. And would those also equally apply to the
`PM800 series machines?
` A. Yes.
` Q. Is any portion of the lifting columns or the
`piston cylinders or the position sensors that we just
`discussed on these pages manufactured by a third party?
` A. I don't know who manufactures these. I don't
`remember.
` Q. If you want to turn back to the document
`titled "Technical Presentation for the PM620, 622 cold
`planers." And this one began with Bates number
`CAT0004149.
` MS. SAHLSTEN: Just to be clear, we're talking
`about Exhibit 5?
` MR. RICHARDSON: Exhibit 5, correct.
` Q. BY MR. RICHARDSON: So I will direct your
`attention to page ending in 4508. So on this page,
`there's a section identified as "Rotor Disengagement,"
`and then a subsequent section identified as "Rotor
`Exposure During Reverse Travel." Do you see that?
` A. Yes.
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 221-32 Filed 10/05/23 Page 7 of 11 PageID #: 17395
`
`1/3/2018
`
`337-TA-1067
`Highly Confidential - Attorneys' Eyes Only
`
`Timothy Lindholm
`
`Page 139
` Q. Feel free to take a look at what's included in
`those sections. But to your understanding, is what's
`being described as the, "rotor exposure during reverse
`travel," the same as the automatic disengagement feature
`that we were talking about earlier today?
` MS. SAHLSTEN: Objection, vague.
` THE WITNESS: The first sentence says, "An
`automatic rotor disengagement feature," so yes.
` Q. BY MR. RICHARDSON: So in that first sentence
`there, continuing on, it says, "An automatic rotor
`disengagement feature detects a condition where the
`rotor could come into contact with the surface while the
`machine is traveling in reverse. If the rotor exposure
`condition is detected, the rotor drive is disengaged."
` And then the following paragraph proceeds to
`say that, "For this feature, the side plates and the
`mold board positions are monitored."
` Do you see that?
` A. Yes.
` Q. And so that is the discussion of the side
`plate sensors and the mold board sensors that we were
`discussing earlier?
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`Digital Evidence Group C'rt 2018
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`202-232-0646
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`
`Case 1:17-cv-00770-JDW Document 221-32 Filed 10/05/23 Page 8 of 11 PageID #: 17396
`
`1/3/2018
`
`337-TA-1067
`Highly Confidential - Attorneys' Eyes Only
`
`Timothy Lindholm
`
`Page 140
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` A. Yes.
` Q. So the mold board position sensor -- I believe
`earlier you indicated that for the mold board position
`sensor to trigger a disengagement of the rotor, it had
`to be that the mold board was brought up -- was extended
`up; is that correct?
` MS. SAHLSTEN: Objection, mischaracterizes
`previous testimony.
` THE WITNESS: Yeah. The mold board has to be
`raised for this feature to engage.
` Q. BY MR. RICHARDSON: And is that a manual
`raising of the mold board, or is that a mold board that
`becomes raised during reverse travel?
` A. It's not going to matter whether it's manual
`or not. If the sensor detects that it's raised, it will
`shut it off.
` Q. When you say, "detects that it's raised," how
`high does it need to be detected -- or how high does it
`need to be raised?
` A. I don't know the exact number.
` Q. Is it safe to say that it needs to be raised
`higher than the rotor itself?
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 221-32 Filed 10/05/23 Page 9 of 11 PageID #: 17397
`
`1/3/2018
`
`337-TA-1067
`Highly Confidential - Attorneys' Eyes Only
`
`Timothy Lindholm
`
`Page 141
` A. That's how I understand it to be, yes.
` Q. And so then if any of the position sensors on
`the side plates or the mold board detect that
`predetermined height, then the rotor disengages?
` MS. SAHLSTEN: Objection, calls for expert
`testimony.
` THE WITNESS: I'm not familiar with all the
`details of how the software is written, but the mold
`board position, there's not a -- there's not a -- an
`exact position that's being monitored with the mold
`board.
` There's just two switches. There's either
`open or closed. If one of them is open, then it knows
`it's raised above a certain point.
` Q. BY MR. RICHARDSON: So it's just a threshold
`height?
` A. Yes.
` Q. If the position sensors measure that the
`height has exceeded that threshold, besides the rotor
`becoming disengaged, are there any other functions that
`occur?
` MS. SAHLSTEN: Objection, calls for expert
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`Digital Evidence Group C'rt 2018
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`202-232-0646
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`Case 1:17-cv-00770-JDW Document 221-32 Filed 10/05/23 Page 10 of 11 PageID #: 17398
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`1/3/2018
`
`337-TA-1067
`Highly Confidential - Attorneys' Eyes Only
`
`Timothy Lindholm
`
`Page 142
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`testimony.
` THE WITNESS: Not that I'm aware.
` Q. BY MR. RICHARDSON: And so the operation of
`that rotor disengagement feature, is that an accurate
`depiction of the rotor disengagement feature on the
`PM600 machines?
` A. That's what this document is for.
` So I can only assume that it's yes, but I did
`not create this document.
` Q. Would you have any reason to believe that that
`description did not also apply to the PM800 machines?
` A. No.
` Q. And was the rotor device engagement feature
`available on the PM600 machines when they were first
`introduced?
` A. Yes.
` Q. If you want to turn to the page ending in
`4358. So the first four paragraphs or so on this page
`provide a description of the ride control feature. Do
`you see that?
` A. Yes.
` Q. And feel free to review those paragraphs if
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 221-32 Filed 10/05/23 Page 11 of 11 PageID #: 17399
`
`tl3l20L8
`
`337-TA-L067
`Highly Confidential - Attorneys' Eyes Only
`
`Timothy Lindholm
`
`Page 165
`
`STATE OF MINNESOTA )
`) ss.
`COUNTY OF HENNEPIN )
`BE IT KNOVüN that the foregoing deposition was
`taken before me, Lisa A. Bfanks, RPR, CRR, and by virtue
`thereof authorized to administer an oath; that the
`witness before testifying was duly sworn by me
`to testify
`to the whole truth;
`that the questions
`propounded to the wltness and the ans\^rers of the witness
`thereto were taken down by me 1n shorthand and
`thereafter reduced to print by computer-aided
`transcription under my directi-on; that pursuant to
`request, notificat.ion was provided that the deposition
`is availabfe for review and signature; that the
`transcript consisting of G1,25 pages is a fulf,
`true and
`accurate transcript of afl_ proceedings and testlmony had
`and adduced upon the taking of said deposj-tion, afl_ done
`to the best of my skilf and abil_ity.
`I FURTHER CERTfFY that I am in no way related
`to nor employed by any of the parties hereto nor am I in
`any way interested in the outcome hereof.
`DATED at Minneapolis, MJ_nnesota, January 4,
`
`2015.
`
`VI
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`202-232-0646
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`
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