`Case 1:17-cv-00770-JDW Document 250-92 Filed 10/25/23 Page 1 of 4 PagelD #: 29036
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`EXHIBIT 89
`EXHIBIT 89
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`Case 1:17-cv-00770-JDW Document 250-92 Filed 10/25/23 Page 2 of 4 PageID #: 29037
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`WIRTGEN AMERICA, INC.,
`Plaintiff,
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`v.
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`CATERPILLAR, INC.,
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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`Case No. 1:17-CV-00770-JDW-MPT
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`Defendants.
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`OPENING EXPERT REPORT OF DR. RICARDO VALERDI
`REGARDING SOURCE CODE
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`Case 1:17-cv-00770-JDW Document 250-92 Filed 10/25/23 Page 3 of 4 PageID #: 29038
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`very short period of time while the new selected sensors measurements are taken.
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`34.
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`To understand how each of these requests work, it’s important to also appreciate
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` For example, as discussed above,
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`whether the machine is on-grade
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`35.
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`In the Scratch Request,
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` These are done in this order and sequence
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`36.
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`In order
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`to actually perform
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`the “Scratching Request” switch,
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`15 CAT-SC0000050-51.
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`16 CAT-SC0000037, lines 2569-2572. It may not be immediately clear why this is.
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`Case 1:17-cv-00770-JDW Document 250-92 Filed 10/25/23 Page 4 of 4 PageID #: 29039
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`71.
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`I declare under penalty of perjury under the laws of the United States that the
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`foregoing is true and correct. Executed on May 18, 2023 in Tucson, AZ.
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`Ricardo Valerdi, Ph.D.
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`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
`35
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