Case 1:17-cv-00770-JDW Document 229-28 Filed 10/05/23 Page 1 of 8 PageID #: 23800
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`Exhibit 75
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`Exhibit 75
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`Case 1:17-cv-00770-JDW Document 229-28 Filed 10/05/23 Page 2 of 8 PageID #: 23801
`
`1/12/2018
`
`337-TA-1067
`Highly Confidential Business Information - Pursuant to Protective Order
`
`Eric Engelmann
`
`Page 1
`
` INTERNATIONAL TRADE COMMISSION
`
`-----------------------------x
`Regarding Certain Road :
` : Investigation No.
`Milling Machines and :
` : 337-TA-1067
`Components Thereof :
`-----------------------------x
`
` Washington, D.C.
`
` Friday, January 12, 2018
`
` ** HIGHLY CONFIDENTIAL BUSINESS INFORMATION **
` PURSUANT TO PROTECTIVE ORDER
`
`VIDEOTAPED Deposition of:
` ERIC ENGELMANN,
`the witness, was called for examination by counsel
`for the Complainant, pursuant to notice,
`commencing at 8:54 a.m., at the law offices of
`Sterne, Kessler, Goldstein & Fox, P.L.L.C.,
`1100 New York Avenue, NW, Suite 600, Washington,
`D.C. 20005, before Dawn A. Jaques, CSR, CLR, and
`Notary Public in and for the District of Columbia.
`
` ____________________________________________________
` 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 229-28 Filed 10/05/23 Page 3 of 8 PageID #: 23802
`
`1/12/2018
`
`337-TA-1067
`Highly Confidential Business Information - Pursuant to Protective Order
`
`Eric Engelmann
`
`Page 69
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` Q And that section of the Technical
`Presentation is describing the reverse rotor
`shutoff feature that we have been discussing these
`past few minutes, correct?
` A Yes, it describes the sequence we've
`been discussing.
` Q Could you read the first sentence
`under the heading Rotor Exposure During Reverse
`Travel?
` A "An automatic rotor disengagement
`feature detects a condition where the rotor could
`come in contact with a surface while the machine
`is traveling in reverse."
` Q Is that statement consistent with your
`understanding of the reverse rotor shutoff
`feature?
` A That statement is not 100 percent
`consistent with my understanding of the feature.
` Q How is that statement inconsistent
`with your understanding of the feature?
` A My understanding of the feature is
`that we simply monitor the moldboard and side
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 229-28 Filed 10/05/23 Page 4 of 8 PageID #: 23803
`
`1/12/2018
`
`337-TA-1067
`Highly Confidential Business Information - Pursuant to Protective Order
`
`Eric Engelmann
`
`Page 70
`plates to be below a certain threshold point, and
`if they're lower than that threshold, we allow the
`rotor to remain on, and if they're above that
`threshold, we shut the rotor off.
` Q And how was that threshold point
`selected?
` A That threshold point was selected
`based on the bottom or tangent plane created by
`the bottom of the rotor.
` Q And the reason the threshold point was
`selected was -- the purpose of the feature is to
`detect a condition where the rotor could come in
`contact with a surface, correct?
` A The purpose of the feature, from my
`perspective, is to detect a condition where the
`rotor may be exposed because the side plates or
`moldboard are raised above that lower surface.
` Q Exposed to what?
` A "Exposed" is a pretty vague term.
`Exposed to anything that may come in contact with
`the rotor, or visually exposed. There's many ways
`to interpret "exposed."
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`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 229-28 Filed 10/05/23 Page 5 of 8 PageID #: 23804
`
`1/12/2018
`
`337-TA-1067
`Highly Confidential Business Information - Pursuant to Protective Order
`
`Eric Engelmann
`
`Page 71
` Q The threshold point that you referred
`to in your previous answer was -- I'm sorry.
` You said the threshold point was
`selected based on the bottom or tangent plane
`created by the bottom of the rotor, correct?
` A I believe that is how I stated it.
` Q And so that -- and that's the
`threshold that is -- the threshold point that is
`used for -- I'm sorry, strike that.
` How was that threshold determined?
` MR. BARNEY: Objection, asked and
`answered.
` THE WITNESS: That threshold was
`determined by the tangent plane to the bottom of
`the rotor.
` BY MR. AINSWORTH:
` Q Turning back to the Technical
`Presentation, the third paragraph under the
`heading Rotor Exposure During Reverse Travel, the
`document describes the parameters that must be
`simultaneously true for at least a half a second
`before the rotor -- reverse rotor shutoff feature
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`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 229-28 Filed 10/05/23 Page 6 of 8 PageID #: 23805
`
`1/12/2018
`
`337-TA-1067
`Highly Confidential Business Information - Pursuant to Protective Order
`
`Eric Engelmann
`
`Page 75
`a location that coincides with the bottom of the
`rotor surface.
` Q Okay. If you could -- now, the side
`plates have position sensors that indicate when a
`side plate has been raised above a certain
`threshold, correct?
` A Can you repeat the question?
` Q Turning back to that third bullet
`point. We talked about when the moldboard status
`changes to Not Lowered, right?
` A Uh-hmm.
` Q And the other condition in that bullet
`point is where the side plate is raised above a
`threshold. Do you see that?
` A I see that statement.
` Q Okay. And whether the side plate is
`raised above that predetermined threshold depends
`upon -- I'm sorry, is detected by position
`sensors. Is that correct?
` A We use position sensors on the side
`plates.
` Q Okay. And those position sensors on
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`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 229-28 Filed 10/05/23 Page 7 of 8 PageID #: 23806
`
`1/12/2018
`
`337-TA-1067
`Highly Confidential Business Information - Pursuant to Protective Order
`
`Eric Engelmann
`
`Page 76
`the side plate are used in connection with this
`feature to determine whether the side plate is
`raised above a particular threshold?
` A We use those values to compare to our
`threshold.
` Q Okay. If you turn back a few pages in
`the Technical Presentation to the page with Bates
`number CAT0004497, there's an image identified as
`SLIDE 228 on that page, correct?
` A I see the image labeled SLIDE 228.
` Q And the image is illustrating at least
`a portion of the side plate; is that right?
` A Can you repeat that?
` Q Sure. Does the image depicted in
`slide 228 illustrate at least a portion of a side
`plate?
` A This image shows very little of the
`side plate.
` Q It depicts -- the image depicts the
`side plate cylinder, correct?
` A This image appears to call out one of
`the side plate cylinders on the machine.
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`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 229-28 Filed 10/05/23 Page 8 of 8 PageID #: 23807
`
`111212078
`
`337-TA-1067
`Highly Confidential Business Information - Pursuant to Protective Order
`
`Eric Engelmann
`
`Page 781
`
`CERTIFICATE OF NOTARY PUBLIC
`I, DAWN A. JAQUES, a Notary Publ-ic in and for
`the District of Columbia, before whom the foregoing
`that witness
`deposition was taken, do hereby certify
`whose testimony appears in the foregoing pages was
`duly sworn by me; that the testimony of said witness
`was taken by me in shorthand at the time and pJ-ace
`mentioned in the caption hereof and thereafter
`reduced to typewriting under my supervision; that
`said deposition is a true record of the testimony
`given by said witness; that I am neither counsel
`for, related to, nor employed by any of the part.ies
`to the action in which this deposition is taken;
`that f am not a relative or employee
`and, further,
`of any attorney or counsel employed by the parties
`thereto, nor financially or otherwise interested in
`the outcome of the actions.
`
`Dawn A. .Taques,
`D
`Notary Public in
`and fo:r
`DistrÃct of Columbia
`
`My commission expires:
`January 14, 2020.
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`www.DigitalEvidenceGroup.com Digital Evidence Group C'rt201B
`
`202-232-0646
`
`
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