Case 1:17-cv-00770-JDW Document 229-22 Filed 10/05/23 Page 1 of 23 PageID #: 23682
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`Exhibit 69
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`Case 1:17-cv-00770-JDW Document 229-22 Filed 10/05/23 Page 2 of 23 PageID #: 23683
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`WIRTGEN AMERICA, INC.
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`Plaintiff
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`CATERPILLAR, INC.
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`Defendant and Counter-Plaintiff
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`____________________________________/
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`C.A. No. 1:17-cv-00770-JDW-MPT
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`OPENING EXPERT REPORT OF DR. ADAM SORINI
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`2111403.000 - 1833
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`115. As shown in Figure 13 below, other displays of the controller UI indicate the
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`location and general shape of the water tank (red elements in left panel below) and water pump
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`(red elements in right panel below).
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`Figure 13:
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`UI display screens of the electronic controller indicating shape and
`location of the water tank (left) and water pump (right).
`116. The location of the “sprinkler unit,” which includes the spray bars discussed above
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`is shown in red (emphasis in original) in Figure 14 below.
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`Figure 17:
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`Photographs illustrating how the operator can change the overall
`strength of the water spray. The left panel shows the Auto
`percentage set to 45. The right panel shows the Auto percentage
`increased to 50.
`120. During the initial operation of the W 210 Fi, the “Auto” percentage was set to
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`“10%.” This setting was ostensibly chosen by the operator because the ground was already
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`relatively wet due to a rain the previous day, and we were milling dirt rather than a harder substance
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`like asphalt. During operation we later changed the setting to “100%” and observed how the
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`amount of sprayed water increased as well as how the estimated amount of remaining water
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`(remaining spray operation time) changed.
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`121. Figure 18 (left panel) below shows the W 210 Fi water tank being filled via a low
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`pressure hose. The middle panel shows the control displaying an intermediate amount of water
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`(372 gallons) in the tank (partway through filling). The right panel shows a fuller tank water level
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`around the time I observed the milling operation (489 gallons).
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`Figure 18:
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`(Left) Inspection photo of water tank in the process of being filled
`via a low-pressure hose. (Middle) UI display indicating an amount
`of water in the tank, as well as a number of other conditions
`indicative of the machine’s status. (Right) UI display showing a
`rendering of the water tank’s shape, position in the machine, and
`current water level.
`122. Figure 19 below shows a set of three photographs indicating the approximate
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`location of the milling operation (the dirt field in the left panel) as well as the milling process in
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`action. The milled dirt/mud is seen partially falling off the conveyor in the lower panel and is seen
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`being ejected off the end of the conveyor in the right panel.
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`2111403.000 - 1833
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`Therefore, it is also my opinion that sales and/or importation of those accused machines infringe
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`these claims.
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`171. Throughout my analysis below I rely on various documentary and other evidence
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`in forming my opinions. I also rely on the photographs, documents, and discussion in Section IX
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`above, even where not specifically cited below. For brevity, I do not repeat the evidence and
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`discussion in Section IX above, but I do incorporate it by reference here for my infringement
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`analysis. At trial, I intend to use the materials and analysis in Section IX, as well as the analysis
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`below, to show how the Accused Wirtgen America Products practice each and every limitation of
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`claims 1, 8, and 14 of the ’618 Patent.
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`a. Claim 1
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`172. Claim 1 of the ’618 patent recites:
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`A cold planer machine comprising a frame and a drum enclosed
`within a housing and arranged to rotate about a drum axis, the drum
`connected to the frame and configured to plane a road surface during
`operation, the cold planer comprising:
`a primary rotor spray bank mounted to the frame and disposed
`in the housing, the primary rotor chamber spray bank
`including a first plurality of spray nozzles arranged along a
`first spray manifold, the first plurality of spray nozzles being
`arranged parallel to the drum axis and being oriented such that
`a plurality of water sprays provided therethrough are directed
`towards the drum;
`a water reservoir mounted on the frame and configured to
`enclose water;
`a pump fluidly associated with the water reservoir and
`configured to draw the water therefrom, pressurize the water,
`and provide pressurized water to a main spray manifold
`connected to the frame;
`wherein the pump is configured to pressurize the water to a
`variable pressure in response to a pump signal;
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`2111403.000 - 1833
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`a pressure sensor associated with the main spray manifold and
`configured to provide a pressure signal indicative of a pressure
`of the pressurized water within the main spray manifold;
`a first control valve fluidly disposed between the main spray
`manifold and the first spray manifold, the first control valve
`selectively fluidly connecting the main with the first spray
`manifold in response to a valve signal;
`an electronic controller associated with the cold planer and
`configured to receive a plurality of operating signals indicative
`of an operating condition of the cold planer, the electronic
`controller disposed to:
`monitor the plurality of operating signals;
`determine an operating state of the cold planer based on the
`operating signals;
`determine whether the primary rotor spray bank should be
`activated based on the operating state;
`estimate an amount of pressurized water that will be required
`to operate the primary rotor spray bank when it is
`determined that the primary rotor spray bank should be
`activated;
`determine a desired main spray manifold pressure based on
`the estimated amount of pressurized water;
`determine the pump signal based on the desired main spray
`pressure, and send the pump signal to the pump;
`activate the first control valve by sending the valve signal to
`the first control valve when it is determined that the
`primary rotor spray bank should be activated; and
`maintain the desired main spray manifold pressure by
`adjusting the pump signal based on the pressure signal as
`a primary control parameter continuously during
`operation.
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`173. Thus, claim 1 of the ’618 patent claims a cold planer machine comprising a rotating
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`drum enclosed in a housing for planing a road surface with specific water usage capabilities
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`managed by an electronic controller. That is, claim 1 claims a primary rotor spray bank including
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`a first plurality of spray nozzles along a first spray manifold arranged parallel to (with sprays
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`directed toward) the drum.
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`174. Claim 1 also claims a water reservoir and a pump which draws and variably
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`pressurizes water from the reservoir and then provides the water to the main spray manifold. Claim
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`1 also claims a pressure sensor associated with the main spray manifold for providing a signal
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`indicative of water pressure within the manifold.
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`175. Claim 1 also claims a first fluid control valve between the main spray manifold and
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`first spray manifold operable in response to a valve signal.
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`176. Claim 1 also claims an electronic controller associated with the cold planer
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`configured to receive a plurality of operating signals and disposed to monitor the operating signals
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`to perform several inter-related control operations. The operating signals indicate an “operating
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`state,” which means any information detected by the machine about then current operation.
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`177. The claimed electronic control operations include determining an “operating state,”
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`which means any information detected by the machine about then-current operation.
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`178. The claimed electronic controls also include determining whether the primary spray
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`bank should be activated, estimating an amount of pressurized water required for such operation,
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`determining a main spray manifold pressure based on the amount of water, determining the pump
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`signal based on the main spray manifold pressure (where “determine the pump signal based on the
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`desired main spray pressure” means “determine the pump signal based on the estimated amount of
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`water needed to generate intended pressure”), opening the control valve, and maintaining the
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`desired main spray manifold pressure by adjusting the pump signal based on the pressure signal.
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`179. For at least the reasons below, it is my opinion that each Accused Wirtgen America
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`Product (as represented by the W 210 Fi) satisfies each and every limitation of claim 1.
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`Accordingly, it is my opinion that Wirtgen America infringes this claim by selling, offering to sell,
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`and importing the Accused Wirtgen America Products.
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`Figure 37.
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`Excerpt from page 110 ([WA-0025852]) of the W 210 Fi Instruction
`Manual, showing the primary rotor spray bank including a first
`plurality of spray nozzles arranged parallel to the drum axis.
`The sectional spray bar is listed as a standard part of the W 210 Fi product, and all
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`201.
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`other Accused Wirtgen America Products. For example, the W 210 Fi Parts Catalog shows this
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`sectional spray bar, outlined in the figure below, which is not indicated as optional (unlike the 3D
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`laser leveling on page 54 of the W 210 Fi Spare Parts Catalog).50
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`50 See also, the Spare Parts Catalogs for the W 220 Fi and W 250 Fi, WA-0015833 and WA-0017852, respectively.
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`2111403.000 - 1833
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`chamber spray bank includes at least a first plurality of spray nozzles arranged along a first spray
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`manifold, parallel to the drum axis, and oriented such that a plurality of water sprays provided
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`therethrough are directed towards the drum, as required by the limitations of claim element 1[a].
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`Thus, for at least the reasons detailed above, the Wirtgen America W 210 Fi product, and all other
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`Accused Wirtgen America Products of which the W 210 Fi is representative, satisfies the
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`limitations of claim element 1[a] of the ’618 Patent.
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`ii.
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`1[b] a water reservoir mounted on the frame and configured to
`enclose water;
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`204. Claim element 1[b] specifies that the cold planer machine includes a water
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`reservoir, which is mounted on the frame, to which the primary spray bank is also mounted, and
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`is configured to enclose water. For at least the reasons detailed below, the Wirtgen America W
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`210 Fi satisfies the limitations of claim element 1[b] of the ’618 patent.
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`205. The Wirtgen America W 210 Fi cold milling machine uses water at least to supply
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`the spray nozzles directed toward the drum, and the water is supplied from a water tank, or
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`reservoir, mounted on the frame of the machine and configured to enclose water, as required by
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`claim element 1[b].
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`206. The water tank is indicated as existing within the enclosed housing of the W 210
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`Fi, as shown in Figure 40. The technical specifications, on page 32 ([CAT-770_023869]) of the W
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`210 Fi product brochure, notes that the product includes a water filling capacity of 865 gallons.52
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`52 See also, the analogous sections of the W 220 Fi and W 250 Fi product brochures at CAT-770 077523 and CAT-
`CAT-770 077636, respectively.
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`Figure 40.
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`Excerpt from page 107 ([WA-0025849]) of the W 210 Fi Instruction
`Manual showing the inlet for the water tank (water reservoir).
`Furthermore, the water tank on a representative W 210 Fi is illustrated by the red-
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`207.
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`orange highlighted machine portions indicated in the image visible on the operator interface, as
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`shown in the photo from the April 28 Antioch, TN inspection (see Figure 41 below).
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`Figure 41.
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`Photo of the operator interface on a W 210 Fi machine showing
`the location and configuration of the water tank reservoir in
`orange.
`The Wirtgen America W 220 Fi includes nominally the same features as the W 210
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`208.
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`Fi with respect to the water spray system. Furthermore, the instruction manual for the W 220 Fi
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`([WA-0014280]) includes a schematic more clearly illustrating the position of the water tank
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`reservoir on the cold planer machine, as shown in Figure 16. The analogous section of the
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`instruction manual for the W 250 Fi is WA-0016336.
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`Figure 42.
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`Excerpt from page 111 ([WA-0014390]) of the W 220 Fi Instruction
`Manual ([WA-0014280]) showing a schematic of the enclosed
`water tank contained within the machine’s housing and mounted
`on the frame.
`Thus, for at least the reasons detailed above, the W 210 Fi product (and all other
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`209.
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`Accused Wirtgen America Products, for which the W 210 Fi is representative) includes a water
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`reservoir mounted on the frame and configured to enclose water, and therefore, this product, and
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`all other Accused Wirtgen America Products of which the W 210 Fi is representative, satisfies the
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`limitations of claim element 1[b] of the ’618 patent.
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`iii.
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`1[c] a pump fluidly associated with the water reservoir and
`configured to draw the water therefrom, pressurize the water,
`and provide pressurized water to a main spray manifold
`connected to the frame;
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`210. Claim element 1[c] specifies the cold planer machine includes a pump that is fluidly
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`associated with the water reservoir. This claim element further specifies that the pump is
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`configured to draw water from the water reservoir, pressurize the water, and provide said
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`215.
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`The water pump is also discussed in the W 210 Fi Spare Parts Catalog, as shown in
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`Figure 47 below.55
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`Figure 47.
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`Annotated version of page 672 [WA-0027224] of the Spare Parts
`Catalog showing the water pump, outlined in red.
`In order for the water to be sprayed, the pressurized water must be provided to the
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`216.
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`main spray manifold, which is connected to the machine’s frame. More specifically, the water
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`pump supplies pressurized water to the water distribution system via a manifold of valves with a
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`pressure indicator, as shown in Figure 48, which constitutes “a main spray manifold,” as required
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`by claim element 1[c].
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`55 See also, the analogous sections of the W 220 Fi and W 250 Fi Spare Parts Catalogs at WA-0015825 and WA-
`0017844, respectively.
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`iv.
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`1[d] wherein the pump is configured to pressurize the water to
`a variable pressure in response to a pump signal;
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`218. Claim element 1[d] specifies the pump required by claim element 1[c] is configured
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`to pressurize the water drawn from the water reservoir to a variable pressure in response to a pump
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`signal. For at least the reasons detailed below, the Wirtgen America W 210 Fi satisfies the
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`limitations of claim element 1[d] of the ’618 patent.
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`219. The water pump, discussed above with respect to claim element 1[c], draws and
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`pressurizes water from the water tank’s reservoir, and provides it to the main spray manifold, as
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`shown in Figure 22 above. The pump is configured to pressurize water to a variable pressure. For
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`instance, the water pump in the W 210 Fi was discussed during the March 29, 2023 deposition
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`testimony of Jan Schmidt. With respect to the water pump shown in the Instruction Manual on
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`WA-0025850 (shown above in Figure 17), Mr. Schmidt was asked “Is it a variable water pump?”
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`and replied, “I believe it is.” (Jan Schmidt 30(b)(6), Deposition Transcript, p.203).
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`220. Figure 49 below, shows that the main manifold is connected to a “Distributor Block
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`(50)” via a hose. Water passing through the distributor block may then be selectively passed to the
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`segmented spray bar of the sprinkler system.
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`filtered actual pressure, and which is compared to the current desired pressure to ensure that the
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`difference is within tolerable amounts. (See, Hausegger Report, Section VII.A (and code cited
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`therein); and see WA-SRC_0000100-101.)
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`233. Thus, for at least the reasons detailed above, the Wirtgen America W 210 Fi
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`product, and all other Accused Wirtgen America Products of which the W 210 Fi is representative,
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`satisfies the limitations of claim element 1[e] of the ’618 patent.
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`vi.
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`1[f] a first control valve fluidly disposed between the main spray
`manifold and the first spray manifold, the first control valve
`selectively fluidly connecting the main with the first spray
`manifold in response to a valve signal;
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`234. Claim element 1[f] specifies that the cold planer include a first control valve
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`wherein said control valve is fluidly disposed between the main spray manifold and the first spray
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`manifold. This claim element further specifies that the first control valve selectively fluidly
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`connects the main with the first spray manifold in response to a valve signal.” For at least the
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`reasons detailed below, the Wirtgen America W 210 Fi satisfies the limitations of claim element
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`1[f] of the ’618 patent.
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`235. The Parts Catalog includes a schematic diagram of a portion of the water system,
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`as shown in Figure 52 below, wherein the electronically controlled “Solenoid Valve (67)” is
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`disposed between, and selectively fluidly connecting, the main spray manifold with the first spray
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`manifold. The valve’s “open” or “close” state is dictated by an electronic signal sent to said valve,
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`which thereby determines whether the water may pass from the main spray manifold to the first
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`spray manifold. More specifically, as a POSITA would understand, an electric current delivered
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`to a solenoid valve passes through a coil of wire, creating a magnetic field that operates to
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`mechanically open and close the valve. In the source code this open/close status is reflected in the
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`boolean
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`variables
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`“b_Wasserleiste_Ventil_1,”
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`“b_Wasserleiste_Ventil_2,”
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`b.
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`Claim 8
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`314. Claim 8 of the ’618 patent recites:
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`A machine, comprising:
`a frame;
`a drum enclosed within a housing and arranged to rotate about a
`drum axis, the drum connected to the frame and configured
`to plane a road surface during operation;
`a first spray bank mounted to the frame, the first spray bank
`including a first plurality of spray nozzles arranged along a
`first spray manifold, the first plurality of spray nozzles being
`oriented to wet the drum;
`a water reservoir mounted on the frame;
`a pump fluidly associated with the water reservoir and
`configured to draw water therefrom, the pump configured to
`pressurize the water to a variable pressure in response to a
`pump signal pressurize the water and provide pressurized
`water to a main spray manifold;
`a pressure sensor associated with the main spray manifold and
`configured to provide a pressure signal indicative of a
`pressure of the pressurized water within the main spray
`manifold;
`a first control valve fluidly disposed between the main spray
`manifold and the first spray manifold, the first control valve
`selectively fluidly connecting the main with the first spray
`manifold in response to a valve signal;
`an electronic controller associated with the cold planer and
`configured to receive a plurality of operating signals
`indicative of an operating condition of the cold planer, the
`electronic controller disposed to:
`monitor the plurality of operating signals;
`determine an operating state of the cold planer based on the
`operating signals;
`determine whether the first spray bank should be activated
`based on the operating state;
`estimate an amount of pressurized water that will be required
`to operate the first spray bank when it is determined that
`the first spray bank should be activated;
`determine a desired main spray manifold pressure based on
`the estimated amount of pressurized water;
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`determine a pump signal based on the desired main spray
`pressure, and send the pump signal to the pump;
`activate the first control valve by sending the valve signal to
`the first control valve when it is determined that the first
`spray bank should be activated; and
`maintain the desired main spray manifold pressure by
`adjusting the pump signal based on the pressure signal as
`a primary control parameter.
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`315. Thus, claim 8 of the ’618 Patent claims “a machine,” whereas claim 1 claims “a
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`cold planer machine.” Nonetheless, claim 8, much like claim 1, claims a machine comprising a
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`rotating drum enclosed in a housing for planing a road surface with various limitations imposed
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`upon the specific water usage capabilities managed by an electronic controller.
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`316. For at least the reasons below, it is my opinion that each Accused Wirtgen America
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`Product (as represented by the W 210 Fi) satisfies each and every limitation of claim 8.
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`Accordingly, it is my opinion that Wirtgen America infringes this claim by selling, offering to sell,
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`and importing the Accused Wirtgen America Products.
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`i. 8[pre] A machine, comprising:
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`317.
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`I described above in Section XI.E.a.i how the accused products are cold planar
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`machines. For the same reasons as described in that section, each Accused Wirtgen America
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`Product represented by the Wirtgen America W 210 Fi is a “machine” and therefore satisfies the
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`preamble of claim 8 of the ’618 Patent.
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`i.
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`8[a] a frame;
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`318.
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`I described above in Section XI.E.a.i how the accused products are cold planar
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`machines comprising a frame. For the same reasons as described in that section, each Accused
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`Wirtgen America Product represented by the Wirtgen America W 210 Fi has a “frame” and
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`therefore satisfies the preamble of claim 8 of the ’618 Patent.
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`of spray nozzles on the first spray bank be “oriented to wet the drum.” As shown above with
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`respect to claim element 1[a], the plurality of spray nozzles on the primary rotor chamber spray
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`bank in the Accused Wirtgen America Products are directed toward the drum. Spray nozzles
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`directed toward the drum will have the effect of wetting the drum. That is, the same nozzles shown
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`to be directed “towards the drum” above with respect to claim element 1[a], are also “oriented to
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`wet the drum,” as required by the language of claim element 8[c].
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`323. Therefore, for the reasons describe above with respect to claim element 1[a] in
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`addition to the reasons described above in this section, the Wirtgen America W 210 Fi product,
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`and all other Accused Wirtgen America Products of which the W 210 Fi is representative, satisfies
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`the limitations of claim 8[c] of the ’618 patent.
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`iv.
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`8[d] a water reservoir mounted on the frame;
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`324. For at least the reasons explained above with respect to claim element 1[b], the
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`Accused Wirtgen America Products represented by the Wirtgen America W 210 Fi satisfy the
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`limitations of claim element 8[d] of the ’618 Patent.
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`v.
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`8[e] a pump fluidly associated with the water reservoir and
`configured to draw water therefrom, the pump configured to
`pressurize the water to a variable pressure in response to a
`pump signal pressurize the water and provide pressurized water
`to a main spray manifold;
`
`325. For at least the reasons explained above with respect to claim elements 1[c] and
`
`1[d], the Accused Wirtgen America Products represented by the Wirtgen America W 210 Fi satisfy
`
`the limitations of claim element 8[e] of the ’618 Patent.
`
`326.
`
`I note that this limitation includes additional language “pressurize the water.” As I
`
`discussed above with respect to claim 1, the water pump does indeed pressurize the water. I
`
`incorporate my analysis from claim 1 here.
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`345. Claim 14 of the ’618 patent depends upon claim 8 and places additional limitations
`
`upon type of pump and the motor that is used to operate it. As detailed above with respect to claim
`
`8, which primarily references discussions above with respect to claim 1, the Wirtgen America W
`
`210 Fi satisfies each and every limitation of claim 8 of ’618 patent. Furthermore, for at least the
`
`reasons described below, the Wirtgen America W 210 Fi (and all other Accused Wirtgen America
`
`Products) satisfies the limitations added to claim 8 by claim 14 of the ’618 patent.
`
`346.
`
`In particular, claim 14 requires that the claimed pump is a variable-speed pump that
`
`is operated by a hydraulic motor. The water pump, discussed above with respect to claim element
`
`1[c], draws and pressurizes water from the water tank’s reservoir, and provides it to the main spray
`
`manifold, as shown in Figure 22 above. The pump is configured to pressurize water to a variable
`
`pressure. For instance, the water pump in the W 210 Fi was discussed during the March 29, 2023
`
`deposition testimony of Jan Schmidt. With respect to the water pump shown in the Instruction
`
`Manual on WA-0025850 (shown above in Figure 17), Mr. Schmidt was asked “Is it a variable
`
`water pump?” and replied, “I believe it is.” (Jan Schmidt 30(b)(6), Deposition Transcript, p.203).
`
`When asked to explain how the pump operates, Mr. Schmidt further stated “I know it’s
`
`hydraulically operated, and it pumps water” (Id., emphasis added).
`
`347. The water pump is included in the W 210 Fi Spare Parts Catalog, identified by part
`
`1, to which is connected what the catalog identifies as the “Hydraulic Motor,” as shown in Figure
`
`29 below.
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`XIII. DECLARATION
`I declare that all statements made of my own knowledge are true and that all statements made on
`
`information and belief are believed to be true, and that these statements were made with the
`
`knowledge that willful false statements and the like are punishable by fine or imprisonment, or
`
`both, under section 1001 of Title 18 of the United States Code.
`
`____________________
`May 19, 2023
`
`
`
`___________________________________________
`
`Adam SoriniAdam Sorini
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`
`
`
`APPENDIX B
`
`Materials Reviewed
`
`
`
`
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`
`Materials Considered and Relied Upon
`
`I have considered and/or relied upon materials provided by counsel, including the
`sources referenced below.
`
`CAT-770_075679-695 (’618 Patent)
`CAT-770_075696-885 (Partial File History of the ’618 Patent)
`Additional File History of the ’618 Patent, including the file history update of 3/9/2023
`denying institution of trial before the patent trial and appeal board.
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,371,618
`(EXPONENT_0005463-566)
`CATERPILLAR INC.’S INITIAL INFRINGEMENT CONTENTIONS, dated March 2, 2022
`CATERPILLAR INC.’S AMENDED INFRINGEMENT CONTENTIONS, dated March 10,
`2023
`Exhibit D to CATERPILLAR INC.’S AMENDED INFRINGEMENT CONTENTIONS
`CATERPILLAR INC.’S SECOND AMENDED INFRINGEMENT CONTENTIONS, dated
`April 7, 2023
`Exhibit D to CATERPILLAR INC.’S SECOND AMENDED INFRINGEMENT
`CONTENTIONS
`CAT-770_023838-877 (“W 210 Fi Brochure”)
`CAT-770_077492-7531 (“W 220 Fi Brochure”)
`CAT-770_077605-644 (“W 250 Fi Brochure”)
`https://www.youtube.com/watch?v=Mw8e7nbDx7A (Last Accessed: 5/7/2020) (“W 210 Fi
`Video”) (EXPONENT_0003859)
`CAT-770_023878-3901 (“Wirtgen Website”)
`CAT-770_023902-24407 (“Wirtgen Parts Catalog”)
`WA-0025743-26245 (“W 210 Fi Instruction Manual”)
`WA-0014280-4784 (“W 220 Fi Instruction Manual”)
`WA-0016223-6757 (“W 250 Fi Instruction Manual”)
`WA-0026553-27351 (“W 210 Fi Spare Parts Catalogue”)
`WA-0015092-5922 (“W 220 Fi Spare Parts Catalogue”)
`WA-0017057-7945 (“W 250 Fi Spare Parts Catalogue”)
`WA-0027386-7473 (“W 210 Fi Hydraulic hose diagram”)
`WA-0015955-16042 (“W 220 Fi Hydraulic hose diagram”)
`WA-0026246-6552 (“W 210 Fi Electric diagram”)
`WA-0014785-15091 (“W 220 Fi Electric diagram”)
`WA-0016758-17056 (“W 250 Fi Electric diagram”)
`WA-0027352-385 (“W 210 Fi Hydraulic diagram”)
`WA-0015923-54 (“W 220 Fi Hydraulic diagram”)
`WA-0017946-978 (“W 250 Fi Hydraulic diagram”)
`WA-0027474-487 (“W 210 Fi Service diagrams”)
`WA-0027488-7513 (“W 200 F/200 Fi/210 F/210 Fi Transportation Instructions”)
`WA-0027514-549 (“W 210 Fi Machine Data”)
`WA-0027653-55 (“W 210 F / W 210 Fi Transportation data”)
`WA-1446291.xlsx (Wirtgen America sales spreadsheet)
`
`2111403.000 - QAID
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`

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`Case 1:17-cv-00770-JDW Document 229-22 Filed 10/05/23 Page 23 of 23 PageID #: 23704
`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
`
`Deposition Transcript of Daniel H. Killion, dated March 15, 2023
`Deposition Transcript of Eric Engelmann, Volume I of II, dated March 16, 2023
`Deposition Transcript of Eric Engelmann, Volume II of II, dated March 17, 2023
`Deposition Transcript of Craig Steffen, dated February 28, 2023
`Deposition Transcript of Sandy Draper, dated March 22, 2023
`Deposition Transcript of Jan Schmidt, dated March 29, 2023
`Deposition Transcript of Timothy Lewis, dated March 31, 2023
`WA-SRC_0000001-121
`WIRTGEN AMERICA, INC.'S RESPONSES AND OBJECTIONS TO CATERPILLAR
`INC.'S FIRST SET OF INTERROGATORIES (NOS. 1-15), dated December 19, 2022
`Appendix A to Wirtgen’s Resp. & Obj. to CAT’s 1st ROGs (1-15)
`PLAINTIFF/COUNTERCLAIM-DEFENDANT WIRTGEN AMERICA, INC.’S FINAL
`INVALIDITY CONTENTIONS, dated April 21, 2023 and attached Exhibits A-1 and A-2.
`EXPONENT_0003860-4329 (Antioch, TN Inspection Photos)
`EXPONENT_0005206-5229 (https://dc-
`br.resource.bosch.com/media/us/products_13/product_groups_1/mobile_hydraulics_4/pdfs_6/r
`e95204_2015-7.pdf)
`Doc. 167 – Markman Memorandum
`Doc. 167 – Markman Order
`Expert Report of Hubert Hausegger (“Hausegger Report”)
`
`2111403.000 - QAID
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`146
`
`