`
`
`Exhibit F
`
`
`
`Case 1:17-cv-00770-JDW Document 245-6 Filed 10/19/23 Page 2 of 5 PageID #: 24568
`
`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 245-6 Filed 10/19/23 Page 3 of 5 PageID #: 24569
`
`1/12/2018
`
`337-TA-1067
`Highly Confidential Business Information - Pursuant to Protective Order
`
`Eric Engelmann
`
`Page 120
`Jim Domanus would be a better person to answer
`that precise question.
` BY MR. AINSWORTH:
` Q But from your review of the materials
`in preparation for your deposition, you understood
`that Caterpillar used the Low Cost Producer
`process as part of its NPI development for the
`cold planer, correct?
` A These materials state that we did
`follow that Low Cost Producer process.
` Q And one piece of the Low Cost Producer
`process that was used in the case of development
`of the cold planers was a teardown of competitor
`products, correct?
` A For the NPI program, there were
`teardowns of competitive product as part of the
`Low Cost Producer process.
` Q And in particular, Caterpillar
`predicted teardowns of a Wirtgen W120 and a
`Wirtgen 210; is that correct?
` A We did tear down two different Wirtgen
`models.
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`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 245-6 Filed 10/19/23 Page 4 of 5 PageID #: 24570
`
`1/12/2018
`
`337-TA-1067
`Highly Confidential Business Information - Pursuant to Protective Order
`
`Eric Engelmann
`
`Page 121
` Q And those teardown procedures involved
`a systematic and comprehensive disassembly of each
`machine, correct?
` A It is my understanding that it did
`involve a systematic comprehensive teardown.
` Q And as part of that teardown process,
`Caterpillar identified features from the Wirtgen
`machines that it considered for part of its
`development program for its cold planer, correct?
` MR. BARNEY: Objection, vague,
`misleading.
` THE WITNESS: Can you repeat the
`question?
` BY MR. AINSWORTH:
` Q As part of that teardown process,
`Caterpillar identified features from the Wirtgen
`machines that Caterpillar considered for part of
`its development program for its cold planer?
` MR. BARNEY: Same objections.
` BY MR. AINSWORTH:
` Q Correct?
` A Some features we considered for the
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`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 245-6 Filed 10/19/23 Page 5 of 5 PageID #: 24571
`
`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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