Case 1:17-cv-00770-JDW Document 249-13 Filed 10/25/23 Page 1 of 13 PageID #: 25240
`Case 1:17-cv-00770-JDW Document 249-13 Filed 10/25/23 Page 1 of 13 PagelD #: 25240
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`EXHIBIT 13
`EXHIBIT 13
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`Case 1:17-cv-00770-JDW Document 249-13 Filed 10/25/23 Page 2 of 13 PageID #: 25241
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`WIRTGEN AMERICA, INC.
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`Plaintiff/Counterclaim-Defendant,
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`v.
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`CATERPILLAR INC.
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`)
`)
`)
`)
`) C.A. No. 1:17-cv-00770-JDW
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`)
`)
`)
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`Defendant/Counterclaim-Plaintiff.
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`INITIAL EXPERT REPORT OF DR. JOHN MEYER
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`Case 1:17-cv-00770-JDW Document 249-13 Filed 10/25/23 Page 3 of 13 PageID #: 25242
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`Appendix D
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`Case 1:17-cv-00770-JDW Document 249-13 Filed 10/25/23 Page 4 of 13 PageID #: 25243
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`functionalities. See D.I. 186, Apr. 12, 2023 Joint Stipulation at 2. Accordingly, to the extent components and functionalities are substantially
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`All models of the Accused Large Milling Machines include substantially the same components and provide substantially the same
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`after Wirtgen filed its complaint.
`this action, see, e.g., CAT_0028678 (June 2017 Patent Notice Email Chain). Caterpillar’s infringement of the ’641 Patent continued even
`Landscape), and has been on notice of its infringement of the ’641 Patent since at least June 16, 2017, by virtue of the Original Complaint in
`infringes the ’641 Patent. Caterpillar has had knowledge of the ’641 Patent since at least 2012, CAT_00053633 (Wirtgen Ten Year Patent
`infringing manner. Caterpillar’s end customers have used and continue to use the Accused Large Milling Machines in a manner that directly
`customers on how to use the Accused Large Milling Machines, including through its manuals, videos, training, and advertising, in an
`configured to infringe, and Caterpillar, directly and/or through its dealers and distributors, actively instructs, promotes, and encourages
`Milling Machines in a manner that infringes claims 11, 17, and 18 of the ’641 Patent. The Accused Large Milling Machines are specifically
`Caterpillar indirectly infringes by knowingly and intentionally inducing dealers and customers to use and operate the Accused Large
`
`770_043792 (Oct. 2021 PM3XX Technical Presentation) at 4030, 4033-35.
`Presentation) at p. 389; CAT-770_021849 (Jun. 2020 PM3XX Systems Operation Testing and Adjusting Manual) at 1926; CAT-
`2021 PM6XX & PM8XX Systems Operation Testing and Adjusting Manual); CAT_00057357 (Mar. 2021 PM6XX & PM8XX Technical
`manuals. See, e.g., CAT0007161 (Oct. 2016 PM620 & PM622 Systems, Operating, Testing & Adjusting Manual); CAT-770_014810 (May
`drum running, the customer is practicing the steps of the asserted claims, and is taught how to do so by Caterpillar’s training materials and
`can disengage. See Engelmann Dep. 146:9-147:17, Mar. 16, 2023. When a customer backs up, or drives in reverse and leaves the milling
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`Caterpillar’s customers directly infringe as the reverse rotor shutoff feature is “present at all times” and is not something a customer
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`to “[c]heck the reversing with rotor functionality”).
`forward direction but would shut off the rotor in reverse.”); CAT_00054680 (PM600 Software Testing) (describing 2014 performance tests
`CAT_00013338 (Mar. 2017 Meeting Notes) at 4 (“If the ECM is not seeing any of the moldboard sensors the machine would still mill in the
`Milling Machines. See, e.g., CAT_00003117 (Jan. 2017 Meeting Notes) at 2; see also CAT_00012831 (Oct. 2016 email) at 1;
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`Caterpillar directly infringes by making, using, offering to sell, selling, and importing into the United States the Accused Large
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`18 of the ’641 Patent, both literally and under the doctrine of equivalents.
`America, Inc. (“Wirtgen”). Caterpillar directly infringes claims 11, and 17–18 of the ’641 Patent and indirectly infringes claims 11, 17, and
`Milling Machines”) operate so as to practice claims 11, 17, and 18 of U.S. Patent No. 7,530,641 (“the ’641 Patent”), owned by Wirtgen
`PM825) road milling machines—including the 01A and 02A builds, and certain machines of the 02B build— (collectively, “Accused Large
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`The PM600 series (including at least the PM620 and the PM622), and PM800 series (including at least the PM820, PM822, and
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`Caterpillar’s Large Milling Machines Infringe U.S. Patent No. 7,530,641 under 35 U.S.C. § 271(a) and (b)
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`Case 1:17-cv-00770-JDW Document 249-13 Filed 10/25/23 Page 5 of 13 PageID #: 25244
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`The Accused Large Milling Machines perform a method that is automative by means of traveling devices.
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`(8)
`means of traveling devices
`11[a]. that is automotive by
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`explain the technology and/or illustrate this feature.
`to show that the PM620 practices this feature. I also may rely upon demonstratives that I have not yet prepared to
`interrogatories, and responses to requests for admission, and/or inspection of the PM620 or a representative machine
` may also rely on additional expert testimony, other documents considered, witness testimony, responses to
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` I
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`element 11[p]. Thus, it is my opinion that claim element 11[p] is also met under the doctrine of equivalents.
`substantially the same function, in substantially the same way, to achieve substantially the same result as claim
`Large Milling Machines include a substantially similar damage avoidance/safety feature that is intended to perform
`insubstantial. Indeed, to the extent that any such differences exist, it is nonetheless my opinion that the Accused
`in claim element 11[p], a person of ordinary skill in the art would have understood these differences to be
`To the extent that any differences may exist between the Accused Large Milling machines and the features disclosed
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`
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`ITC_00458692–WA-ITC_00458743.)
`WAITC_00458189; WA-ITC_00458656–WA-ITC_00458660; WA-ITC_00458640–WAITC_00458669; WA-
`features of the PM620 machine); WA-ITC_00458331–WA-ITC_00458633; WA-ITC_00457239–
`CAT0004149, Technical Presentation PM620 and PM622 Cold Planers at 4155-4162 (describing the operation and
`“[s]ame external dimensions”), and 3766-68 (describing the operation and features of the PM620 machine);
`and PM622 Cold Planers at 3764, 3765 (stating that the “PM620 and PM622” have the “[s]ame design” and the
`the PM620 machine) and 3699-3700 (describing the cutting system of the PM620 machine); CAT0003764, PM620
`operation); CAT0003690, PM620 and PM622 Cold Planers at 3690-3694 (describing the operation and features of
`machine), 2663 (describing the intended use of the PM620 Cold Planer Machine), and 2688 (describing machine
`PM622 Cold Planers at 2635-2637 (illustrating a road milling machine), 2643-44 (illustrating a road milling
`pavement using the PM620 Cold Planer Machine); CAT0002629, Operation and Maintenance Manual PM620,
`CAT0003576, Milling by the Numbers PM620 & PM622 Cold Planer at 3576, 3578 (discussing steps to remove
`Cold Planers at 3288, 3289 (discussing steps to remove pavement using the PM620 Cold Planer Machine);
`(See also, e.g., WA-ITC_00225912 at 5934; CAT0003260, Cold Planer Handbook for CAT PM620 and PM622
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`(CAT-770_042222, PM820, PM822, and PM825 Cold Planers, Publication No. QEHQ2329 (June 2018) at 2243.)
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`
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`Accused Large Milling Machines
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`U.S. Patent No. 7,530,641
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`Case 1:17-cv-00770-JDW Document 249-13 Filed 10/25/23 Page 6 of 13 PageID #: 25245
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`explain the technology and/or illustrate this feature.
`to show that the PM620 practices this feature. I also may rely upon demonstratives that I have not yet prepared to
`interrogatories, and responses to requests for admission, and/or inspection of the PM620 or a representative machine
` may also rely on additional expert testimony, other documents considered, witness testimony, responses to
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` I
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`element 11[a]. Thus, it is my opinion that claim element 11[a] is also met under the doctrine of equivalents.
`substantially the same function, in substantially the same way, to achieve substantially the same result as claim
`Large Milling Machines include a substantially similar damage avoidance/safety feature that is intended to perform
`insubstantial. Indeed, to the extent that any such differences exist, it is nonetheless my opinion that the Accused
`in claim element 11[a], a person of ordinary skill in the art would have understood these differences to be
`To the extent that any differences may exist between the Accused Large Milling machines and the features disclosed
`
`at 4228.)
`describes the steering modes accomplished by adjusting track alignment as the machine travels. (CAT-770_042222
`propel system includes propel pumps, circuits, and motors for crawler tracks. (CAT-770_042222 at 4227.) It also
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`Accused Large Milling Machines
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`U.S. Patent No. 7,530,641
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`Case 1:17-cv-00770-JDW Document 249-13 Filed 10/25/23 Page 7 of 13 PageID #: 25246
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`surface, i.e., when not in milling mode.
`position by extending the lifting columns/leg posts to lift the frame and the milling drum away from milled ground
`Because the milling drum of the Accused Large Milling Machines is fixed to the frame, it is moved into a raised
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`when it is not in milling mode.
`The Accused Large Milling Machines perform a method where the milling drum is moved into a raised position
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`not in milling mode,
`raised position when it is
`drum (12) is moved into a
`11[c]. where the milling
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`explain the technology and/or illustrate this feature.
`to show that the PM620 practices this feature. I also may rely upon demonstratives that I have not yet prepared to
`interrogatories, and responses to requests for admission, and/or inspection of the PM620 or a representative machine
` may also rely on additional expert testimony, other documents considered, witness testimony, responses to
`
` I
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`element 11[b]. Thus, it is my opinion that claim element 11[b] is also met under the doctrine of equivalents.
`substantially the same function, in substantially the same way, to achieve substantially the same result as claim
`Large Milling Machines include a substantially similar damage avoidance/safety feature that is intended to perform
`insubstantial. Indeed, to the extent that any such differences exist, it is nonetheless my opinion that the Accused
`in claim element 11[b], a person of ordinary skill in the art would have understood these differences to be
`To the extent that any differences may exist between the Accused Large Milling machines and the features disclosed
`
`
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`Accused Large Milling Machines
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`U.S. Patent No. 7,530,641
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`Case 1:17-cv-00770-JDW Document 249-13 Filed 10/25/23 Page 8 of 13 PageID #: 25247
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`(CAT_00056536 at p. 394 (annotated); see also CAT-770_007018 at 7473.)
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`the milling drum.
`driven pulley, wherein the clutch transfers the torque of the driven engine to the driven pulley, which in turn drives
`The Accused Large Milling Machines include a clutch that is operably positioned between the drive engine and the
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`milling drum corresponds to the rotating direction of the traveling devices.
`with the drive engine when in raised position and with a direction of travel in which the rotating direction of the
`The Accused Large Milling Machines perform a method characterized in that the milling drum remained coupled
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`explain the technology and/or illustrate this feature.
`to show that the PM620 practices this feature. I also may rely upon demonstratives that I have not yet prepared to
`interrogatories, and responses to requests for admission, and/or inspection of the PM620 or a representative machine
` may also rely on additional expert testimony, other documents considered, witness testimony, responses to
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` I
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`element 11[c]. Thus, it is my opinion that claim element 11[c] is also met under the doctrine of equivalents.
`substantially the same function, in substantially the same way, to achieve substantially the same result as claim
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`
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`devices (8);
`direction of the traveling
`corresponds to the rotating
`milling drum (12)
`the rotating direction of the
`direction of travel in which
`raised position and with a
`drive engine (6) when in
`remains coupled with the
`the milling drum (12)
`11[d]. characterized in that,
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`Accused Large Milling Machines
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`U.S. Patent No. 7,530,641
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`Case 1:17-cv-00770-JDW Document 249-13 Filed 10/25/23 Page 9 of 13 PageID #: 25248
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`76, 7225, 7229, 7335; CAT0004149 at 4359-60, 4497, 4508-09; see also CAT-770_001580 at 1597-98.) This
`obstacle) via one or more of the side plate positions and the scraper (“moldboard”) position. (CAT0007161 at 7175-
`The Accused Large Milling Machines monitor a distance between the milling drum and the ground surface (or an
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`seen in direction of travel.
`between the rotating, raised milling drum and the ground surface or an obstacle located in front of the milling when
`The Accused Large Milling Machines perform a method in that a distance is monitored, directly or indirectly,
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`explain the technology and/or illustrate this feature.
`to show that the PM620 practices this feature. I also may rely upon demonstratives that I have not yet prepared to
`interrogatories, and responses to requests for admission, and/or inspection of the PM620 or a representative machine
` may also rely on additional expert testimony, other documents considered, witness testimony, responses to
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` I
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`element 11[d]. Thus, it is my opinion that claim element 11[d] is also met under the doctrine of equivalents.
`substantially the same function, in substantially the same way, to achieve substantially the same result as claim
`Large Milling Machines include a substantially similar damage avoidance/safety feature that is intended to perform
`insubstantial. Indeed, to the extent that any such differences exist, it is nonetheless my opinion that the Accused
`in claim element 11[d], a person of ordinary skill in the art would have understood these differences to be
`To the extent that any differences may exist between the Accused Large Milling machines and the features disclosed
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`the direction of travel;
`milling (12) when seen in
`located in front of the
`surface (2) or an obstacle
`drum (12) and the ground
`rotating, raised milling
`monitored between the
`11[e]. in that a distance is
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`Accused Large Milling Machines
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`U.S. Patent No. 7,530,641
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`Case 1:17-cv-00770-JDW Document 249-13 Filed 10/25/23 Page 10 of 13 PageID #: 25249
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`element 11[e]. Thus, it is my opinion that claim element 11[e] is also met under the doctrine of equivalents.
`substantially the same function, in substantially the same way, to achieve substantially the same result as claim
`Large Milling Machines include a substantially similar damage avoidance/safety feature that is intended to perform
`insubstantial. Indeed, to the extent that any such differences exist, it is nonetheless my opinion that the Accused
`in claim element 11[e], a person of ordinary skill in the art would have understood these differences to be
`To the extent that any differences may exist between the Accused Large Milling machines and the features disclosed
`
`
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`WA-1717268 (Inspection Videos).)
`1717228; WA-1717237; WA-1717239; WA-1717101; WA-1717109; WA-1717111; WA-1717152; WA-1717155;
`WA-1717281; WA-1717214; WA-1717216; WA-1717217; WA-1717137; WA-1717145; WA-1717147; WA-
`(See also WA-1717278; WA-1717213; WA-1717227; WA-1717136; WA-1717100; WA-1717283; WA-1717282l;
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`389-390.)
`(CAT0007161 at 7225, 7235; see also CAT-770_001580 at 1662; CAT0004149 at 4508-09; CAT_00057357 at p.
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`Accused Large Milling Machines
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`U.S. Patent No. 7,530,641
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`Case 1:17-cv-00770-JDW Document 249-13 Filed 10/25/23 Page 11 of 13 PageID #: 25250
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`Large Milling Machines include a substantially similar damage avoidance/safety feature that is intended to perform
`insubstantial. Indeed, to the extent that any such differences exist, it is nonetheless my opinion that the Accused
`in claim element 15[a], a person of ordinary skill in the art would have understood these differences to be
`To the extent that any differences may exist between the Accused Large Milling machines and the features disclosed
`
`See 11[e] above.
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`drum and the ground surface.
`milling drum is raised by a pre-determined amount that is larger than the minimum distance between the milling
`The Accused Large Milling Machines perform a method in accordance with claim 11, characterized in that the
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`
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`explain the technology and/or illustrate this feature.
`to show that the PM620 practices this feature. I also may rely upon demonstratives that I have not yet prepared to
`interrogatories, and responses to requests for admission, and/or inspection of the PM620 or a representative machine
` may also rely on additional expert testimony, other documents considered, witness testimony, responses to
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` I
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`element 11[f]. Thus, it is my opinion that claim element 11[f] is also met under the doctrine of equivalents.
`substantially the same function, in substantially the same way, to achieve substantially the same result as claim
`Large Milling Machines include a substantially similar damage avoidance/safety feature that is intended to perform
`insubstantial. Indeed, to the extent that any such differences exist, it is nonetheless my opinion that the Accused
`in claim element 11[f], a person of ordinary skill in the art would have understood these differences to be
`To the extent that any differences may exist between the Accused Large Milling machines and the features disclosed
`
`
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`1717173; WA-1717143; WA-1717107 (Inspection Videos).)
`WA-1717232; WA-1717140; WA-1717166; WA-1717104; WA-1717235; WA-1717171; WA-1717172; WA-
`1717138; WA-1717102; WA-1717163; WA-1717164; WA-1717231; WA-1717165; WA-1717139; WA-1717103;
`WA-1717228; WA-1717237; WA-1717239; WA-1717101; WA-1717109; WA-1717111; WA-1717230; WA-
`(See also WA-1717281; WA-1717214; WA-1717216; WA-1717217; WA-1717137; WA-1717145; WA-1717147;
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`series machines).)
`accuracy of the description in the training manual and that the same software applies to the PM600 series and PM800
`(CAT0004149 at 4508-09; see also O’Donnell Dep. 275:9-279:9, 337-TA-1067, Jan. 5, 2018 (confirming the
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`the ground surface (2), and
`the milling drum (12) and
`minimum distance between
`amount that is larger than a
`by a pre-determined
`milling drum (12) is raised
`characterized in that the
`accordance with claim 11,
`15[a]. Method in
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`Accused Large Milling Machines
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`U.S. Patent No. 7,530,641
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`See 11[e] above.
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`blade that is arranged behind the milling drum when seen in the direction of travel is used as a sensing device.
`The Accused Large Milling Machines practice a method in accordance with claim 15, characterized in that a scraper
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`explain the technology and/or illustrate this feature.
`to show that the PM620 practices this feature. I also may rely upon demonstratives that I have not yet prepared to
`interrogatories, and responses to requests for admission, and/or inspection of the PM620 or a representative machine
` may also rely on additional expert testimony, other documents considered, witness testimony, responses to
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`arranged behind the
`scraper blade (22) that is
`characterized in that a
`with claim 15,
`17. Method in accordance
`
`element 15[b]. Thus, it is my opinion that claim element 15[b] is also met under the doctrine of equivalents.
`substantially the same function, in substantially the same way, to achieve substantially the same result as claim
`Large Milling Machines include a substantially similar damage avoidance/safety feature that is intended to perform
`insubstantial. Indeed, to the extent that any such differences exist, it is nonetheless my opinion that the Accused
`in claim element 15[b], a person of ordinary skill in the art would have understood these differences to be
`To the extent that any differences may exist between the Accused Large Milling machines and the features disclosed
`
`determined distance between the raised milling drum and the ground surface. (CAT_00057234 at p. 49.)
`See 11[e] above. The operator may raise or lower the moldboard by pressing a button, thereby setting a pre-
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`maintained between the milling drum and the ground surface.
`surface takes a lower limit position which corresponds to a pre-determined distance or to a minimum distance to be
`The Accused Large Milling Machines perform a method in that a sensing device measuring towards the ground
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`
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`ground surface (2).
`milling drum (12) and the
`be maintained between the
`to a minimum distance to
`pre-determined distance or
`which corresponds to a
`takes a lower limit position
`the ground surface (2)
`device measuring towards
`15[b]. in that a sensing
`
`explain the technology and/or illustrate this feature.
`to show that the PM620 practices this feature. I also may rely upon demonstratives that I have not yet prepared to
`interrogatories, and responses to requests for admission, and/or inspection of the PM620 or a representative machine
` may also rely on additional expert testimony, other documents considered, witness testimony, responses to
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`element 15[a]. Thus, it is my opinion that claim element 15[a] is also met under the doctrine of equivalents.
`substantially the same function, in substantially the same way, to achieve substantially the same result as claim
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`
`
`Accused Large Milling Machines
`
`U.S. Patent No. 7,530,641
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`explain the technology and/or illustrate this feature.
`to show that the PM620 practices this feature. I also may rely upon demonstratives that I have not yet prepared to
`interrogatories, and responses to requests for admission, and/or inspection of the PM620 or a representative machine
` may also rely on additional expert testimony, other documents considered, witness testimony, responses to
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` I
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`that claim 18 is also met under the doctrine of equivalents.
`function, in substantially the same way, to achieve substantially the same result as claim 18. Thus, it is my opinion
`include a substantially similar damage avoidance/safety feature that is intended to perform substantially the same
`to the extent that any such differences exist, it is nonetheless my opinion that the Accused Large Milling Machines
`in claim 18, a person of ordinary skill in the art would have understood these differences to be insubstantial. Indeed,
`To the extent that any differences may exist between the Accused Large Milling machines and the features disclosed
`
`
`
`See 11[e] above.
`
`
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`device.
`plate arranged at the side next to the milling drum and/or a hood enclosing the milling drum is used as a sensing
`The Accused Large Milling Machines practice a method in accordance with claim 15 characterized in that a side
`
`explain the technology and/or illustrate this feature.
`to show that the PM620 practices this feature. I also may rely upon demonstratives that I have not yet prepared to
`interrogatories, and responses to requests for admission, and/or inspection of the PM620 or a representative machine
` may also rely on additional expert testimony, other documents considered, witness testimony, responses to
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` I
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`that claim 17 is also met under the doctrine of equivalents.
`function, in substantially the same way, to achieve substantially the same result as claim 17. Thus, it is my opinion
`include a substantially similar damage avoidance/safety feature that is intended to perform substantially the same
`to the extent that any such differences exist, it is nonetheless my opinion that the Accused Large Milling Machines
`in claim 17, a person of ordinary skill in the art would have understood these differences to be insubstantial. Indeed,
`To the extent that any differences may exist between the Accused Large Milling machines and the features disclosed
`
`
`
`Accused Large Milling Machines
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`sensing device.
`drum (12) is used as a
`(18) enclosing the milling
`drum (12) and/or a hood
`side next to the milling
`plate (24) arranged at the
`characterized in that a side
`with claim 15,
`18. Method in accordance
`
`device.
`travel is used as a sensing
`seen in the direction of
`milling drum (12) when
`
`U.S. Patent No. 7,530,641
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`