5/18/09 court docs... from Toyota's "expert witness"..
notice his compensation rate (bolded).. heck, I only get paid 1/2 that for manipulating this message board, lol..
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
____________________________________
)
SOLOMON TECHNOLOGIES, INC., )
)
Plaintiff, )
v. ) CASE NO. 8:05-cv-01702-JDW-MAP
)
TOYOTA MOTOR CORPORATION, )
TOYOTA MOTOR SALES, U.S.A., INC., )
TOYOTA MOTOR ENGINEERING AND )
MANUFACTURING NORTH AMERICA, )
INC., and TOYOTA MOTOR )
MANUFACTURING KENTUCKY, INC., )
)
Defendants. )
____________________________________)
DECLARATION OF EDWARD M. CAULFIELD, Ph.D., P.E. IN SUPPORT OF
TECHNOLOGY TUTORIAL
1. I am the president and Chief Technical Officer of Packer Engineering, Inc.
("Packer Engineering") a multi-disciplinary engineering consulting and technical services
company with locations in Naperville, Illinois; Cincinnati, Ohio; Washington D.C.; and Ann
Arbor, Michigan. Packer Engineering offers a wide range of engineering services, including
extensive technical support in the automotive field. I have a Ph.D. in Theoretical and Applied
Mechanics, a M.S. in Theoretical and Applied Mechanics, and a B.S. in Mechanical Engineering
in Machine Design. I am a member of the Society of Automotive Engineers, American Society
of Testing and Materials, American Society of Mechanical Engineers, Society for Experimental
Mechanics, American Association for Automotive Medicine, and Illinois Society of Professional
Engineers.
2. My personal practice involves the application of mechanical engineering
principles to design review and evaluation, failure analysis, accident investigation and
Case 8:05-cv-01702-JDW-MAP Document 66 Filed 05/18/2009 Page 1 of 2
2
reconstruction, and testing. Since joining Packer Engineering in 1979, I have consulted for a
wide range of industrial clients, including automotive vehicle makers, among others.
3. Prior to joining Packer Engineering, I was an Assistant Professor in the
Department of Mechanical Engineering at the University of Illinois, where I taught courses in
dynamics, vibration, material science, and design of machinery. Through my educational
background and duties at Packer Engineering, Inc., I have developed a thorough understanding
of vehicles and mechanical transmission systems. I have extensive background and experience
in automotive design, testing, and analysis. This includes engine, transmission and drive train
analysis for many types of ground vehicles, watercraft, and aviation equipment.
4. A copy of my curriculum vitae, listing my qualifications to be an expert in this
field, is attached as Exhibit 1.
5. For my services in this action, Packer Engineering is being compensated for my
time at an hourly rate of $525.00 plus expenses. No part of this compensation is contingent upon
the outcome of this case or any issue in it.
6. I have participated in the preparation of the technology tutorial prepared on behalf
of Toyota Motor Corporation, Toyota Motor Sales, U.S.A., Inc., Toyota Motor Engineering and
Manufacturing North America, Inc., and Toyota Motor Manufacturing Kentucky, Inc. This
tutorial represents a fair and accurate representation of the technology at issue in this case
Respectfully submitted,
Edward M. Caulfield, Ph.D., P.E.
Case 8:05-cv-01702-JDW-MAP Document 66 Filed 05/18/2009 Page 2 of 2
Exhibit 1
Case 8:05-cv-01702-JDW-MAP Document 66-2 Filed 05/18/2009 Page 1 of 6
Edward M. Caulfield, Ph.D., P.E.
President and Chief Technical Officer
EDUCATION - DEGREES
Ph.D. Theoretical and Applied Mechanics, University of Ilinois at Urbana-Champaign, 1979
M. S. Theoretical and Applied Mechanics, University of Ilinois at Urbana-Champaign, 1974
B.S. Mechanical Engineering, University of Ilinois at Urbana-Champaign, 1972
HONORS
1976 - Award for excellence II undergraduate teaching, University of Ilinois at Urbana-
Champaign ( campus-wide)
1975 - J. O. Smith award for excellence in undergraduate teaching, Departent of Theoretical and
Applied Mechanics, University of Ilinois at Urbana-Champaign.
2000 - First TAM Distinguished Alumni Award for technical accomplishments in Theoretical and
Applied Mechanics, and serving in a professional and technical capacity that reflects honor on the
departent and University, Departent of Theoretical and Applied Mechanics, University of
Ilinois at Urbana-Champaign.
SOCIETIES
Sigma Xi, ASME, ASTM, ISPE, NSPE, SAE, AAAM, HFES
REGISTRATION
Registered Professional Engineer in State of Ilinois
Registered Professional Engineer in State of Florida
ACADEMIC AND TEACHING EXPERIENCE
1978-1979 University of Ilinois at Urbana-Champaign, Department of Mechanical
Engineering - Assistant Professor-Machine Design
1972-1978 University of Ilinois at Urbana-Champaign, Departent of Theoretical and
Applied Mechanics - Graduate Research and Teaching Assistant
INDUSTRIAL EXPERIENCE
1998 - Present Packer Engineering, Inc.
Napervile, IL
President & Chief Technical Offcer
Page 1 of 5
Case 8:05-cv-01702-JDW-MAP Document 66-2 Filed 05/18/2009 Page 2 of 6
1995 - 1998
1990 -1995
1986 - 1990
1979 - 1985
1975 - 1978
1975 - 1978
1969 - 1972
Packer Engineering, Inc.
Napervile,IL
President
Packer Engineering, Inc.
Napervile,IL
Chief Operating Offcer
Executive Vice President
Packer Engineering Associates, Inc.
Napervile, IL
Vice President
Packer Engineering Associates, Inc.
Naperville,IL
Director of Mechanical Engineering
Strctural Dynamics Research Corporation (SDRC)
Cincinnati, OR
Consulting and seminar presentations
Fatigue, Fracture Mechanics, Failure Analysis & Prevention
Consultant to members of Ground Vehicle Industr
Fatigue, Fracture Mechanics, Failure Analysis, Dynamics of Machinery
Teletye Corporation
Skokie, IL
Cooperative Education
NON-PUBLISHED CORPORATE REPORTS AND INVESTIGATIVE STUDIES
Design
Machine design employing the multi-disciplined areas of ergonomics, materials and dynamic
stress analysis to obtain minimum risk configurations.
Accident Reconstruction
Analyzing numerous industral, traffc, aircraft and structural accidents employing the
principles of advanced dynamics and modem investigative engineering techniques.
Industral Machine Design
Evaluation of restraint systems and operator stations for industral equipment from the
biomechanical and ergonomic standpoints employing anthropometric test devices (ATD).
Intellectual Property
Evaluation of numerous components, apparatus or machines for infrngement or noninfringement
of various patents.
Page 2 of 5
Case 8:05-cv-01702-JDW-MAP Document 66-2 Filed 05/18/2009 Page 3 of 6
Turbine/Generator Rotor Reliability Analysis
Probabilistic fracture mechanics, computerized finite element methods, empirical temperature
data and practical experience incorporated to provide a criterion from which major utility
companies may engage in an appropriate run-retire decision making process.
Fatigue Analysis
In-field strain histograms, material properties and simulated tests incorporated to determine
the fatigue life of strctural components. Suggestive alternative designs were presented to
provide longer fatigue life in tyical fatigue service applications.
Fracture Analysis
Determine cause of structural component fracture in the following disciplines: fatigue,
brittle fracture, strctural overload, corrosion, creep, etc.
Strctural Analysis
Evaluate through analytical and experimental techniques the adequacy of vanous
mechanical configurations designed for static load carring capacity.
Material Properties
Evaluation of metallic, polymer, and ceramic material parameters such as modulus,
hardness, fracture toughness, crack growth rate, strain-life curves for fatigue, creep
properties, tre/engineering stress strain curves for material selection purposes in
commercial machine design and sporting goods applications.
PUBLICATIONS
"TURBINE ROTOR RELIABILITY: A PROBABILITY MODEL FOR BRITTLE
FRACTURE"
Authors: E. M. Caulfield, M.T. Cronin, W. B. Fairley, N.E. Rallis
Published by Society for Risk Analysis, Proceedings 1983, Annual Meeting 1983.
"AN APPROACH TO RELIABILITY ANALYSIS OF CRACKED CONTINOUS
DIGESTERS"
Authors: E. M. Caulfield, C. R. Morin, J. E. Slater
Published by NACE (National Association of Corrosion Engineers), Houston,
TX, March 1982.
"ROTOR RELIABILITY ASSESSMENT IN THE ELECTRIC POWER INDUSTRY"
Authors: E. M. Caulfield, M. T. Cronin
Published by Edison Electric Institute (The Association of Electrc Companies) at
9th Annual Engineering Conference on Reliability, Hershey, PA, June 1982.
Page 3 of 5
Case 8:05-cv-01702-JDW-MAP Document 66-2 Filed 05/18/2009 Page 4 of 6
"AN INESTIGATION OF STRESS-DEPENDENT; TEMPERATUR-DEPENDENT;
AND TIME-DEPENDENT STRAINS IN RANDOMLY ORIENTED FIBER
REINFORCED COMPOSITES"
Author: E. M. Caulfield
Published by ASTM (American Society for Testing and Materials) Philadelphia,
PA, 1982, Chapter - Short Fiber Reinforced Composite Materials, ASTM STP
772.
"AN INVESTIGATION OF STRESS, TEMPERATUR, AND TIME DEPENDENT
STRAINS IN A RANDOMLY ORIENTED FIBER REINFORCED COMPOSITE WITH
SPECIAL EMPHASIS GIVEN TO THERMAL STRESS SITUATION"
Author: E. M. Caulfield
Published by University of IL, Urbana, IL, T &AM Report No. 432, December
1978.
"FUNDAMENTALS OF MODERN FATIGUE ANALYSIS"
Authors: D. F. Socie, M.R. Mitchell, E.M. Caulfield
Published by University of IL, Urbana, IL, FCP Report No. 26, April 1977,
Revised December 1979.
"FRACTURE MECHANICS PARAMETERS OF A-27 CAST STEEL"
Author: E. M. Caulfield
Published by University ofIL, Urbana, IL, FCP Report No. 28, December 1977.
SEMINARS AND PRESENTATIONS
"Productivity in Modem Heat Treating Practices," Northern Ilinois Heat Treaters
Association, Rockford, IL, April 1980.
"Modem Fatigue Analysis," ASM Chicago-Western Chapter, April 1980.
"Technical Aspects of Modem Failure Analysis," Westec Conference, Los Angeles, CA,
March 1980.
"Temperature, Stress and Time Dependent Strains in Fiber Reinforced Polymers," ASTM
Conference, Minneapolis, MN, March 1980.
"Modem Fatigue Analysis," National Water Lift, Kalamazoo, MI, March 1979.
"Thermal Stress Computations for Materials with Highly Varying Modulii over
Temperature," Stellite Corporation, Division of Cabot. Kokomo, IN, December 1978.
"Fracture Toughness Properties of A-27 Cast Stee,l University of Ilinois, November
1978.
"Fundamentals of Modem Fatigue Analysis", Structural Dynamics Research Corporation,
Cincinnati, OH, January 1977; Cincinnati, OH, June 1977; Chicago, IL, December 1977;
Cincinnati, OH, June 1978.
Page 4 of 5
Case 8:05-cv-01702-JDW-MAP Document 66-2 Filed 05/18/2009 Page 5 of 6
"Fundamentals of Modem Fatigue Analysis," University of Ilinois, January 1977; June
1977; January 1978; June 1978.
"Modem Fatigue Analysis," General Motors Proving Ground, Milford, MI, August 1977.
"Refresher Course for 'Engineer in Training' in State of Ilinois," University of Ilinois,
Spring, Fall, 1973, 1974, 1975, 1977. Sponsored by A.S. C. E. Student Chapter.
"Strain Components in Glass Fiber Reinforced Composites," University of Ilinois,
September 1976.
"Theory and Applications of Fracture Mechanics," Marion Power Shovel Company,
Marion, OH, June 1975.
"Fracture Mechanics Parameters of A-27 Cast Steel," Clark Equipment Company, Niles,
MI, June 1975.
"Introduction to Fracture Mechanics," Rexnord Corporation, Milwaukee, WI, June 1975.
Page 5 of 5
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