GEOFFREY L. MAHON Augu - American Association for Justice

RE: MULTI-LEVEL AIR BAG : SWORN
STATEMENT OF:
CRASH SENSOR :
- - - - - - - - - - - - - - - -
GEOFFREY L. MAHON
August 2, 2002
Hackensack, New Jersey
B E F O R E:
DIANE FOND, a Certified Shorthand
Reporter and Notary Public of the State of New
Jersey, at the offices of JERROLD R. MC DOWELL,
ESQ., 45 Essex Street, Hackensack, New Jersey,
on Friday, August 2, 2002, commencing at 11:22
a.m., pursuant to Notice.
A P P E A R A N C E S:
G. LYNN SHUMWAY, ESQ.
ALSO PRESENT: Matt Wielgus, Videographer
BARRY A. FOND SHORTHAND REPORTERS, INC.
CERTIFIED SHORTHAND REPORTERS 381
BROADWAY WESTWOOD, NEW JERSEY
07675 (201) 666-4888

2
1 MR. WIELGUS: My name is Matt
Wielgus. I'm
2 employed by Phokus, Incorporated, 56
Greenwood
3 Avenue in Madison, New Jersey.
Today's date is
4 August 2nd, 2002. We're at the law
offices of
5 Jerrold McDowell, 45 Essex Street in
Hackensack,
6 New Jersey. We're here to videotape
the sworn
7 statement of Geoffrey Mahon. The
time is
8 approximately 11:23.
9 Would the attorney please
identify
10 themselves?
11 MR. SHUMWAY: Yes. I am Lynn
Shumway
12 taking this examination of Mr. Mahon.
13 MR. WIELGUS: The Court
Reporter will now
14 swear in the witness and we can begin.
15
16 G E O F F R E Y L . M A H O N , 221 Circle

Avenue,
17 Ridgewood, New Jersey, is sworn.
18
19 EXAMINATION BY MR. SHUMWAY:
20 Q Thank you. Let's first of all
get a little
21 bit of information on the record about your
background in
22 the sensing industry and your education.
Let's start with
23 the education.
24 A Okay. I have a Bachelors and a Masters
degree in
25 mechanical engineering. Bachelors is from
Fairleigh
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3
1 Dickinson University. The Masters is from the
Cooper
2 Union. I am licensed to practice engineering
in the State
3 of New Jersey, so I am a P.E.
4 Q And you went to work in 1988
for Breed. Is
5 that correct?
6 A 1987. I joined Breed in June of 1987.
7 Q Could you give us a quick

undown of what
8 your mechanical engineering or other
engineering career
9 involved prior to 1987?
10 A Prior to 1987, beginning in 1967, I
worked for a
11 series of consulting engineering firms and we
designed and
12 built process plants and power plants; in
particular,
13 desalination plants, power plants and things
such as coal
14 gasification plants. I was project manager of
a coal
15 gasification plant in North Dakota.
16 Some of the expertise that I developed
over that
17 time was the ability to manage large complex
projects, and
18 in 1987 the Breeds, who I had known for some
time,
19 approached me because they felt the air bag
industry was
20 about to blossom and that they were a
relatively small
21 organization at the time; they were going to
have to grow

22 rapidly, and this was a large technical
undertaking that
23 was going to require a staffing up with a
large number of
24 technical people, bringing in a lot of
equipment and
25 organizing a lot of things, and they asked if
I would join
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4
1 them in that endeavor. And I was originally
reluctant but
2 eventually agreed, and in June of 1987 joined
Breed
3 Corporation, which became Breed Automotive and
later Breed
4 Technologies.
5 Q We'll just call Breed.
6 A Which we will call Breed, that's fine.
7 Q What was the background of the
Breed
8 Corporation at the time the Breed brothers
came to try to
9 recruit you that qualified them or put them in
the
10 position to compete for air bag
component business?

11 A Well, Breed originally was a
manufacturer of
12 sensors for armament. They would measure the
conditions
13 of a shell in a cannon, for example. When
you fire a
14 cannon, you would prefer that the shell not
go off in the
15 barrel, so there is a sensor in that shell
that senses
16 that the shell has been accelerated and has
accelerated
17 for long enough and had a big enough velocity
change or
18 travelled a long enough distance to have left
the cannon.
19 At that point it's gliding, and then the fuse
is set or
20 enabled or armed, and then the next time it
impacts
21 something the shell will explode.
22 They also made a sensor that sensed the
rotation of
23 the shell in a cylinder in the bore, if you
will, of a
24 cannon, and after so many rotations they would
arm the

25 shell.
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5
1 So they built sensors that lived in
very, very
2 violent conditions; namely, inside cannons or
mortars or
3 things of that nature, and they concluded that
it was
4 easier to sense crashes in automobiles because
those are a
5 lot more gentle than the interior of a cannon.
And a
6 number of the engineers at Breed Corporation
started
7 working on sensors that would sense cars
crashing, and
8 they eventually came up with what is called
the
9 ball-in-tube sensor, which was an offshoot of
some of the
10 sensors they used for sensing shells. They
then started
11 testing the sensors in car crashes when car
companies were
12 testing cars and found that they were able to
reliably

13 sense a crash and to determine when a crash
was severe or
14 when it wasn't severe. In particular, they
could do this
15 in the front of the vehicle in the so-called
crush zone.
16 It was relatively easy to sense crashes in the
crush zone.
17 Q Let's talk about the crush zone
in a few
18 moments but finish up getting a little of your
background.
19 How did you personally develop
expertise in and
20 knowledge about manufacture and performance of
sensors for
21 automotive crash applications?
22 A Okay. When I arrived at Breed I
obviously knew
23 nothing about crash sensors because that
knowledge was
24 resident at Breed. I worked directly with
David and Alan
25 Breed, learning how the sensors worked,
learning what we
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1
were going to have to do to implement them in
cars,
2 learning what we were going to have to do to
manufacture
3 them. So from the period of June of 1987
until May of
4 1988 I was with David Breed almost every day
learning more
5 and more about sensors. We had a computer
model that
6 described how the sensor worked. We had
physical tests
7 that examined how the sensors worked, and I
went into
8 those in great depth to try and figure out
how to put
9 together an organization to actually
manufacture these
10 sensors and to implement them in vehicles.
11 Then in May of 1988 a rift which had
been growing
12 between David and Alan Breed actually split
apart and
13 David Breed left the company, and we were
faced with the
14 problem that the man who did all of the
sensor

15 calibrations and all of the computer
modeling of sensors
16 had left.
17 At that time, because I had some
background in
18 computer modeling very early in my
consulting days, I
19 decided that it would be necessary for me
to take over
20 that activity, which I volunteered to do and
in fact did,
21 and began to study the computer program, get
it running
22 again, get the modeling running again, and
from May of
23 1988 through late 1987 I had total charge of
the sensor
24 calibration effort at Breed Technology. I was
responsible
25 for the sensor system calibrations that left
the company
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7
1 on every vehicle. I didn't personally do
every vehicle,
2 but I signed off on every vehicle. I had
ultimate

3
responsibility for every vehicle. I put
together a team
4 of engineers who actually did the work. I
taught them the
5 essence of their job and the details of their
job and I
6 supervised their work and led them to get the
appropriate
7 results.
8 Q What period of time did you
supervise and
9 oversee the sensor engineering work at Breed?
10 A From May of 1988 until late 1997.
11 Q And in 1997 you left Breed?
12 A In 1997 they closed the Boonton
facility and
13 retained me for a period of about a year. My
final day at
14 Breed was in March of 1998, but realistically
my team was
15 disbanded in '97.
16 Q And Boonton is Boonton, New
Jersey?
17 A Boonton, New Jersey, yes.
18 Q Near your home here?
19 A Near my home, yes.
20 Q Now, let's jump over and talk a

little bit
21 about how crush zone sensing works. I think
you've got a
22 diagram that you can use to explain that.
23 A Right. Let me begin by saying that
crash sensing
24 can be divided, at least one way, into two
different
25 categories. One is crush zone sensing, and
the other is
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1 everything else.
2 If you consider a car and you think
about a car
3 moving down the road or going around corners
or anything
4 like that, the car moves as a unit. The front
of the car,
5 the back of the car, the middle of the car,
the top of the
6 car and the bottom of the car all move
together. They
7 start together, they stop together, they
corner together.
8 So one place in the car is very much the
same as another

9
if you wanted to measure what the car was
doing. But if
10 you run that car into a brick wall, the
front of the car
11 comes to a complete stop shortly after it
touches the
12 brick wall, while the back of the car
continues moving.
13 And initially, the back of the car has slowed
very little
14 from the very first instant the front of the
car has
15 touched the brick wall, and then perhaps an
inch or two
16 more of the car has come to a complete stop
and the back
17 of the car is still moving, although somewhat
more slowly,
18 because that portion that was crushed
converted some of
19 the kinetic energy of the car into work on the
metal of
20 the car. So you've got a situation where the
front of the
21 car is now completely stopped and the back of
the car is
22 moving; so the car is not acting as a single

homogenous
23 unit anymore. There are, in fact, two zones.
24 For sensing purposes, when we talk
about the crush
25 zone, we talk about that part of the car
which comes to a
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9
1 stop in time to make a decision whether or
not the event
2 or the crash warrants the triggering of an
air bag. So
3 it's not necessarily the region of the car
where all of
4 the metal is bent; it's the region of the
car which has
5 come more or less to a complete stop in time
to adjudicate
6 the event into a crash or a non-crash event.
7 Now, if I may, we have a vehicle here -
-
8 MR. SHUMWAY: Have you had time
to zero
9 down in on it?
10 A -- running into this brick wall here,
and you can
11 see some crushed metal. We have chosen two

locations, a
12 location A, which is in the passenger
compartment, perhaps
13 between the front bucket seats or in the
console or
14 something like that; and a location B, which
would be on
15 the radiator support, very close to the front
of the
16 vehicle.
17 We have mounted devices known as
accelerometers in
18 these two locations, measured the acceleration
that these
19 two locations felt and then converted that
acceleration by
20 a process known as "integration," into a
velocity change
21 of those two locations. And this curve here
represents
22 the velocity change of A, which is the
passenger
23 compartment. And as you can see -- and this
scale down
24 here is time in milliseconds, which are
thousandths of a
25 second. This scale here is miles per hour in

velocity.
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10
1 So the car was originally doing 35
miles per hour.
2 It struck the wall at this time zero, and
initially very
3 little happened. And as the car started
crushing, it
4 started slowing down and the passenger
compartment change
5 in velocity looks like this; and after a
period of about
6 70 milliseconds in this car, which
parenthetically makes
7 this a relatively stiff car, the car has come
to a
8 complete stop.
9 In location B, which is towards the
front of the
10 car, you can see that for the first perhaps
ten
11 milliseconds it acts exactly as location A, so
it's in the
12 part of the car which for the first ten
milliseconds has
13 not crushed and so it's everywhere else in the

car. The
14 car everywhere else is acting as a single
entity. But
15 then you can see that the crushed metal stacks
up in front
16 of it and this sensor comes to a stop very
rapidly. This
17 velocity change is dramatic, so that by 16 or
17
18 milliseconds into this crash at this point,
this location
19 has come to a complete stop. We are now in a
position to
20 measure the crash completely, so we don't have
to predict
21 or worry whether this has been a bad crash.
We can
22 measure the velocity change and we can say
that the front
23 of the car has gone through a 35 mile an hour
velocity
24 change and that the back of the car will
shortly go
25 through a similar velocity change; and
therefore, we need
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11

1
to do something like deploy an air bag. And
as you can
2 see, eventually the back of the car does go
through the 35
3 mile an hour velocity change. But that
information is not
4 available until 70 milliseconds, where here
perhaps 16
5 milliseconds it's available. And in fact, if
we had a
6 threshold less than 35 miles an hour to
trigger a sensor,
7 we would have all the information we need at
perhaps 15
8 milliseconds or maybe 12 milliseconds. The
point is, in a
9 very short period of time we can measure the
crash and
10 determine whether or not this crash warrants
an air bag.
11 It's a very, very powerful method of sensing
crashes.
12 Now, this being so powerful and so
simple, it
13 should be easy to implement. Every car
should do it this
14 way. The problem is that less than five

percent of the
15 crashes that occur are cars driving straight
into brick
16 walls. It's a very small percentage of the
cars.
17 Typically, cars hit walls on an angle. They
hit part of
18 the wall, such as a bridge abutment. They
hit telephone
19 poles, light stanchions. They hit other
cars. They hit
20 the back of trucks, where the tailgate is at
a level
21 similar to the hood. They hit barriers in
the road that
22 only come up a foot or two. So you don't
always hit the
23 full front of the vehicle; and therefore, if
you only had
24 one sensor, if you missed that sensor you
could fail to
25 sense the crash. So a sensor system designer
needs to
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12
1 understand the structure of the vehicle and
how much

2
information can be provided to the sensor by
the motion of
3 the structure.
4 If we had an infinitely rigid invisible
shield in
5 front of our car, one sensor would work fine
because every
6 impact at every point in the front of the
vehicle would
7 look like a frontal barrier crash, but such a
shield
8 doesn't exist. We're dealing with grilles and
bumpers and
9 hoods and things like that; and so you could
have a pole
10 which you could hit in the center or you could
hit on the
11 side. You could hit a barrier at an angle,
and you need
12 to therefore put sensors across the front of
the vehicle,
13 spaced on the structure such that no matter
what you hit
14 will provide an adequate signal to the sensor.
15 Typically, this can be done with two or
three
16 sensors across the front of the car.

Sometimes two
17 sensors on either side of the radiator are
adequate if the
18 radiator support is relatively rigid, that a
pole coming
19 into the center will trigger one or both of
the sensors;
20 an angled barrier will catch the outside of
either sensor;
21 an offset barrier, which only catches part of
the vehicle,
22 would catch at least one of the sensors. And
then one
23 ought to consider whether or not you need to
have some of
24 the sensors higher than others to be able to
catch a
25 tailgate or a road barrier.
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13
1 This is all part of the art of
designing crush zone
2 sensing systems; and typically, you end up
with two, three
3 or even four sensors arrayed across the front

of the
4 vehicle, depending on the vehicle structure,
to insure
5 that you catch all the crashes.
6 I have said in the past that I could
catch crashes
7 in a vehicle made out of cardboard, but I
might take
8 thirty sensors to do it. Obviously, since
vehicles are
9 made out of steel there's a certain rigidity
that allows
10 you to receive the information several inches
from where
11 the point of impact is and still get adequate
information.
12 One also needs to be careful how one
mounts these
13 sensors to insure that they come to a stop, or
at least
14 give sufficient information before they
rotate 90 degrees
15 and start looking at crashes from the side
and not from
16 the front, which are of no interest to
frontal air bags.
17 But this is part of the art of any sensing

system, and the
18 sensor designer needs to consider the mounting
and the
19 bracketry and the location in concert with the
structure
20 of the vehicle. So that's a short discourse
on crush zone
21 sensing.
22 Occupant compartment sensing, or
passenger
23 compartment sensing, is somewhat easier
because by and
24 large, to a first approximation, almost
anywhere in the
25 vehicle acts the same as anywhere else.
There are some
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14
1 differences from rotation, and so forth, but
those are
2 small compared to the difference between the
passenger
3 compartment and the crush zone.
4 Passenger compartment sensing is much
harder to do
5 than crush zone sensing. It requires much
more

6
sophistication. As a result, for the moment
when we're
7 talking about multi-level sensing systems,
which I know
8 we're going to talk about, I want to really
talk about
9 crush zone sensors.
10 Q Okay. Now, the crush zone
sensor that was
11 used predominantly in the late '80s and
through most of
12 the '90s was a sensor designed by Breed. Is
that correct?
13 A That's correct. We at Breed had more
than 50
14 percent of the world market for crash
sensors. Our
15 sensors were manufactured by us. They were
manufactured
16 under license from us by TRW and under
license from us by
17 Bendix Restraints Group. But it was our
design and our
18 technology that was installed in more than 50
percent of
19 the world's cars. In fact, I think it was
more than 60

20 percent of the world's cars at one point.
21 Q Who during the late '80s, 1988
and after,
22 and through most of the '90s was the primary
engineer in
23 charge of that sensing department?
24 A I was.
25 Q Could you describe for us what
the
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15
1 ball-in-tube sensing system comprised of or
the unit, the
2 component, how -- what was that comprised of
and how did
3 it work?
4 A It was comprised of a gold-plated ball
which
5 nestled inside a metal cylinder cradled at
the back by a
6 plastic housing. There was a small gap
between the ball
7 and the cylinder, very small gap as a matter
of fact, on
8 the order of a thousandth or two thousandths
of an inch,
9 so that as the ball moved forward it would

create a
10 partial vacuum behind it and there would be
a pressure
11 difference between the gas at the front of
the ball and
12 the gas at the back of the ball, so gas would
flow through
13 the gap past the ball and thereby damp the
ball's motion.
14 Also, the partial vacuum at the back creates
a form of
15 damping. So it is known in science that a
damped device
16 can be used to convert or to integrate
acceleration into a
17 velocity change. So this sensor was basically
a velocity
18 change sensor.
19 Because when you drive down the road
and step on
20 your brakes from sixty miles an hour and come
to a stop at
21 a stop light, you go through a velocity change
of, say,
22 sixty miles an hour, you would not want an
air bag to
23 deploy on such an event, there was an

additional feature
24 of the sensor, which was a magnet or a
spring in some
25 cases which would hold the ball back into its
initial
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16
1 position and create a minimum acceleration
requirement of
2 anywhere from as low as 1.5 to as much as 5 or
6 G's,
3 depending on where we use the sensor, before
the velocity
4 integration would occur. This is known as the
bias of the
5 sensor, and it requires that you have some
kind of fairly
6 strong deceleration before we start
integrating the
7 acceleration and converting it into a velocity
change.
8 Q Now, the sensors that Breed
sold to the
9 auto industry during the late 1980s and '90s
up to 1997
10 were mostly the ball in tube, correct?
11 A Mostly, that's correct.

12 Q And they were sold
universally for use in
13 single stage inflators. Is that right?
14 A Yes, as far as I know.
15 Q Was there any capability of
using a Breed
16 ball in tube like that Breed produced in and
after 1988 to
17 sense a threshold higher than the thresholds
that the
18 Breed ball in tube were actually used to sense
in American
19 cars during the period from 1988 to
1997?
20 A Well, sure. Within some limits,
we made many
21 calibrations from low to high. The
calibrations we
22 offered varied by a factor of about 1.6,
just in the
23 standard sensors that we made. We could have
made -- and
24 those are front crush zone sensors. We
certainly could
25 have made less sensitive or more sensitive
crush zone
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17
1 sensors. The less sensitive ones would have
required some
2 change to the off-the-shelf components. We
would not want
3 to reduce the gap between the ball in the
cylinder
4 significantly beyond our highest calibration
sensor
5 because unpleasant effects started occurring
at very, very
6 small gaps. We could increase the travel
somewhat on
7 these sensors to increase the calibration,
decrease the
8 sensitivity, but the other thing that can be
done
9 relatively easily, within limits, is to reduce
the ball
10 diameter and, therefore, the ball mass, and
the ball mass
11 reduces as the cube of the diameter. The
initial damping
12 reduces as the square of the diameter, and the
viscous
13 damping reduces as the diameter. So you can
have a rather

14 dramatic decrease in sensitivity with a fairly
small
15 decrease in mass and decrease in diameter.
16 There are some difficulties with
reducing the mass,
17 in that the electrical contact pressure gets
reduced by
18 reduced mass. So for example, I wouldn't
recommend
19 reducing the mass or the diameter by a factor
of two and,
20 therefore, the mass by a factor of eight.
This would take
21 you far too low in contact pressure. You
could certainly
22 reduce the mass by 30, 40, 50 percent and
still design
23 contacts that would give good electrical
performance. So
24 a combination of reducing the diameter by
anywhere from 10
25 to 25 percent, increasing the travel by a bit
could get
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18
1 you calibrations that, depending on the
vehicle, could

2
give you 18, 20, 22 mile an hour thresholds
if somebody
3 wanted that. Beyond that, the ball-in-tube
technology
4 would be stretched beyond reasonable
limits.
5 Q When you spoke about
desensitizing the
6 sensor, are you talking about changing it from
the old
7 threshold of eight to fourteen that many
manufactures were
8 using to a threshold of something that has
around a
9 nominal 20 miles an hour?
10 A For example, yes.
11 Q And you could do many
iterations in
12 between?
13 A Oh, certainly in between you could do -
- you have a
14 continuum in between. In order to do it you
need to crash
15 the vehicle a number of times. You need to
take a lot of
16 accelerometer data. You need to do a lot of
computer

17 modeling. And as I said, we would need new
tooling for
18 the cylinders and the plastic parts and we
would have to
19 buy other material and different tooling for
the balls;
20 not different material, but different rod
stock is what I
21 mean, for forming the balls at a different
diameter. But
22 there is no technical barrier to raising the
threshold to
23 in the vicinity of 20 miles an hour, give or
take a
24 couple, depending on the vehicle. Some
vehicles might be
25 limited to 18, some might be amenable to 24,
depending on
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19
1 location and the structure. Sitting here,
it's not easy
2 to say would a particular vehicle be amenable
to 23 or
3 something like that. It requires study to
get the exact
4 number, but certainly the range of 20 miles

an hour is
5 doable and I'm confident that I could have
done a 20 mile
6 an hour threshold in most of the American
vehicles, had
7 anyone asked.
8 Q Let's talk about how you would
package
9 Breed ball-in-tube sensors of the various
sensitivities
10 that you've just described to make it two
stage or two
11 level of threshold sensing system to operate
a two-stage
12 inflation air bag system.
13 A Sure. The Breed sensors were
packaged in a metal
14 housing, which we refer to as a can, and
typically these
15 cans were about two inches by two and a half
inches by
16 maybe three inches, overall dimensions. The
can contained
17 the ball-in-tube sensor, which consisted of
the
18 aforementioned ball and tube and the plastic
housing, and

19 so forth, generally mounted on a printed
circuit board,
20 and the printed circuit board terminated the
wire harness
21 and frequently contained resistors so that
certain
22 diagnostic tests could be made when the car
was started.
23 If I were going to do a dual level
system, I could
24 make the can larger in either depth or width
and either
25 stack the sensors vertically or horizontally,
put two
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20
1 sensors next to each other on the same
printed circuit
2 board or above each other on the same printed
circuit
3 board, place them in the can with a wire
harness
4 containing one or two more wires, or even
three more
5 wires, depending on the circuitry of the car
company --
6 conductors, I should say -- and that would

come out into a
7 cable which would exit the can through a
grommet, and so
8 the can would grow by -- it wouldn't become
twice in the
9 dimension; it would be perhaps 70 percent
more in one
10 dimension and the other dimensions would stay
the same.
11 Maybe even 80, but I think I could do it for
70 percent
12 increase.
13 Q Now, if you could, there have
been some
14 suggestions by people in the auto industry
that, in fact,
15 if you tried to put a second threshold to
sense a higher
16 threshold, something like 18 or 20 miles per
hour for the
17 high level of a two-stage air bag system,
that you would
18 end up with late deployments in the second
threshold in
19 crush zone sensing. Is that accurate?
20 A You would not have late deployments
necessarily.

21 The second squib or initiator would probably
trigger a
22 couple or so milliseconds later than the
first, but what
23 you would have is a timely trigger of the
first initiator.
24 The bag would break the cover and progress
towards the
25 occupant; and as that was occurring, the
second gas
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21
1 generator would begin producing gas, and the
bag would be
2 pumped with the extra gas. So what you would,
in fact,
3 have is a gentle deployment with a stiffened
bag, which is
4 actually quite desirable.
5 Q The gentle deployment you're
talking about
6 is?
7 A Is the breaking of the cover and the
initial thrust
8 of the front face of the bag. This is the
area where
9 there has been some bad publicity over the

years about
10 bags harming people during deployment, and
it's the
11 aggressive nature of the cover burst and the
progression
12 of the front face of the bag which has caused
some of
13 these injuries, and the industry has opted to
de-power the
14 bags and spend more time filling the bags.
And we used to
15 fill bags in perhaps 35 milliseconds, and this
has been
16 stretched out to 50 or more milliseconds, as
it was
17 understood that we need to open the bag but
we don't need
18 to throw it out quite as rapidly now as we
did in the
19 past. So a dual stage system would still
break the cover
20 in a timely manner, start to put the bag out
gently and
21 then pump it a little bit further, so a delay
of a few
22 milliseconds is not an issue, point one.
23 Point two is that you design the system

so that the
24 high threshold fires on time. This is a
requirement of
25 any sensor design. The sensor has to fire on
time, has to
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22
1 trigger on time. Anything less than a timely
trigger is a
2 poorly designed system.
3 Q Can you use the diagram you
were using to
4 explain the crush zone to us in a crush zone
sensing
5 system and explain to us, based on the trace
we're looking
6 at there, how much time difference there would
be in, say,
7 a 24 mile-an-hour angled barrier impact
between the
8 sensing of a low threshold, a regular
threshold, versus
9 this hypothetical 20 mile-an-hour threshold
we're talking
10 about with the redesigned sensor?

11 A Okay. Well, first of all, this is not
of an angled
12 barrier. This is of a frontal barrier. But
if your
13 sensor is properly located, then the sensor
trace in the
14 crush zone is quite similar because crushed
metal stacks
15 up and you get a rapid velocity change.
16 What you see here is that at the
beginning of the
17 crash there is virtually no velocity change,
and no
18 reasonable sensor, whether it's a sensor set
to go off at
19 ten miles an hour or a sensor set to go off at
20 miles an
20 hour, is going to trigger in this time
period. And you
21 can see this occupies the first ten
milliseconds or so of
22 this crash. Then you can see that we have a
velocity
23 change of well over 30 miles an hour that
occurs in a
24 period of perhaps six milliseconds, and if I
had a sensor

25 for a fourteen mile-an-hour crash, which is
typically set
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23
1 at ten miles an hour or less in order to
trigger the
2 sensor, but even at a fourteen mile an hour
you can see
3 that we would have achieved that. Having
spent the first
4 ten milliseconds doing nothing, we would have
achieved
5 that in the next perhaps four milliseconds.
If we needed
6 a higher calibration, say ten miles an hour
higher, the
7 difference in achieving that is perhaps a
millisecond or
8 two. The sensor itself would be slightly
less responsive
9 than this sensor because the travel would be
slightly
10 longer. That would be the only reason, by
the way, it
11 would be less responsive, and one could
design it by
12 adjusting the mass and the gap so that the

trigger time
13 would not be significantly later; but even so,
it might be
14 two or three milliseconds slower than this
sensor. So the
15 fact that this sensor achieved its velocity
here and this
16 sensor was perhaps two milliseconds later and
could be
17 three milliseconds slower, you would be
perhaps five
18 milliseconds later on your initiation of
your second
19 stage.
20 But remember, the bag would have
begun here
21 (indicating). The bag doesn't normally leave
the cover
22 for six milliseconds. By the time this
sensor is
23 beginning to initiate gas generation, the bag
is still
24 inside the cover. Now, there's still six
milliseconds or
25 so before the generant really creates a lot
of gas, but
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24
1 the bag then comes out of the cover and starts
being
2 filled and it gives you the sort of curve that
is quite
3 desirable today. There is not an issue, if
the sensor is
4 properly designed, of a late sensing. These
sensors
5 integrate the velocity and come to a
conclusion.
6 Q Now, if we were going to talk
about a pole
7 impact, what additional complications, if any,
would there
8 be using a double ball in tube set to sense a
lower and a
9 higher threshold as we've been talking about?
10 A The issue with poles has nothing to do
with single
11 or dual or high or low thresholds. The issue
with poles
12 is, is the sensor in a position to sense the
crash or is
13 it not. If it's in a position to sense the
crash, if
14 there's enough sensors in the front of the

vehicle such
15 that the pole will impact one of the
sensors or impact
16 structure that will provide the information to
one of the
17 sensors, then the crash can be sensed; and if
it's not, it
18 won't. And so an improperly designed sensor
system might
19 see a pole impact where the sensor folds
inwards before it
20 gets the information. That's not an issue of
threshold;
21 it's an issue of sensor system design. The
designer has
22 to work with the structure of the vehicle.
Anything less
23 is irresponsible.
24 Q Now, ball in tubes -- ball-intube
sensors,
25 are they the only way to sense crashes in the
crush zone?
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25
1 A No. We felt that in the late '80s
ball-in-tube
2 sensors were superior from both a technical

and, in some
3 cases, economic point to other methods. There
was --
4 there were a number of spring type sensors.
TRW made
5 something called a Roll-a-Might, which was
essentially a
6 spring mass sensor. It did not sense velocity
change very
7 well, so it was an acceleration sensor. And
as a result,
8 if you had a sharp short event, such as a
breakaway pole
9 or a breakaway barrier or something like that,
you could
10 get a bag, whereas our sensor would require
that you slow
11 down and would measure the slow down rather
than the rap.
12 But then as the time went on -- well,
in fact, even
13 in the '80s there were accelerometers that
existed which
14 could measure the acceleration and, in fact,
were used in
15 all of these test crashes to measure the
acceleration, but

16 they were expensive and then you would have to
have some
17 computing power to interpret their signal into
a velocity
18 change. So although they were technically
feasible, it
19 would cost you hundreds of dollars to
implement the system
20 like that in a vehicle, and the car companies
didn't feel
21 that in production such a system would get to
be
22 inexpensive, whereas they felt that the Rolla-Might
and
23 ball in tube could get to be inexpensive.
24 Now, naturally there have been great
advances in
25 electronic technology, and the price of
accelerometers and
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26
1 microprocessors and application specific
integrated
2 circuits, so called ASICs, has come down
dramatically and
3 came down dramatically beginning with the very
late '80s

4
and the early '90s, so that by the early '90s
there were
5 accelerometers that could be used to measure
sense crashes
6 in the crush zone if someone so desired.
7 Q Is their only one kind of
accelerometer or
8 are there various levels?
9 A There are numerous kinds of
accelerometers
10 characterized by their method of measuring
acceleration
11 and by their construction. There are sensors
which have a
12 movable mass, and that movable mass changes
something
13 called capacitance, and they're called
capacitive sensors.
14 There are sensors that have a movable mass
which create a
15 stress and a strain in the beams that hold the
movable
16 mass, and a material known as a piezoresistive
material
17 is applied to those beams, and the change in
resistance is
18 measured; and there are sensors that use a

form of quartz
19 that when subjected to pressure produces an
electrical
20 current, and those are known as piezoelectric
21 accelerometers.
22 Beyond that there are many shapes of
beams and
23 masses. Some of them look like many fingered
combs; some
24 of them look like blocks of silicons; some of
them look
25 like beams. So there are -- there's huge
variation in
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27
1 accelerometer design.
2 Q Some car companies started
using
3 accelerometers to measure crash severity to
fire -- to get
4 a threshold to fire an air bag even in the
'80s. Is that
5 true, say the Bosch system for Mercedes?
6 A Yeah, I'm not sure what year the Bosch
system came
7 out, but certainly by the early '90s there
were

8
accelerometer-based systems. I understand
that Bosch may
9 have had a system in the very late '80s, but I
cannot say
10 exactly what year.
11 Q Now, American car companies
started working
12 towards incorporating these electronic sensing
systems
13 using accelerometers in the early '90s?
14 A Oh, yes.
15 Q And do you know about when they
started
16 going into production?
17 A Certainly in the '93, '94, '95 time
frame they were
18 beginning to be phased in, and that phasing
continued
19 right through the very late '90s. But in the
very early
20 '90s we were developing electronic sensing for
the Ford
21 Motor Company. We did not get sourced for
that business.
22 We did develop sensors for Fiat, and we were
sourced for
23 that business on a couple of Fiat models. I,

in fact,
24 have the patent for that sensing system.
25 Q Now, the accelerometers used in
electronic
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28
1 sensing system, where can they be placed in
the car in
2 relation to your discussion about different
placements in
3 the car in crush zone versus passenger
compartment?
4 A There are no fundamental limitations
where the
5 accelerometers can be placed. The issue is
how to package
6 the accelerometer. If you put the
accelerometer into the
7 electronic control module, sometimes call the
SDM, in the
8 passenger compartment in a box containing
other electronic
9 components, then the accelerometer can be
fairly fragile.
10 It can be packaged inexpensively mounted on a
circuit
11 board with no special protection and it's

very cost
12 effective and inexpensive.
13 If you want to put a sensor or an
accelerometer
14 into the engine compartment, then you
require a more
15 robust package. It's going to have to be
hermetic. It's
16 going to have to be safe from oil, and so
forth. The
17 package is going to have to withstand
relatively higher
18 temperatures, so the electronics for the
application
19 specific integrated circuit may be somewhat
more expensive
20 because they're going to have to be rated at a
higher
21 temperature.
22 The wiring, of course, is going to
have to be
23 similar to the wiring for other under hood
applications.
24 It's going to have to be sheathed. You know,
people drop
25 wrenches, they drive over stones which get
kicked up; so

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29
1 the under hood environment is a non-trivial
environment
2 and you have to package for it, and this will
add a few
3 dollars to the cost of an accelerometer just
to get a
4 robust package. But there's no fundamental
reason why it
5 can't be done. It's just an issue of
packaging it
6 properly for the application.
7 Q With an accelerometer it's
more difficult
8 to sense a crash and fire an air bag from the
passenger
9 compartment than it is from the crush zone?
10 A Well, that's true of any system
because there is
11 far more information available in the crush
zone at the
12 time you need to make a decision than there
is in the
13 passenger compartment. In the crush zone you
measure the
14 crash. It's over in the crush zone. The

crash is
15 completely over, you measure it, you say, gee,
that was a
16 bad crash, I think I'll fire an air bag, and
you have all
17 the time in the world to do that.
18 In the passenger compartment, you
predict that this
19 that I'm feeling will be a bad crash by the
time it's
20 over, but by the time it's over I have to have
deployed an
21 air bag. So there's a lot more information
that needs to
22 be gathered in the passenger compartment.
There are
23 inferences that have to be made that there's
an
24 acceleration and it's increasing. There are
increasing
25 amplitude of the vibration; there are some
frequency
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30
1 issues; there are many things people look at,
whereas the
2 work that needs to be done in the crush zone

is measure
3 the change in velocity, yes, it's bad, give me
an air bag.
4 It's a much simpler, if you will, algorithm.
It's not
5 even an algorithm; it's a measurement. It's a
very simple
6 circuit that would decide to fire the air bag
at one or
7 two levels using an accelerometer. The
computational
8 requirements are trivial.
9 Q Now, if you are going to use an
10 accelerometer in the SDM or air bag control
module that's
11 somewhere in the passenger compartment on many
American
12 cars through the mid 1990s, in the mid 1990s,
say '93 to
13 present, was it possible to design a reliable
sensing
14 system using that in passenger compartment
accelerometer?
15 A Everything is relative. Many sensing
systems were
16 designed. A vast preponderance of the cars on
the road in

17 the late '90s by then had sensors with
accelerometers in
18 the SDMs. Some of them required additional
front sensing,
19 known as auxiliary discriminating sensing,
which could
20 have been ball in tube, it could have been a
read switch
21 based or it could have been accelerometer
based.
22 I wrote a paper some time ago on the
relative
23 merits of single point versus multi-point
versus all
24 mechanical, and multi-point is always
smarter. It has
25 more information than single point, so it's
always harder
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31
1 to adjudicate all events from the passenger
compartment
2 than it is from the crush zone. On the
other hand, it
3 takes multiple sensors in the crush zone,
so it's more
4 expensive than in the passenger

compartment.
5 The multi-point sensors add some
small amount of
6 weight to the car. They add some small amount
of
7 complexity to the car. So there are tradeoffs
8 encountered in designing sensor systems. But
in general,
9 it is more difficult to sense a crash, to
sense the total
10 universe of crashes, in the passenger
compartment than in
11 the crush zone.
12 If all one ever ran into were frontal
barriers at
13 90 degrees, it's a trivial exercise no matter
where you do
14 it. It's the other 96 percent of the crashes
that are the
15 problem. Frontal barriers represents perhaps
four percent
16 of the total population. It's the poles, it's
the offset
17 barriers, it's the overrides, the under rides,
the angled
18 barriers that create the problems because each

of these
19 provides a different signature to the
passenger
20 compartment and you have to sort out each of
these
21 signatures and at the same time reject
potholes, railroad
22 track overrides, perhaps deer hits and other
23 non-deployment events.
24 Q In the 1990s it is true, isn't
it, that
25 there were some American cars that were
produced with only
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32
1 a single point sensing system without
auxillary
2 discriminating sensors?
3 A That is correct.
4 Q Now, would those cars that had
that kind of
5 system be able to have a second threshold
built into their
6 accelerometer-based system to sense a 20 milean-hour
7 collision as well as a 114 mile-an-hour
collision?

8 A In principle, yes. What you would have
to do is
9 run the whole series of crashes in simulations
at the
10 higher threshold and then design the
algorithm for the
11 higher threshold. You would then have the
higher
12 threshold algorithm and the lower threshold
algorithm both
13 built into the microprocessor. It would
require only a
14 slightly more capable microprocessor than they
had. The
15 same accelerometer could probably used for
both. I see no
16 reason to put a second accelerometer in. And
of course
17 the firing circuitry would have to be
duplicated for the
18 first and second stages, but that's a
straightforward
19 circuitry.
20 Q Were there more powerful
microprocessors
21 available that would have been necessary to
run a second

22 threshold, say, in 1993?
23 A Oh, yeah. Even if you put in a second
24 microprocessor, the cost isn't all that
significant. The
25 microprocessors was, in those days, probably,
if memory
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33
1 serves me right, a five dollar item. These
days it's a
2 dollar fifty.
3 Q Is there a difference in the
difficulty of
4 setting and developing the -- setting the
threshold and
5 developing the algorithm to operate a 14
mile-an-hour
6 threshold from the difficulty of separately
developing and
7 setting a 20 mile-an-hour threshold for single
point
8 sensing system?
9 A I don't think there's a significant
difference.
10 I've obviously never done a production 20
miles an hour,
11 but the steps I would go through would be the

same steps.
12 I've done ten, twelve and fourteens and they
all required
13 the same amount of effort. You have to do all
the crashes
14 and you have to gather all the data and
generate the
15 algorithm. I don't think there's a
significant or even
16 real difference between the two.
17 Q Now, then the cost difference
between doing
18 a single point one threshold sensing system
and a single
19 point two threshold sensing system, say in
1995, for a
20 1995 model year production vehicle, would be
what?
21 A Well, let's sort of take a worst case
and put a
22 second -- put an extra five dollars worth of
23 microprocessor in there. The bigger cost
would be the
24 duplicate firing circuitry and you'd have a
larger housing
25 to accommodate mostly the duplicate firing
circuitry. You

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34
1 might require larger energy storage because
you've got two
2 squibs you've got to fire. It could cost you
fifteen,
3 twenty dollars, without accounting for the
inflator
4 differences, but just in the sensing and
providing the
5 power to the inflators it could cost you
fifteen or twenty
6 dollars to accomplish that. Probably less,
but that would
7 be a worst case.
8 Q Would that include the
duplicate -- well,
9 it wouldn't be duplicate, but the crash
testing and
10 algorithm development for the second stage?
11 A Because the crash testing tended to be
written off
12 against the production cost of the sensors,
since we're
13 raising the price to accommodate the
second sensors I
14 think that that's probably in the

allpark, that that
15 would be covered.
16 Q By the fifteen to twenty
dollars?
17 A Right. I mean we didn't charge
separately. We
18 didn't have a separate charge for the crash
testing. The
19 overall program was done and quoted, and we
basically
20 built the crash testing into the overall
price.
21 Q Okay. Now, by what model year
do you
22 believe that a car that would have otherwise
had a single
23 point sensing system in the '90s could have
had a single
24 point sensing with a second threshold, say a
20
25 mile-an-hour threshold on top of the normal 14
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35
1 mile-an-hour threshold?
2 A Well, it's a question of when someone
asked for it.
3 But had someone asked for it in time for '93

or '94, it
4 could have been done, but they would have had
to have
5 asked for it, you know, back in '88, '89 in
order to get
6 there for '93 or '94. That time would have
shortened
7 somewhat a little bit later because things
were a little
8 bit developmental once they had gotten the
first single
9 threshold systems out there and started
understanding what
10 they needed to do.
11 Q Which kind of brings us to
another point.
12 At Breed were there discussions about use of
two-stage
13 inflators to help reduce inflation-induced
injuries while
14 you worked there at Breed?
15 A Oh, yeah. We talked about multilevel,
two level,
16 and not necessarily just two equal levels,
many times over
17 the years. We were always looking at ways to
improve the

18 restraint system and reduce injuries and
improve the
19 occupant's experience in the crash, but no
demand for the
20 product really came up and we didn't develop
the product
21 because -- we talked about it but we never
developed it
22 because we didn't have any customers that
really wanted
23 it, so there was no point in spending any
serious money at
24 it.
25 Later in the '90s, as there was more
talk, we
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36
1 started actually looking at products and
developing
2 products for multilevel inflation. We got
very, very
3 serious. We had a team of people working on
multilevel
4 inflators, and at that point we were
starting to look at
5 inflators, as I recollect, that were one-

third and
6 two-thirds capacities so that you could
produce a bag of
7 one-third the fill or a bag of two-thirds
the fill or a
8 bag of three-thirds the fill, which actually
gives you
9 three level fill, and we also looked at the
possibility of
10 infinitely variable fill, if we could. The
temperature
11 compensated store gas inflator was something
that we
12 thought about for that. If we could adjust
the orifices,
13 we might be able to get infinite variation.
14 Q Was that with the allied hybrid
inflator?
15 A No, this was an invention developed at
Breed, which
16 was a pure gas inflator whose performance was
totally
17 independent of the ambient temperature. It
was developed
18 by Peter Materna and myself and a couple of
other people.
19 In fact, I forget what year it was. I think

it was '94.
20 I think we won an award as one of the best
products at the
21 time, but we never in fact commercialized that
product.
22 The industry really didn't at that time want
pure cold gas
23 inflators. They were doing hybrids.
24 Q Okay. Now, when we finished
talking about
25 a ball in tube a few minutes ago, I didn't go
on and ask
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37
1 you the question I wanted to, and that is
about if someone
2 had asked for a two-level sensing system using
ball in
3 tubes, if that was what had to be used in
1998 -- strike
4 that. I mean 1988. If an automobile
manufacturer had
5 asked for a two-level sensing system in
1988, how long
6 would it have taken your engineering
department to have
7 had a production-ready two-level sensing

system with the
8 low having a must-fire of fourteen and a
high of a
9 must-fire of, say, twenty?
10 A Okay. I would expect that within a
period of one
11 year we could have developed a prototype
sensor that would
12 have, at least in laboratory test, thruster
test and so
13 forth, met the requirements, and at that point
we would be
14 on the same time scale as any other newly
developed
15 sensor, which means that you're about three
years in those
16 days from production ready. So if you asked
me the
17 question in 1988, I should have a prototype in
1989, and I
18 think that's conservative; I think I could
have easily
19 done that, which puts you '92 production
ready for a '93
20 model year car.
21 Q And I'll just ask you kind of
a legal like

22 question here. Would you hold that opinion
to a
23 reasonable degree of engineering certainty?
24 A Yes.
25 Q How about -- I think you said
that an
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38
1 accelerometer-based sensing system, if asked
for in time,
2 could have been available by what model year?
3 A '93, '94 maybe, same as -- I mean they
were
4 starting to come out in '93, '94; and in
principle, if
5 you've done all the crash testing and, you
know, if you
6 were asked early enough, it's just twice the
crash testing
7 effort. The rest of it is relatively simple.
8 Q So by model year '94 or '95, do
you have
9 any doubt that --
10 A No. If you asked early enough, that
was perfectly
11 doable.
12 Q And do you hold that opinion to

a
13 reasonable degree of engineering certainty?
14 A Yes, I do.
15 Q Let's talk for a few minutes
about the
16 number of people that there are in the world
that have the
17 background and knowledge and experience in
developing
18 crash sensing systems that you have, and feel
free not to
19 feel a need to be humble at this point, but
tell us what
20 you know about how many people there are that
actually
21 have the knowledge that you have in developing
crash
22 sensing systems.
23 A It's really a small number of people.
I would say
24 at the time frame that we're talking about,
which is the
25 mid to late '90s or even before, but let's say
the mid
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39
1 '90s, there may have been a dozen or so

people. Certainly
2 less than fifty, much less than fifty; and
realistically,
3 I would say a much smaller number than that.
4 Q Now, back in the late '80s, I
take it it
5 was even a smaller community of sensing
engineers with
6 good experience in the area.
7 A Right. That number is probably a
dozen or less.
8 There was David Breed and one or two other
people at
9 Breed. There were a couple of people at
Delco. There
10 were one or two people at TRW. One of
them, at least,
11 came from Ford. A couple people at
division of TRW
12 Technar, which they acquired, and probably
a couple of
13 people I can't think of.
14 Q Did your company and you get
hired by some
15 of the others to provide them some training
in sensing?
16 A We offered a course, which I taught,

called Sensor
17 101. I taught this course to all Breed
engineers who were
18 involved in sensing and a number of Breed
engineers not
19 involved in sensing and Breed employees who
weren't even
20 technical so that they could understand what
we did.
21 Beyond that we gave the course,
although not for
22 hire -- we actually gave the course free of
charge -- to
23 Ford Motor Company, Delco Electronics,
Jaguar, Nissan,
24 Mazda, Fiat, and I've probably missed some,
but I gave the
25 course to at least that group of people.
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40
1 Q And the folks that you gave the
course to,
2 they would come to New Jersey?
3 A Frequently I would travel to their
site. We would
4 set up a conference room; or in the case of
Ford, at one

5
point we set up a hotel because it was going
to be a
6 larger gathering. But I gave the course in
Italy, I gave
7 the course in England, I gave the course in
Detroit and
8 Cocama, and Hiroshima at Nissan's
headquarters.
9 Q Some of the people that went
through your
10 course, and we talked about it a little this
morning so I
11 think I'm going to know -- there are a few
that I want to
12 see if my memory is right on, David Bauch from
Ford?
13 A Sure.
14 Q From Delco, Chris Caruso?
15 A Yes.
16 Q Byron Singer?
17 A I think Byron Singer sat in the course,
but I can't
18 be absolutely sure. Certainly Jon Kelley did,
and there
19 are some other names I don't recall at the
moment, but
20 there were several people at Delco.

21 Q Do you recall Bill Galles?
22 A I know Bill Galles. I don't remember
if Bill
23 Galles sat in the course when I gave it or
not. He might
24 very well have. Bill was certainly
associated with the
25 programs and knew about sensors, but whether
he sat in the
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41
1 course particularly I don't know. I think
Chris Caruso
2 did. I'll leave it at that at the moment. I
know there
3 are some others that I'm missing.
4 Q Was one of the people in the
late '80s that
5 had some good knowledge on automotive crash
sensing Gerald
6 Livers from Delco?
7 A Jerry Livers did a lot of the very
early work in
8 crash sensing and has been involved in crash
sensing and

9
air bags -- I'd like to say forever, but that
probably
10 dates him, but for a long time. He was out
of, as I
11 recollect, Santa Barbara.
12 Q Now, there were a couple of
companies
13 around in the early '90s that were making
accelerometers
14 that were designed specifically for
automotive crash
15 sensor use?
16 A Yes, there were.
17 Q What were those companies?
18 A Analog Devices of Massachusetts was
the most vocal
19 manufacturer of accelerometers for automotive
purposes.
20 They made a lot of press releases about having
inexpensive
21 crash sensors, as a matter of fact, when in
fact what they
22 had was an accelerometer. Beyond that, there
was a
23 Norwegian company called SenseNor, which made
a number of
24 accelerometers. Motorola eventually started

making
25 accelerometers for automotive purposes, and
there were
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42
1 some European and Japanese manufacturers as
well. So
2 there were a number of companies that were
starting to
3 make accelerometers for crash sensing
beginning in the
4 early to mid '90s; and of course, there
was a company
5 which was originally known as Vaisala
Technology,
6 Incorporated, became known as VTI, and was
purchased from
7 the Finnish, from the consortium of Finns and
United
8 Technologies, by Breed and became our inhouse
9 manufacturer of accelerometers.
10 Q And those accelerometers were
available in
11 the mid '90s at what kind of a price? And
I'm talking
12 about accelerometers that would be usable as

crush zone
13 sensors.
14 A Well, the crush zone design was not
offered, so it
15 becomes an estimate of what those prices are.
The
16 accelerometers were offered by Analog Devices,
for
17 example, originally at about five dollars or
so, and they
18 kept claiming that they had a two dollar
accelerometer. I
19 don't know if they ever got to two, but I know
that prices
20 for the accelerometers got into the two dollar
range. But
21 those were for SDM mounting, so you would have
to add
22 significant money, perhaps three to five
dollars to
23 package it for an engine compartment. So you
would have
24 an upper limit of ten and a lower limit of
five, so five
25 to ten dollars for a sensor that could
survive in the
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43
1 under hood environment.
2 Q And that would make them
somewhat
3 comparably priced with the ball in tube
around '95?
4 A That would actually be less than the
ball-in-tube
5 sensor.
6 Q Now, you know Russel
Brantman?
7 A Sure.
8 Q Where did you know Dr.
Brantman from?
9 A Dr. Brantman was at Breed Technologies
when I
10 arrived and stayed at Breed Technologies, I
think, until
11 about 1997. So I knew Russ at Breed for
about ten years.
12 We were both in Boonton until he moved to
Lakeland,
13 Florida, somewhere around '94 or '95. I'm not
sure
14 exactly when he moved to Lakeland.
15 Q And that was when Breed opened
up an office

16 down there?
17 A Well, it was a bit after Breed opened
the office.
18 They moved down in stages.
19 Q Now, could you describe for us
the relative
20 positions that you and Dr. Brantman held and
how they
21 related with one another, the positions, from
basically
22 1988 until 1997?
23 A Well, when I joined the company my
title was
24 vice-president and general manager, and Russ
was
25 vice-president, and I'm not sure if there were
any words
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44
1 after vice-president or if it was just vicepresident.
2 I eventually became vice-president of
engineering
3 after David Breed left and I took over the
engineering
4 function.
5 Russ' responsibilities were restraints

designs;
6 that is, the air bag design, the inflator gas
curves, with
7 particular attention on Jaguar. Russ devoted
almost, not
8 all, but almost all of his time to Jaguar
passenger and
9 driver's side applications in the early
years; from my
10 standpoint, in the early years, from, you
know, '87
11 through perhaps '92 or so. He then started
looking at
12 advanced inflator designs, multi-stage
inflating, and so
13 forth, after that, particularly when he
moved to Florida
14 and we had a full-fledged inflator operation
in Florida.
15 Q Now, was Dr. Brantman a sensor
engineer at
16 Breed?
17 A No. Dr. Brantman obviously got
involved with the
18 all mechanical sensor and whether the
triggering was too
19 early or too late, would offer opinions

perhaps as to how
20 to adjust the sensor and certainly knew, you
know, how the
21 sensors worked.
22 This not to say that Russ didn't
understand the
23 sensor or anything, but it wasn't his job to
calibrate
24 sensors, to run the model, to do the sensor
system. It
25 was his job to do the restraints, to choose
the size of
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45
1 the air bag, the gas fill, and fill rate, and
things of
2 that nature, and I did sensors.
3 Q He knew things you didn't know
about
4 inflators, I take it?
5 A I would assume so.
6 Q And you knew some things he
didn't know
7 about sensors?
8 A I believe so.
9 Q Have you read some of what Dr.
Brantman is

10 projected to say in a case Sherr versus
Chrysler,
11 DaimlerChrysler?
12 A Yes, I have.
13 Q Did you see any inaccuracies
in that
14 proposed testimony of Dr. Brantman?
15 A Well, as I recollect, one of the
things that Dr.
16 Brantman was claiming was that the trigger
of a second
17 threshold would be 40 or 80 milliseconds
into the crash,
18 or some huge number, and that's just not
true. That's
19 just a badly designed system. I don't know
where he gets
20 that idea, but there is no reason when the
crash is over,
21 particularly in the crush zone, in as little
as 15
22 milliseconds why you spend the next 65
milliseconds
23 closing the switch. That's just
incomprehensible.
24 Q You also, I think, saw
something about his

25 discussion about that a second stage would
have a risk of
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46
1 having the occupant's chest against the module
at the time
2 of firing?
3 A Right. And first of all, if you fired
80
4 milliseconds late, there might be something to
that.
5 However, even then I think he's wrong because
the first
6 stage would have fired the air bag, opened
the cover and
7 deployed the bag. So the occupant would have
had some
8 restraint from the first stage already, and
certainly the
9 bag is already out. So that even if the
second stage
10 fired at 80 milliseconds into the crash, which
as I said
11 is incomprehensible, you would be repumping
the bag which
12 is already seated on the occupant. You
wouldn't be

13 punching the occupant with an undeployed bag.
14 Now naturally, one would expect the
sensor to fire
15 a few milliseconds after the first stage, if
the system is
16 designed properly, and then you would have the
gentle
17 initial deployment followed by a stiffening of
the bag in
18 the second stage, and that's the whole purpose
of a dual
19 level system; and in fact, I believe dual
level systems
20 that are in production today would, in fact,
do that. And
21 I think, frankly, Russ was working on systems
that would
22 do that in the late '90s with the onethird/two-thirds
23 system.
24 Q I believe you also saw some
comments by Dr.
25 Brantman regarding the access of the ball-intube
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47

1
accelerometer being -- or it being turned off
its axis and
2 then becoming ineffective in crashes, such as
pole crashes
3 or angle barriers, making it unfeasible to use
a higher
4 threshold. Could you comment on that?
5 A That's just a badly designed system.
That problem
6 can occur in a badly designed system with any
threshold.
7 If you don't have a sensor that's able to
receive the
8 pulse, the crash pulse, without turning then
you can't do
9 a fourteen mile an hour threshold or a twelve
or a ten or
10 a sixteen or any other. You have to design
the system
11 such that the sensor is able to receive the
information
12 delivered by the structure, and that's just
proper sensor
13 design. Anything less is just improper
sensor design.
14 Q Did you also see some
discussion by Dr.

15 Brantman about a problem of setting a
higher threshold,
16 say 20 miles an hour, using a ball-in-tube
sensor would be
17 that you would have to make the tube so long
that it would
18 create too much of a delay in firing?
19 A Yes, I saw that. The factors in making
a higher
20 calibration involve, among other things,
increasing the
21 travel. That is by far the simplest thing
to do, just
22 increase the travel. The calibration is
approximately
23 linear with travel. Increasing the travel
will cause a
24 somewhat slower response, not 40 or 80
milliseconds, but
25 it will cause a somewhat slower response.
You could
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48
1 decrease the gap, although we made sensors
whose
2 calibrations pushed the limits of those
gaps, the

3
so-called F-175 sensor. You can decrease
the mass, and
4 with a combination of mass and travel I
believe that you
5 could come up with a sensor that could reach
the 20 mile
6 an hour range.
7 I don't think that a ball-in-tube
sensor as
8 configured without significant work on
contacts in
9 particular could be made for a 30 or 35
mile an hour
10 threshold. I think that's going to require
significant
11 work on the contacts.
12 Q Describe the reason that it
would require
13 work on the contacts.
14 A The mass on the ball would get to be
quite small
15 because you'd have to do some mass
adjustments; and
16 therefore, the force that the ball would press
against the
17 contacts to make a good electrical contact
would be

18 reduced by a significant factor from the
current
19 ball-in-tube sensors. So you'd have to have a
design with
20 the ball nestled more in the contacts rather
than just
21 impacting it and pushing it back, and that
would require
22 research and development and considerable
effort. In
23 principle, it's probably possible, but it
would require
24 considerable effort and testing.
25 MR. SHUMWAY: Let's go off the
record for a
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49
1 few minutes.
2 MR. WIELGUS: Going off camera.
The time
3 is approximately 12:45.
4
5 (At this point in the
proceedings a
6 recess is taken.)
7
8 MR. WIELGUS: We're back on

camera. The
9 time is approximately 12:54.
10
11 BY MR. SHUMWAY:
12 Q Okay. Another question: Is it
feasible to
13 develop a dual stage inflator; and in fact,
was it
14 feasible for, say, model year 1995 or '96
or '97?
15 A Sure. The simplest way to do it is
to use two
16 small inflators. We certainly looked at
using two
17 inflators, one of which was one-third
capacity, one of
18 which was two-thirds capacity, and that
would give you
19 three levels of inflation. You could also
use just two
20 fifty percent inflators to get two levels of
inflation and
21 just gang them together. It's relatively
straightforward.
22 Obviously you could put them together into a,
you know, a
23 single housing and get more complicated; but

for a very
24 fast solution, you could just take two small
inflators and
25 put them together. And we, in fact, did that
to
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50
1 demonstrate the technology in the mid '90s.
2 Q One other thing I forgot to go
into and I
3 will just do it briefly, but there is a
document put out
4 by the Jet Propulsion Laboratory in 1997 that
purports to
5 summarize the information they gathered from
speaking with
6 suppliers about the availability of smart air
bag
7 technology, including crash severity sensing.
Do you know
8 of any contact that was made with you or your
sensing
9 engineers as a part of that Jet
Propulsion Laboratory
10 study?
11 A They never spoke with me, and I
don't have any

12 knowledge of them speaking with any of
the engineers.
13 This doesn't preclude the fact that they may
have at some
14 point called, but I would rather doubt it.
It's possible,
15 but I doubt it.
16 Q One point that I found made in
that Jet
17 Propulsion Laboratory summary was some
commentary about
18 there being a lack of clear directive or
objectives given
19 to the suppliers of crash sensing systems
from the
20 automotive manufacturers. Could you comment
on your
21 knowledge about what directives and objectives
were given
22 to sensing suppliers by the automotive
companies?
23 A The automotive companies were looking
for generally
24 single level crash sensing. They were looking
for
25 decreasing cost. Obviously, cost in any
automotive

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51
1 product is a major driver. They wanted that
at no
2 degradation in reliability, and they would
provide a
3 library of crashes which they felt would be
representative
4 of real world events that we should meet.
They were also
5 interested to listen if we had any advanced
technology
6 that we'd like to talk about, but once we
disclosed
7 advanced technology they would then ponder
whether or not
8 this would provide them any competitive edge
or any other
9 edge that they felt was worth having, and most
times there
10 would be a significant delay until they felt
there was a
11 need to go to a next generation or a different
product.
12 Their industry is very competitive and
they do
13 what's necessary to stay equal to or ahead of

the
14 competition, but the directives were, "You
will meet these
15 crashes and you will meet these reliably for
the least
16 amount of money."
17 Q Was there ever, prior to 1995,
an
18 automobile manufacturer that came to Breed,
that you know
19 of, and asked specifically for crash sensing
to operate a
20 two-stage multilevel inflation system?
21 A No. If they asked for it, we would
have given it
22 to them, or at least we would have quoted it
and they
23 would have decided whether or not the cost was
worth doing
24 it.
25 Q When an automotive company
wanted some
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52
1 advanced technology from a supplier like
Breed, would they
2 talk with Breed about funding some of the R &

D cost for
3 that at times?
4 A Sometimes. Usually, however, they
preferred that
5 the supplier base do the inventing. See, if
they paid for
6 the R & D, then they of course would own the -
- would own
7 certain rights to the R & D. So both the
suppliers and
8 the auto companies generally prefer that the
supplier
9 develop it and then can sell it to anybody.
10 MR. SHUMWAY: Well, I thank you
very much
11 for all this information.
12 THE WITNESS: You're quite
welcome.
13 MR. WIELGUS: This concludes
the sworn
14 statement. The time is
approximately 12:59.
15
16 (At this point in the
proceedings a
17 recess is taken.)
18

19 MR. WIELGUS: We're back on
camera. The
20 time is approximately one o'clock.
21 BY MR. SHUMWAY:
22 Q Now, Geoff, you and I have only
known each
23 other a short time?
24 A That's correct.
25 Q And when we first had some
conversations it
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53
1 was a matter of a few weeks ago. Is that
correct?
2 A I would say less than three weeks ago,
perhaps
3 three weeks, something like that.
4 Q And we were talking about how
we could get
5 together quickly, correct?
6 A That's correct.
7 Q And something came up that
interfered with
8 my being able to spend any time with you,
correct?
9 A Right. I was told that my mother had
less than ten

10 days to live. My mother and father live in
Florida, so I
11 flew down to Florida to be by my mother's
side. As luck
12 would have it, she has rallied somewhat and is
well enough
13 for the moment for me to return, so I returned
Monday
14 night of this week, this being Friday, so it's
just four
15 days ago I flew back.
16 MR. SHUMWAY: Thank you very
much.
17 THE WITNESS: You're quite
welcome.
18 MR. WIELGUS: This concludes
the testimony.
19 The time is approximately 1:01.
20
21
22
23
24
25
54
1
2

3
C_E_R_T_I_F_I_C_A_T_I_O_N
_ _ _ _ _ _ _ _ _ _ _ _ _
4
5 I, DIANE FOND, License
Number XI00847,
6 a Certified Shorthand Reporter and
Notary Public of
7 the State of New Jersey, certify that
the foregoing
8 is a true and accurate transcript of
the sworn
9 statement of GEOFFREY L. MAHON, who was
first duly
10 sworn by me at the place and on the
date
11 hereinbefore set forth.
12 I further certify that I am
neither
13 attorney nor counsel for, nor related
to or
14 employed by, any of the parties to the
action in
15 which this sworn statement was taken,
and further
16 that I am not a relative or employee of
any
17 attorney or counsel employed in this

case, nor am I
18 financially interested in the action.
19
20
21
22
_________________________________________________
A Notary Public of the State of New
Jersey
23
24
25