`Case 1:17-cv-00770-JDW Document 388-2 Filed 05/24/24 Page 1 of 5 PagelD #: 35649
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`EXHIBIT 2
`EXHIBIT 2
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`Case 1:17-cv-00770-JDW Document 388-2 Filed 05/24/24 Page 2 of 5 PageID #: 35650
`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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`Plaintiff/Counterclaim-Defendant,
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`WIRTGEN AMERICA, INC.,
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`CATERPILLAR INC.,
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`v.
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`Civil Action No. 1:17-cv-00770-JDW
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`CONTAINS INFORMATION MARKED
`CONFIDENTIAL PURSUANT TO
`PROTECTIVE ORDER
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`Defendant/Counterclaim-Plaintiff.
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`INITIAL EXPERT REPORT OF DR. CHRISTOPHER RAHN
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`Case 1:17-cv-00770-JDW Document 388-2 Filed 05/24/24 Page 3 of 5 PageID #: 35651
`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`CAT-770_040200 (OMM Manual – Grade & Slope) at 0216.
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`398. The Accused PM600/PM800 Sensor Swapping Machines’ operator display
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`includes GUI buttons (switches) that allow the operator to change the inputs and outputs for the
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`grade and slope control. For example, the operator display includes virtual switches (items 6 and
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`7 in the image below) that allow the operator, during the milling operation, to pre-select the desired
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`sensor and confirm the sensor selection before the system swaps sensors.
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`246
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`Case 1:17-cv-00770-JDW Document 388-2 Filed 05/24/24 Page 4 of 5 PageID #: 35652
`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`CAT-770_022979 (All SOTA - Monitoring System/Grade & Slope) at 3041; see also CAT-
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`770_040200 (OMM Manual – Grade & Slope) at 0221, 0223; CAT-770_001323 (Hot Swap
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`Software Requirements) at 1323; see also CAT_00054722 (Hot Swap Flow Chart). Accordingly,
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`these operator displays’ GUI buttons allow the operator to pre-select the replacement sensor before
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`effecting the switchover.
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`399. As shown below, Caterpillar’s grade and slope system pre-sets the operating
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`parameter of the replacement sensor and then effects the switchover after the replacement sensor
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`has been pre-selected. After the operator has pre-selected the replacement sensor, the bench
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`function, pushes the currently measured value of the replacement sensor to be the target value of
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`the replacement sensor, before the sensor swap is completed. See Tarvin Dep., 65:5-21; 66:20-
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`67:6, Mar. 7, 2023.
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`247
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`Case 1:17-cv-00770-JDW Document 388-2 Filed 05/24/24 Page 5 of 5 PageID #: 35653
`HIGHLY CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY
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`Dated: May 19, 2023
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`Christopher Rahn, Ph.D.
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`299
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