1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:00:00

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF OHIO

WESTERN DIVISION

- - -

UNITED STATES OF AMERICA,

Plaintiff,

vs.

YANJUN XU, also known as XU

YANJUN, also known as QU HUI,

also known as ZHANG HUI,

Defendant.

:

:

:

:

:

:

:

:

:

:

CASE NO. 1:18-cr-0043

TRIAL EXCERPT

28th of OCTOBER, 2021

2:32 P.M.

- - -

TRANSCRIPT OF PROCEEDINGS

BEFORE THE HONORABLE TIMOTHY S. BLACK, JUDGE

- - -

APPEARANCES:

For the Plaintiff:

Timothy S. Mangan, Esq.

Emily N. Glatfelter, Esq.

Assistant United States Attorneys

221 East Fourth Street, Suite 400

Cincinnati, Ohio 45202

and

Matthew John McKenzie, Esq.

United States Department of Justice

National Security Division

950 Pennsylvania Avenue NW

Washington, D.C. 20530

and

Jacqueline K. Prim

Special Assistant, Paralegal

United States Department of Justice

National Security Division

950 Pennsylvania Avenue NW

Washington, D.C. 20530

For the Defendant:

Ralph William Kohnen, Esq.

Jeanne Marie Cors, Esq.

Sanna-Rae Taylor, Esq.

Taft Stettinius and Hollister

425 East Walnut Street, Suite 1800

Cincinnati, Ohio 45202

and

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 1 of 68 PAGEID #: 2299
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

2

Robert K. McBride, Esq.

Amanda Johnson, Esq.

Taft Stettinius and Hollister

50 East RiverCenter Boulevard

Suite 850

Covington, Kentucky 41011

and

Florian Miedel, Esq.

Miedel & Mysliwiec, LLP

80 Broad Street, Suite 1900

New York, New York 10004

Also present: Mae Harmon, Interpreter

Robin Murphy, Interpreter

Yanjun Xu, Defendant

Law Clerk: Cristina V. Frankian, Esq.

Courtroom Deputy: Bill Miller

Stenographer: Mary Schweinhagen, RPR, RMR, RDR, CRR

United States District Court

200 West Second Street, Room 910

Dayton, Ohio 45402

Proceedings reported by mechanical stenography,

transcript produced by computer.

*** *** *** ***

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 2 of 68 PAGEID #: 2300
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

3

INDEX OF WITNESSES

THURSDAY, OCTOBER 28, 2021

DIRECT CROSS REDIRECT RECROSS

PLAINTIFF'S WITNESSES

NICK KRAY 5 51

* * * * *

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 3 of 68 PAGEID #: 2301
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:32:21

02:32:22

02:32:25

02:32:26

02:32:27

02:32:29

02:32:32

02:32:38

02:32:42

02:32:44

02:32:47

02:32:50

02:32:51

02:32:52

02:32:56

02:33:00

02:33:01

02:33:01

02:33:04

02:33:04

02:33:06

02:33:09

02:33:15

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

4

P-R-O-C-E-E-D-I-N-G-S 1:55 P.M.

(Proceedings reported but not transcribed.)

THE COURT: The government's going to call another

witness at this time. Who does the government call,

Ms. Gladfelter?

MS. GLATFELTER: Thank you, Your Honor. We call

Nick Kray to the stand.

THE COURT: If that gentleman would be willing to

approach. I am going to put you up on the witness stand. And

if you'd be willing to pause where you are, I am going to ask

you to take the oath to tell the truth.

Our right hands are raised. Do you solemnly swear or

affirm that your testimony today will be the truth, subject to

the penalty of perjury?

THE WITNESS: I do.

THE COURT: Very well. Climb up and get you

acclimated.

THE WITNESS: Is it okay to take this off

(indicating)?

THE COURT: If you wish to take your mask off, you

may.

THE WITNESS: Thank you.

THE COURT: We'll need you up close to that fancy

federal microphone. Exhibits may come up on the screen or in

paper in front of you.

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 4 of 68 PAGEID #: 2302
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:33:16

02:33:18

02:33:20

02:33:21

02:33:23

02:33:23

02:33:25

02:33:27

02:33:27

02:33:33

02:33:36

02:33:36

02:33:38

02:33:41

02:33:43

02:33:44

02:33:46

02:33:50

02:33:52

02:33:56

02:34:02

02:34:07

02:34:09

02:34:13

02:34:15

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

5

The attorney for the government has a chance to begin

with questions of you.

Ms. Gladfelter.

MS. GLATFELTER: Thank you, Your Honor.

DIRECT EXAMINATION

BY MS. GLATFELTER:

Q. Mr. Kray, can you state and spell your name for the

record?

A. Yes. Nicholas Kray. N-I-C-K K-R-A-Y.

Q. And, Mr. Kray, are you currently employed?

A. Yes.

Q. Where?

A. General Electric Aircraft Engines.

Q. What does -- does it also go by GE Aviation?

A. Yes.

Q. And what does GE Aviation do?

A. We, well, design and manufacture commercial and

military aircraft engines.

Q. Who does GE Aviation sell its engines to?

A. So we're a global company. We sell engines basically

to any airline globally across the -- across the world.

Q. How long have you worked for GE Aviation?

A. Over 33 years.

Q. And what's your current position there?

A. I'm a chief consulting engineer for polymeric

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 5 of 68 PAGEID #: 2303
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:34:20

02:34:22

02:34:24

02:34:27

02:34:31

02:34:31

02:34:35

02:34:39

02:34:42

02:34:45

02:34:50

02:34:55

02:34:59

02:35:00

02:35:07

02:35:10

02:35:19

02:35:23

02:35:26

02:35:29

02:35:35

02:35:37

02:35:42

02:35:43

02:35:43

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

6

composites.

Q. I'm sorry. You said for what?

A. Polymeric composites.

Q. Polymeric composites?

A. Yes.

Q. Can you explain what you do, like, every day for your

position? What a day in the life of Nick Kray is?

A. Okay. So I work in the chief engineer's office, and

it's -- the chief engineer's office is essentially an

independent engineering division within aviation. We have

kind of three main goals. First one is safety. I mean, in

aviation safety is obviously number one for everything that

we work on.

Number two is to make sure that all of our designs are

evaluated with design rigor to make sure that when we

release either a new product to the field or we fix a field

product that's existing, we do as much rigor as possible to

make sure that that's a good fix or good product.

And number three is to actually mentor our younger

engineers in a technical track to make sure we build a

strong technical base for our next generation of engineers.

Q. And you said that you work in the area of polymeric

composites? Did I pronounce that right?

A. Yes.

Q. I want to come back in that area in a moment, but I want

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 6 of 68 PAGEID #: 2304
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:35:46

02:35:50

02:35:51

02:35:55

02:35:57

02:36:01

02:36:05

02:36:09

02:36:12

02:36:15

02:36:18

02:36:22

02:36:24

02:36:28

02:36:33

02:36:37

02:36:42

02:36:44

02:36:50

02:36:52

02:36:56

02:36:58

02:37:02

02:37:04

02:37:08

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

7

to understand more what a chief consultant engineer does. Can

you describe that to the jury?

A. Sure. So I get involved in all different type of

issues at Aviation, whether it's a new product introduction,

a new design, so to speak. We typically have to make sure

the design rigor and the way we approach the design is

adequate, that we result in a safe design; or if we have a

field problem, to make sure that we pull the right team

together to work on that field problem to make sure we

address it and fix it for our customers.

Q. How long have you been the chief consultant engineer?

A. It's been a little bit over a year now.

Q. And what did you do before that at GE Aviation?

A. Before that, I was in other technical positions of

consulting engineer and principal engineer, again in

polymeric composites. I worked on MPI design and sustaining

programs to support both of those.

Q. And your area of focus has been polymeric composites

through those different positions?

A. Polymeric composites has been my expertise for probably

25 years now.

Q. What kind of training and experience has prepared you for

your current position.

A. So certainly -- certainly school, you know, the

baseline college education. I have a master's and a

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 7 of 68 PAGEID #: 2305
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:37:10

02:37:16

02:37:17

02:37:21

02:37:25

02:37:28

02:37:33

02:37:38

02:37:41

02:37:44

02:37:47

02:37:50

02:37:50

02:37:51

02:37:52

02:37:54

02:37:56

02:38:00

02:38:04

02:38:05

02:38:13

02:38:14

02:38:17

02:38:18

02:38:21

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

8

Bachelor's of Science in mechanical engineering, both in the

University of Cincinnati.

We have in-house training. General Electric offers

their employees a very rigorous training program. It's on a

selected basis. You can take these courses at your -- at

your leisure. And then obviously trying to keep our

transfer of knowledge between senior engineers and younger

engineers, you always work within a team to make sure that

you, again, gain the knowledge from the more senior people

and kind of build upon that.

Q. Thank you. So you said you have a bachelor's degree?

A. Correct.

Q. And what is that in?

A. Mechanical engineering.

Q. And where did you get that from?

A. From the University of Cincinnati.

Q. Thank you. During your career at GE Aviation, you said

you focused on polymeric composites for how many years?

A. About 25.

Q. Can you explain to the jury what a composite is? When

you use that term, what you mean?

A. Okay. So composite is a very broad term. Think about

it as taking two different materials and mixing them

together, but when the resulting product of those materials

is still separate.

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 8 of 68 PAGEID #: 2306
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:38:23

02:38:27

02:38:35

02:38:38

02:38:41

02:38:45

02:38:48

02:38:49

02:38:50

02:38:50

02:38:52

02:38:53

02:38:56

02:39:00

02:39:04

02:39:07

02:39:07

02:39:10

02:39:16

02:39:20

02:39:26

02:39:32

02:39:33

02:39:36

02:39:39

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

9

So -- so an easiest way to say, for example, when you

put a cast on your arm. You mix fibers with a plaster of

paris. You mix it up and you wrap it on your broken arm or

leg, and that cures, and it cures as a hard substance. That

essentially is a composite in a very broad sense.

THE COURT: Can I interrupt and ask you to bring the

microphone closer?

THE WITNESS: Sure.

BY MS. GLATFELTER:

Q. So you were using the analogy of a cast?

A. Correct.

Q. Okay. I just want to make sure everyone could hear you.

If you could repeat that last answer for us. You were trying

to give us an analogy of what a composite is. If you could

repeat that while you are closer to the microphone so everyone

can hear you.

A. Yeah, sure. So composite is a substance that is

typically fibrous and a binder material. So as a cast, you

typically put a fibrous, a cloth material, you dip it in

plaster of paris, wrap it on your arm or a leg, and then it

cures or hardens, and the resulting structure is essentially

a composite.

Q. Now, is there a particular area that you have been

involved in during your career, a certain application of those

composites at GE Aviation?

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 9 of 68 PAGEID #: 2307
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:39:40

02:39:44

02:39:47

02:39:54

02:39:59

02:40:02

02:40:06

02:40:08

02:40:12

02:40:17

02:40:20

02:40:21

02:40:26

02:40:29

02:40:29

02:40:31

02:40:37

02:40:40

02:40:46

02:40:51

02:40:51

02:40:52

02:40:53

02:40:55

02:40:58

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

10

A. Yes. My main involvement over the last 25 years has

been on composite fan blades and fan cases.

Q. What's the function of a fan blade and a fan encasement?

A. So a blade -- a blade in a triple fan engine

essentially pumps the air. That's the whole purpose of it.

And pumping of the air gives the aircraft thrust. So it's

to pump the air.

The containment case is to make sure that if we -- if

the blade releases inadvertently from the retaining

structure, it is still contained, does not hit the fuselage

of the aircraft.

MS. GLATFELTER: Okay. And if we can show the jury

and the witness Exhibit 78, which is already admitted into

evidence?

THE COURT: Yes, we can publish it.

MS. GLATFELTER: Thank you.

THE COURT: So could you move your binder to your

left, sir. Way over. Now, will you pull the microphone in

front of your mouth and speak to the jury and turn your head.

It's hard.

THE WITNESS: Okay.

THE COURT: You're doing fine.

Go ahead. Sorry.

MS. GLATFELTER: Thank you, Your Honor.

BY MS. GLATFELTER:

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 10 of 68 PAGEID #: 2308
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:40:59

02:41:03

02:41:06

02:41:11

02:41:12

02:41:14

02:41:14

02:41:15

02:41:17

02:41:19

02:41:20

02:41:23

02:41:28

02:41:29

02:41:36

02:41:36

02:41:39

02:41:43

02:41:46

02:41:50

02:41:52

02:41:56

02:41:58

02:42:03

02:42:06

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

11

Q. All right. Does this graphically or illustrate the

concepts you were mentioning before about the propulsion of

the fan blades and the function of the fan blades and

encasement?

A. Okay. You want me to go through this --

Q. Yes.

A. -- figure here.

Q. Will this help you explain?

A. Yes, certainly it will help. I think it will help the

jury understand as well.

Q. And I think if you touch your screen, I think we can --

you can point to different parts as you're speaking. There

you go.

A. Okay. So to give a little bit of Jet Engine 101 so

everybody can understand it.

So when you look at an aircraft, you obviously have the

aircraft, but the engines are what typically sit underneath

the wing. And typically they look like a couple big tubes,

right? I mean, all you see are the white tube coverings on

that jet engine.

If you took that cell covering off, you would see a

structure that's similar to this, all right? This is the

carcass of a jet engine. It's a cut-away view, so you can

see some of the internals in a jet engine.

The jet engine's made up of a couple of different

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 11 of 68 PAGEID #: 2309
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:42:09

02:42:15

02:42:18

02:42:22

02:42:25

02:42:27

02:42:31

02:42:35

02:42:37

02:42:38

02:42:41

02:42:46

02:42:49

02:42:53

02:42:57

02:43:02

02:43:06

02:43:09

02:43:13

02:43:17

02:43:20

02:43:24

02:43:31

02:43:34

02:43:38

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

12

modules here. The fan module, which is this guy right here

(indicating), is the main pumping for air. And the big

purpose for that is to get as much air through the --

through the engine as possible. As it pumps air, it pushes

the aircraft forward.

The thing that makes the aircraft fly is forward

velocity from the engine. The wings make it lift. And

that's how you get flight. Okay? So the engine's doing all

the pushing.

So the fan module is up here (indicating). Then you

have a compressor module here (indicating) which compresses

more air, so the air kind of comes into the engine. We

compress it very, very tightly, okay. Pressure ratio gets

very compact. Right here (indicating) we add fuel into that

compressed air. The fuel lights off, expands the air even

more, and it comes out the back of the engine, okay.

Now, a couple things happen. When it expands, it goes

through the turbine blades here (indicating). The turbine

blades are hooked to the compressor blades so they spin at

the same time. So I'm feeding energy to continue my

pumping. So I add fuel and I pump it, and I continue to

pump fuel, and then as it exits the aircraft it goes through

the pumper feed back here (indicating). And it drives the

fan blades and pumps the majority of the air to get the

thrust to the engine. That whole system basically makes as

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 12 of 68 PAGEID #: 2310
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:43:41

02:43:43

02:43:46

02:43:47

02:43:48

02:43:50

02:43:51

02:43:51

02:43:54

02:44:00

02:44:04

02:44:06

02:44:08

02:44:10

02:44:11

02:44:18

02:44:22

02:44:27

02:44:34

02:44:37

02:44:43

02:44:48

02:44:52

02:44:54

02:44:58

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

13

much forward thrust on the aircraft as possible.

Q. Mr. Kray, we also -- or you mentioned before the fan

encasement system?

A. Um-hmm.

Q. Do you see that on this illustration?

A. Yes.

Q. Okay.

A. The containment system is here (indicating), crosssection view. It goes all the way around the fan blades.

The cut-away view, you can't obviously see all of it, but it

encompasses the fan blades.

Q. All right. And what are -- if the fans help propel and

push the air to the compressor, what's the function of the

encasement system?

A. So one of the -- one of the requirements from the

Federal Aviation Administration for safety, again, is to

design a system such that if one of these blades breaks,

okay, and releases from the spinning, this holds it. It has

to be contained within this containment structure so it

doesn't hit the aircraft and obviously damage passengers.

It doesn't happen that often. Fan blade releases do

very seldom happen. We have had a case -- and it's been in

the newspaper just, I guess it was in February, of one of

our competitors that lost a fan blade, did a lot of damage.

The inlet ended up on the ground and in somebody's front

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 13 of 68 PAGEID #: 2311
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:45:01

02:45:02

02:45:05

02:45:06

02:45:12

02:45:16

02:45:19

02:45:22

02:45:26

02:45:29

02:45:32

02:45:35

02:45:38

02:45:41

02:45:41

02:45:42

02:45:50

02:45:54

02:45:58

02:46:02

02:46:05

02:46:08

02:46:11

02:46:17

02:46:24

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

14

yard in Texas.

So it does happen. We have to design to make it as

safe as possible.

Q. And in order to have an engine certified, do you have to

test the capability of your fan encasement?

A. Yes. The Federal Aviation Administration requires a

full engine blade-out test for certification. We have to

take a complete engine, intentionally release a fan blade,

and show containment in a safely -- a safe shutdown of that

engine if that indeed happens.

Q. Now, have you been involved in the development of GE's

fan blade and containment system over the course of your

career?

A. Yes.

Q. And in what roles?

A. So my first encounter with composites, polymeric

composites, was on the GE90-115B fan blade design. I was on

the design team for that. And that's -- our GE90 engine

goes on the 777 aircraft. That was a new product

introduction. It was a brand new design. I saw that

through design and certification, which included the

testing, including fan blade-out.

Then I was a team lead for our GEnx engine family. At

GEnx, we have a 1B GEnx engine, which goes on a 787

aircraft; and we have a GEnx-2B family, very similar, which

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 14 of 68 PAGEID #: 2312
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:46:28

02:46:31

02:46:35

02:46:39

02:46:44

02:46:49

02:46:50

02:46:54

02:47:00

02:47:05

02:47:09

02:47:09

02:47:13

02:47:17

02:47:17

02:47:20

02:47:20

02:47:24

02:47:25

02:47:36

02:47:42

02:47:46

02:47:51

02:47:57

02:47:59

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

15

goes on the 747-800 aircraft.

And then just recently, as a consulting engineer or

chief consulting engineer, of involvement on our GE9X

engine, which is our latest offering on a 777X, which is yet

to be certified by Boeing. So it's a certified engine but

not a certified aircraft yet.

Q. And what part of the engine have you worked on?

A. Typically the blades and the casement the majority of

the time. Obviously, we have other composite sundry parts

in the engine, but the majority of it has been the cases and

the blades.

Q. And have you been involved in the design process for

using a composite material for GE fan blades?

A. Yes.

Q. And GE containment systems?

A. Yes.

Q. Okay. When did GE start using composite material for its

fan blades?

A. Our first fan blade design was started probably 1989,

maybe early '90. And that was -- it was certainly developed

before that as far as a subcomponent testing, et cetera, but

the final product was certified in 1995 on our GE94B, which

was the first engine that we put on a 777 before the 115B.

Q. And that engine had composite fan blades?

A. Correct.

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 15 of 68 PAGEID #: 2313
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:47:59

02:48:05

02:48:06

02:48:11

02:48:16

02:48:21

02:48:25

02:48:28

02:48:30

02:48:35

02:48:39

02:48:45

02:48:48

02:48:52

02:48:56

02:49:01

02:49:04

02:49:08

02:49:11

02:49:14

02:49:20

02:49:25

02:49:28

02:49:33

02:49:36

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

16

Q. Does GE Aviation have particular expertise in this area,

composite fan blades?

A. I think we're probably the world leader in composite

fan blades. Actually, nobody else has composite fan blades

certified in production other than General Electric.

Q. Is GE Aviation the only company in the world that has the

combination of the composite fan blade and containment system?

A. That is correct.

Q. Does GE derive a competitive advantage from using the

composite fan blade with the composite encasement system?

A. Certainly. It is one of our, I would say, biggest

advantages in the commercial airspace, is that combination.

Q. Why -- what is unique about being able to use a composite

material in a fan blade? How is that advantageous?

A. Okay, so to give a little bit of background. So

typically aircraft engines up until our introduction of

composites had metal blades. And the material of choice has

typically been titanium. That's been the industry standard

ever since, you know, the 1940s.

The problem with that is these engines run at very high

RPM. It spins very fast. And imagine yourself pulled in

onto a rock on a rope and spinning it around, okay. And you

got to hold onto that rope pretty, pretty hard, right? If I

put a bigger rock on that rope, it's going to get even

harder to -- you spin at the same RPM, it's going to get

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 16 of 68 PAGEID #: 2314
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:49:40

02:49:40

02:49:44

02:49:51

02:49:56

02:49:58

02:50:01

02:50:02

02:50:06

02:50:08

02:50:12

02:50:15

02:50:17

02:50:22

02:50:26

02:50:30

02:50:34

02:50:38

02:50:40

02:50:43

02:50:46

02:50:49

02:50:51

02:50:54

02:50:55

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

17

even harder to hold; am I right?

When you get to the size of these engines, which are

very large -- our GEnx9 -- our GE9X is, you know, 13 feet in

diameter. So the blades are very, very large. To hold onto

those would be almost impossible -- well, it would be

impossible if they were metallic. So we have to look at

lighter alternatives.

Composite material is about a third of the density of

titanium. All right. So I'd certainly have an advantage if

I can make it a lighter blade, still pump the air and get

the same performance, and yet be able to hold onto that

blade as it spins very fast.

Now, our competitors have gone to hollow titanium as an

alternate. All right. Hollow titanium has a lot of

disadvantages in that it has a lot of stress risers internal

to the blade because it's got hollow cavities. And when you

machine out something with very tight radiuses, you get very

high stress concentrations.

Our composite blades don't have that. They are

monolithic. They are 100 percent composite through. And

they are, again, a third of the density. So we have that

advantage, from a design perspective.

Q. Let me ask you a few questions about that. So you

mentioned stress risers?

A. Yes.

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 17 of 68 PAGEID #: 2315
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:50:55

02:51:00

02:51:02

02:51:06

02:51:08

02:51:11

02:51:13

02:51:19

02:51:24

02:51:27

02:51:31

02:51:34

02:51:37

02:51:40

02:51:42

02:51:45

02:51:48

02:51:52

02:51:55

02:51:57

02:52:01

02:52:06

02:52:09

02:52:10

02:52:14

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

18

Q. Do I have that term right? What did you mean by that?

A. So I guess I'll go back to the recent example I talked

about earlier. One of our competitors had a fan blade

failure in February. I think it was February of this year.

That resulted from stress concentration internal in the

blade because it was a hollow metallic blade.

The stress concentrations basically have a high stress

in a certain area of the blade. And as that stress either

works itself from an LCF perspective -- you know, think

about a paper clip. I bend a paper clip back and forth,

back and forth, eventually, it's going to break.

So what happens is when you have a stress

concentration, as I cycle that blade, on every flight it

takes off, it takes -- comes down. Every flight it gets

more and more cycles. Eventually, if I have a stress

concentration it will start to propagate a crack in that

local area, which can then lead to a blade separation.

Q. So when you talk about greater durability, that's what

you're talking to in terms of the composite fan blades?

A. Yes. Composites inherently have much better durability

than metallics. On a back-to-back basis, the fatigue

capability of composites is superior to any -- any

metallics.

Q. You mentioned before that they are lighter than hollow

titanium or metallics. What is the benefit of having a weight

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 18 of 68 PAGEID #: 2316
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:52:20

02:52:21

02:52:24

02:52:28

02:52:31

02:52:37

02:52:39

02:52:42

02:52:47

02:52:51

02:52:54

02:52:57

02:53:00

02:53:02

02:53:09

02:53:12

02:53:16

02:53:19

02:53:29

02:53:34

02:53:38

02:53:43

02:53:47

02:53:52

02:53:57

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

19

reduction for your engines?

A. So, again, you know, we build engines for our

customers. Our customers want a light -- as weightefficient design as possible. And we try to provide that.

Certainly safety first, but then give it a light design.

The more I can take weight out of the engine -- because

every time the aircraft takes off, that weight goes with the

engine, right? I lift it up each time. The lighter I can

make it means I can either put more passengers on the

aircraft or I can put more seats in the aircraft; I can

either go the same amount of seats, I can go farther

distance. I can fly from, you know, let's say the United

States to India, for example, versus having to stop in

Europe. So I can go farther if I have a lighter design.

Q. Thank you, Mr. Kray. You've been working on this

technology for a long time. How long has it taken GE Aviation

to develop the composite fan blade technology?

I'm sorry. Go ahead and take a drink, please.

A. A typical NPI introduction of a new material, like

composites -- and I'll go by our experience -- it took

between 10 to 15 years to develop the composite fan blade

for the GE -- first GE9 engine.

Q. And so how long is a cycle now? When you are developing

a new engine, based on your experience that you've gained from

these prior engines, how long is it taking?

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 19 of 68 PAGEID #: 2317
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:53:59

02:54:03

02:54:10

02:54:13

02:54:17

02:54:19

02:54:21

02:54:24

02:54:28

02:54:33

02:54:36

02:54:36

02:54:40

02:54:46

02:54:50

02:54:53

02:54:57

02:55:05

02:55:07

02:55:13

02:55:17

02:55:26

02:55:28

02:55:32

02:55:36

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

20

A. I would say we've taken it down from 10 to 15 years to

probably 6 to 10 years. Again, it's a learning curve,

right. So as you learn things from previous designs -- what

works, what doesn't work, design know-how, so to speak --

you can shorten that design cycle.

And certainly that's one of our goals, right, is to

make it as short as possible so we can get a product to our

customers faster, and a more reliable product.

Q. And you mentioned some specific models of GE engines over

time that use the composite blade technology. Can you go

through that list again?

A. Sure. So the first, first one was certified was the

GE94B. All right. And that was on the 777, the first 777

aircraft that was launched by Boeing. And that was in circa

1995-ish.

Okay. The next one after that was the GE90-115B, which

goes on the 777, extended ER. They call it the extended

range 777 which is basically a bigger 777.

And then the GEnx-1B -- which I believe this picture's

a GEnx-1B -- that goes on the 787 aircraft. I believe that

was certified in -- I think in 2005-ish. Don't quote me on

that, but it's around 2005.

And then the GEnx-1 -- 2B followed very closely

thereafter because we had a request from Boeing to the aging

747s. So we basically leveraged this GEnx-1B design to a

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 20 of 68 PAGEID #: 2318
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:55:43

02:55:45

02:55:47

02:55:49

02:55:52

02:55:56

02:56:03

02:56:05

02:56:08

02:56:10

02:56:15

02:56:17

02:56:18

02:56:18

02:56:19

02:56:19

02:56:26

02:56:30

02:56:34

02:56:37

02:56:40

02:56:43

02:56:48

02:56:51

02:56:53

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

21

GEnx-2B, a little bit different thrust, different air

pumping to match that airframe. That was certified a year

or two after the 1B.

And then just recently the 9X, which is our latest

offering, which is, again, a 13-foot diameter engine, which

is going to go on the 777X, which again is an even bigger

variant than the 777 from Boeing. But it, again, is not

certified yet, with Boeing, but the engine hasn't had all

the certification.

Q. Now, Mr. Kray, you mentioned several models of GE

engines. Are you familiar with the LEAP engines?

A. The LEAPs?

Q. Yes.

A. Yes, I am.

Q. What is that?

A. The LEAP engine is an engine from our CFM, CFM-I. It's

a partnership between GE and our revenue-sharing partner

Safran, from France.

Q. Okay. And what kind of -- what kind of aircraft is the

LEAP engine?

A. So the LEAP goes on -- there is basically three main

aircraft that the LEAP goes on. It goes on the 737 Max

aircraft. This is the one that was recently grounded,

right, for all the other issues. It wasn't the engine. But

the 737 Max. The 8320, it goes on that; and the COMAC,

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 21 of 68 PAGEID #: 2319
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:57:01

02:57:06

02:57:10

02:57:16

02:57:21

02:57:24

02:57:28

02:57:31

02:57:36

02:57:37

02:57:41

02:57:41

02:57:46

02:57:50

02:57:52

02:57:57

02:58:01

02:58:05

02:58:08

02:58:14

02:58:17

02:58:18

02:58:21

02:58:24

02:58:29

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

22

C919, I think it is.

Q. And the LEAP engine, does it have composite fan blades?

A. Yes, it does.

Q. Have you been involved in the -- in that project?

A. Yes. So the fan blade is actually owned by our

revenue-sharing partner, Safran, from France. However, we

were very instrumental in assisting them in getting them

that product certified, leveraging our learnings off of our

composite fan blades.

Q. And so what does GE bring to the table in that

partnership?

A. So certainly our expertise in design; our, obviously,

design understanding, the material property understanding;

our testing methods, which are sometimes unique for

composite blades versus a metallic blade; and then our

certification approach, which is somewhat unique sometimes

with composite versus metallic blades. And all that

interaction with how to approach the FAA on the best way to

satisfy their requirements for safety of that engine.

Q. Okay. And what does Safran bring to the table with that

particular engine?

A. So certainly Safran is -- again, they are also an

engine company in France. They make more engines than just

the CFM, our LEAPs. They make other military and commercial

engines. So certainly they have expertise in aerodynamics

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 22 of 68 PAGEID #: 2320
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:58:34

02:58:37

02:58:40

02:58:42

02:58:43

02:58:44

02:58:48

02:58:51

02:58:57

02:59:00

02:59:00

02:59:00

02:59:04

02:59:10

02:59:15

02:59:19

02:59:25

02:59:26

02:59:32

02:59:37

02:59:38

02:59:41

02:59:45

02:59:46

02:59:51

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

23

and just like GE would. They have their own suite of

engineering with respect to engine development.

Q. So both companies bring their own expertise --

A. Yes.

Q. -- to --

A. It's typically what we call our revenue-sharing

partnership, where we both come to the table equally, both

from a business perspective, from a monetary perspective,

but from a knowledge base to come up with a very viable

product.

Q. Okay.

A. CFM has been -- has been a good partnership since like

1980s with GE and Safran and has been very, very -- very,

very positive for both companies. We sell a lot of engines.

I think all 737s -- well, not all -- I would say the

majority of them have either CFM or Flash LEAP engines,

which are under the same partnership.

Q. Now, you said that GE and Safran have been in sort of a

business relationship for back -- back until the '90s or '80s,

did you say?

A. Probably since the '80s, I believe.

Q. Okay. And do they have a composite fan blade apart from

the LEAP engine?

A. No. LEAP is the only composite fan blade they have.

Q. Okay. And so even though you've been working in this

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 23 of 68 PAGEID #: 2321
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:59:54

02:59:57

02:59:58

03:00:05

03:00:11

03:00:15

03:00:19

03:00:27

03:00:30

03:00:34

03:00:37

03:00:38

03:00:46

03:00:48

03:00:52

03:00:58

03:01:01

03:01:02

03:01:09

03:01:11

03:01:15

03:01:18

03:01:19

03:01:22

03:01:23

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

24

joint venture, they haven't been able to develop their own

composite fan blade engine?

A. Well, it's kind of a shared -- it's a little bit of

both. Typically, we'd keep our, we keep all of our IP, our

intellectual property, separate, whether it's CFM-I or GE or

Safran, right. So there's -- there's a very fine line of

sharing technology and making an engine versus sharing

technology for the sake of sharing technology.

Q. All right. So for an example, does Safran have access to

GE Aviation design files about the composite fan blades used

on the GE9X?

A. No, they would not.

Q. Do you -- strike that. Because you have this

partnership -- because GE Aviation has this partnership with

Safran on the LEAP engine, do they have access to other

non-public information by GE, other things besides the LEAP

engine?

A. I would say nonpublic, probably yes. I mean, there are

a lot of things that we have to share to make an engine

work, you know, whether it's interfaces at critical joints.

We have to give loads that they can then design their

hardware with.

So, yeah, I would say they do have some non-public

information, certainly.

Q. Okay. But they don't have like the design files and the

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 24 of 68 PAGEID #: 2322
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:01:26

03:01:28

03:01:28

03:01:32

03:01:33

03:01:33

03:01:35

03:01:39

03:01:41

03:01:47

03:01:51

03:01:51

03:01:55

03:01:59

03:02:03

03:02:07

03:02:10

03:02:14

03:02:18

03:02:21

03:02:26

03:02:29

03:02:34

03:02:40

03:02:43

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

25

testing files and all of the --

A. No.

Q. -- files you built up over the last 20 to 30 --

A. No.

Q. -- years?

A. Not at all.

Q. Has developing these composite fan blades and containment

systems been expensive for GE Aviation?

A. Yeah. So let's talk about that a little bit. So as I

said, if it's a new product, it takes about 10 years to

develop a product.

And you think about it's kind of built like a learning

pyramid, okay? The very bottom is, is you start with the

material system composite, for example. And you do coupon

testing. You very simple coupon test, and you start to

characterize the material itself, you know: How strong is

it? When does it break? How does it break? How many times

can I bend back and forth, this paper clip, before it starts

to fatigue? That's a very basic coupon level.

Then I go up to a subcomponent level. I start to look

at different features, you know: Can I drill a hole in it?

Can I bond metal onto it? You know, how do I protect it

from sunlight, ultraviolet lightings, that type of thing.

Then I get into component testing. I make a blade. I

can test that blade very -- you know, by itself. I can test

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 25 of 68 PAGEID #: 2323
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:02:47

03:02:49

03:02:53

03:02:57

03:03:00

03:03:06

03:03:10

03:03:13

03:03:14

03:03:19

03:03:24

03:03:30

03:03:33

03:03:37

03:03:42

03:03:44

03:03:46

03:03:49

03:03:52

03:03:54

03:03:56

03:04:01

03:04:05

03:04:07

03:04:12

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

26

it either -- and I can shake it, you know, to put vibration

into it. I can throw birds at it. I can -- I can pull it

until it breaks. That's at the component level.

And then certainly as I start getting to, you know,

system-level evaluations, I look at disks and spinning it

and containment cases and how does it fracture, how does it

release. And then at the end, obviously, you have a toplevel engine test.

So typically that, that type pyramid, to develop that

type of pyramid is hundreds of millions of dollars.

Astronomical. I mean, a single-engine test for this type of

test, just to do a fan blade-out test, which is a very high

level on this pyramid, is probably $15 million. Because the

engine alone at the development stage is probably at least

$10 million. And when I do a fan blade-out test, I

essentially destroy that engine.

So that's the one test, and I have got a whole gamut of

tests I have to do to understand the material and certify

the material. So it's very, very expensive.

Q. How much did you say that one test is?

A. This test is probably at least $15 million. At least.

Q. Per test?

A. For one, for one engine test. Now, I talk about

subcomponent tests, you know, a single-blade test. Let's

back it down even -- down the pyramid even further, all

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 26 of 68 PAGEID #: 2324
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:04:12

03:04:16

03:04:19

03:04:24

03:04:26

03:04:29

03:04:33

03:04:36

03:04:41

03:04:44

03:04:47

03:04:49

03:04:53

03:04:54

03:04:58

03:05:01

03:05:01

03:05:05

03:05:09

03:05:13

03:05:13

03:05:18

03:05:21

03:05:24

03:05:29

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

27

right?

A single-blade test, if I want to, for example, shoot a

bird at it, which is -- we can talk about that more -- but I

can shoot a bird at it, and that single test is about a

quarter million dollars, about $250,000.

So -- and I don't just do one test, right. I have to

do a whole gamut of tests to understand what's my threshold.

You know, is this spot in the blade critical? Is this spot

critical? Is the back? Is the front? So that's -- you

know, you could see how it adds up very quickly.

Q. So I want to ask you about a few things you mentioned

there. I will ask about the bird test, but I want to get

back. I want to ask the other ones first.

You mentioned a fan blade-out test. Is that what you are

referring to as testing the engine to failure?

A. Yes.

Q. Can you please describe that more to the jury?

A. Sure. So can I erase this screen some how?

THE COURT: We can erase it.

THE WITNESS: Perfect. So imagine this is a

development engine here, all right? And I have to release the

blade there (indicating). That's a requirement from the FAA

to say, you have to demonstrate -- GE, you have to demonstrate

that if a fan blade fails there, that -- a couple things.

Number one, it's contained, right? It doesn't come out of the

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 27 of 68 PAGEID #: 2325
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:05:32

03:05:36

03:05:37

03:05:42

03:05:46

03:05:50

03:05:54

03:06:00

03:06:02

03:06:03

03:06:06

03:06:09

03:06:12

03:06:13

03:06:15

03:06:18

03:06:22

03:06:24

03:06:27

03:06:30

03:06:31

03:06:35

03:06:38

03:06:42

03:06:45

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

28

encasement, hit the aircraft, and go into the passengers,

number one.

Number two, the engine doesn't fall off of this mount

switch up here and this mount here (indicating). The loads,

the unbalance of the engine, if I release this big, heavy

blade, right, that spins at, you know, 3,000 RPM, as soon as I

lose one of those, there is a big imbalance in the engine and

it shakes violently. If you ever see one of these tests, I

mean, it shakes.

So all of the loads going into these structures here are

very, very high. We design for them, but you have to prove

that our design works. So we test for it. So that's the

second thing.

And the third thing is anything back in here (indicating)

can't start on fire. You can't have a fire in the aircraft

because -- or on the engine, right. So even if it holds on

the wing, if it's on fire, you know, and you are sitting in

the seat and you are looking out the window and see a fire,

you're not going to be very happy. So we have to make sure

there's not a fire.

So those three things, basically, that test damages,

completely damages the engine. It's no longer usable for any

other test. So that's -- again, a development engine, on this

size, is at least $15 million. At least.

BY MS. GLATFELTER:

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 28 of 68 PAGEID #: 2326
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:06:45

03:06:48

03:06:51

03:06:52

03:06:52

03:06:53

03:06:56

03:06:59

03:07:02

03:07:09

03:07:10

03:07:15

03:07:17

03:07:22

03:07:25

03:07:31

03:07:33

03:07:36

03:07:40

03:07:43

03:07:46

03:07:47

03:07:51

03:07:55

03:07:58

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

29

Q. So when you say fan blade-out or test to failure, you

mean you have to actually make that engine show how it

works --

A. Yes.

Q. -- when it fails?

A. Yes. You have to actually -- what we do on this line

down here, this guy down here (indicating), we intentionally

put explosives in there and we release it. Spin the engine

up to top speed, hit the explosives, it cuts the blade. The

blade releases. Has to be shown that it's contained in this

structure, right. And then all the subsequent loads and the

lack of fire have to be demonstrated.

Q. Okay. I'm sure the jury's interested in this because you

mentioned a bird test. So before we move on, could you just

tell us what you meant by a bird test?

A. Sure. So aircraft, you know, when we fly in the air,

right, one of the biggest threats for the fan module is,

this front end of the engine, is birds. It happens a lot.

Bird strikes happen on aircraft all the time.

In the Hudson River, right, took a bunch of birds to

make the engine stop.

So we have to design for bird strike. And one of the

things about bird strike is obviously this front profile,

the engine, is the first thing the bird's going to hit. So

the blades, we have to make sure the blades don't get

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 29 of 68 PAGEID #: 2327
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:08:01

03:08:07

03:08:13

03:08:18

03:08:21

03:08:23

03:08:26

03:08:30

03:08:32

03:08:37

03:08:40

03:08:44

03:08:48

03:08:52

03:08:57

03:09:00

03:09:01

03:09:05

03:09:09

03:09:13

03:09:15

03:09:19

03:09:22

03:09:25

03:09:31

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

30

damaged beyond what -- there is various criteria. The FAA

has, based on engine size, criteria for small birds up to

two and a half pounds, medium birds up to five and a half

pounds, and then very large birds up to eight pounds, a

Canadian geese type of bird. You have to show --

demonstrate for each one of those bird sizes that your

engine, again, is safe; whether it's going to keep producing

thrust for small birds -- in other words, if I take off and

I take a bird or two, I'll make sure I can keep pushing

thrust, right, so I can either turn around to the airport

and re-land and I don't have issue; or if it's a very large

bird, again, if it breaks a blade off somewhere, that

safe -- that engine is still -- contains the piece of blade

that's broken off and have safe shutdown. So I can still

operate on one engine if I have to and still make a safe

return to the airport.

So, yeah, birds -- and we have to demonstrate that we

have to actually fire birds into an engine to show that that

is indeed compliant with those requirements.

Q. That's an FAA requirement?

A. It is an FAA requirement. But, again, just like --

just like FBO -- we talked about FBO and the cost of doing

that -- you know, we don't -- from a business perspective,

we don't wait until last minute to do those type of tests.

There's a lot of engineering tests that are done before

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 30 of 68 PAGEID #: 2328
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:09:34

03:09:39

03:09:42

03:09:46

03:09:47

03:09:50

03:09:55

03:09:58

03:09:59

03:10:03

03:10:07

03:10:10

03:10:13

03:10:16

03:10:20

03:10:23

03:10:27

03:10:30

03:10:34

03:10:35

03:10:40

03:10:44

03:10:50

03:10:50

03:10:55

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

31

we do our certification test, right. So we do a lot of

ingestion on an engineering basis, shoot birds into the fan

to make sure that we're comfortable from a design

perspective that that design is adequate.

And then, certainly, the last test or the certification

test is witnessed by the FAA, and that is basically the --

you get a checkmark there and say, yeah, you passed that

test.

But, typically, these big tests, these big, expensive

tests, we don't -- we don't just do one test at the end. We

do a series of engineering tests to lead up to that

successful demonstration. We don't want to do it for the

first time in front of the FAA, because you don't want to

show the regulatory agencies that, you know, you are very

cavalier. It's not a proper design approach.

Q. Mr. Kray, has the cumulative knowledge gained during the

testing and analysis process over these cycles been important

to GE Aviation in developing its fan blades and containment

system technology?

A. Well, certainly. And I think the perfect example of

that is, as I said, the first composite blade, you know,

took probably 15 years to certify. Now that we're up that

learning curve, we are down to probably seven, just half

that. Or maybe a little bit less than that.

So we can leverage off of our current learnings that we

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 31 of 68 PAGEID #: 2329
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:11:00

03:11:04

03:11:07

03:11:12

03:11:16

03:11:18

03:11:22

03:11:26

03:11:28

03:11:33

03:11:38

03:11:43

03:11:46

03:11:50

03:11:54

03:11:57

03:12:01

03:12:05

03:12:09

03:12:13

03:12:16

03:12:18

03:12:21

03:12:24

03:12:27

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

32

document our design practices into our design study

summaries that, again, a new engineer can go in, access

those studies, and learn what worked and what didn't work so

you don't have to reinvent the wheel each time you come up

with a new design.

Q. The results of these composite fan blade testing, it

builds on one another, from cycle to cycle?

A. Yes, as much as we can certainly. Certainly, every

engine has its own thrust requirements. So the 9X has a

thrush requirement, let's say, of 115,000 pounds of thrust.

Where the GEnx might be 70,000 pounds of thrust. So

certainly the size of the engine, the RPM, is different for

every application to optimally match the engine to the

airframe. But certainly, the basic understanding of

leverage of that learning curve, yes.

In our design reviews, we typically pull up previous

designs, how we benchmark against those designs, and say,

yeah, you're within that learning curve. If you're not or

if you want to deviate from that learning curve, there is

certainly a lot more rigor that we would then put on that

design to make sure that, again, we have, number one,

safety, right, a safe product, first of all. And then,

second of all, is it feasible to do that or should you back

off your design maybe and get it maybe a little more

conservative.

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 32 of 68 PAGEID #: 2330
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:12:28

03:12:31

03:12:34

03:12:38

03:12:42

03:12:46

03:12:47

03:12:53

03:12:57

03:13:01

03:13:07

03:13:12

03:13:17

03:13:22

03:13:24

03:13:30

03:13:32

03:13:37

03:13:40

03:13:44

03:13:47

03:13:53

03:13:55

03:13:59

03:14:03

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

33

Q. And those design files that you were just mentioning,

does GE share their design files with its competitors?

A. No, not at all.

Q. And during these cycles, does GE develop information

about the composite fan blades and containment system that it

tries to keep secret?

A. Yes. A composite fan blade and containment system is

what we call our key technology. So it's an internal --

internal specification that we at GE Aviation put on. It's

one of our -- we consider it our competitive advantage

technologies. It is deemed a key technology, which we have

a key technology board, which is run by chief engineer's

office. And it looks at general technologies across the

engine -- certainly composite blades and cases is one of

those -- and deems, if it is considered key technology, it

puts an additional level of, I am going to call it, security

on that information such that it doesn't get disseminated.

Q. And would public information -- I'm sorry -- would public

disclosure of this information about composite fan blades and

composite containment systems that we just talked about, would

that disclosure be economically harmful to GE Aviation?

A. Certainly, certainly. First of all, it's our

composite -- it's our competitive advantage, right. So we

know the competitors are trying to get composite fan blades.

We know Rolls-Royce, for example, has tried this a couple of

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 33 of 68 PAGEID #: 2331
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:14:07

03:14:12

03:14:16

03:14:19

03:14:24

03:14:26

03:14:30

03:14:33

03:14:36

03:14:40

03:14:45

03:14:48

03:14:53

03:14:57

03:15:01

03:15:02

03:15:10

03:15:12

03:15:20

03:15:23

03:15:23

03:15:26

03:15:30

03:15:34

03:15:34

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

34

times. And I go back to probably 1980 was the first attempt

that Rolls-Royce did it. The second attempt was maybe five

or ten years afterward. And it almost bankrupt the company

because they had put a couple programs mainstream that they

were going to use composite blades, and they couldn't make

it work. So it was very difficult for them.

So certainly, it is our competitive advantage. It's

one of the things our customers like about the GE engines,

because, again, its durability. You know, its resistance to

fatigue. It doesn't come with all the stress risers that

have metal blades. It's something that our customers, the

airlines, love, is the composite blade.

MS. GLATFELTER: All right. I would like to show

the witness what's been admitted as Exhibit 69 and publish

this to the jury?

THE COURT: Yes, show everybody 69.

MS. GLATFELTER: Ms. Prim, if we'd pull up the last

page of that exhibit. And if you can enlarge it just a little

bit.

BY MS. GLATFELTER:

Q. Now, Mr. Kray, have you seen this document before?

A. Yeah.

Q. Have you seen this before your testimony today?

A. Yes.

Q. Okay. And you've had an opportunity to read it?

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 34 of 68 PAGEID #: 2332
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:15:35

03:15:36

03:15:46

03:15:49

03:15:55

03:15:59

03:16:04

03:16:05

03:16:09

03:16:11

03:16:15

03:16:19

03:16:22

03:16:26

03:16:28

03:16:30

03:16:33

03:16:37

03:16:38

03:16:41

03:16:43

03:16:47

03:16:50

03:16:54

03:16:57

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

35

A. Yes.

Q. Are there terms on this page that relate to either jet

engine composite fan blade or composite fan encasement?

A. Certainly. So I hope my pointer will work again. I've

got fan rotor blades made of composite materials, okay.

That certainly points to GE Aviation. We're the only ones

with it, right.

Prepreg. Let's talk a little bit about prepreg.

Prepreg is composite material. Composite material comes in

a couple different forms. Again, it's a fiber and a resin.

A prepreg is a combination of those that are basically like

a sheet of paper. It's got fibers and it's got resin in it,

but it's not cured yet. So prepreg is the composite

material itself.

So it's asking how many generations of prepreg. So

that's a good question. Okay, you know, as I said, this

pyramid of learning, the lower pyramid is when we look at

all the coupons.

And certainly there is a multitude of composite

materials out in the industry. It's which one is the right

one to use. And that bottom pyramid that you do a lot of

component testing on it -- coupon testing helps us sort out

which one is right and which one is wrong, and why is one

right and one wrong. You know, there's no free lunches,

right. So as soon as you find something optimal, it's going

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 35 of 68 PAGEID #: 2333
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:17:00

03:17:05

03:17:09

03:17:12

03:17:15

03:17:15

03:17:16

03:17:18

03:17:23

03:17:24

03:17:25

03:17:30

03:17:34

03:17:37

03:17:41

03:17:44

03:17:46

03:17:49

03:17:55

03:17:59

03:18:03

03:18:06

03:18:10

03:18:13

03:18:17

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

36

to have a down side to it. So it's all the pros and cons of

the different materials that can possibly be used in the jet

engine, okay.

Q. Do you see other terms that relate to composite fan

blades or --

A. Sure.

Q. -- fan blade containment systems?

A. Certainly. Fan blade, you know, fan casing here,

right. I mean, that, again, composite fan blades, composite

materials, right.

And, again, now that we are asking here for baseline

value is used in the design A or B. Again, what's your down

select. What's your criteria for down select. That's very

important to short-circuit all that development. We talked

about 10 to 15 years. Can I short-circuit that. Can I

learn, you know, from other people what's good and what's

bad. That certainly is big.

Software programs, you know, and virtual simulation,

that's one of our big things, right. I mean, we don't -- we

certainly test, but we also build mathematical models to

break those tests. And to build those mathematical models,

to build that correlation of which models work, which ones

don't work, how do I correlate to a test result using that

simulation. Very, very important to short-cycle that design

cycle, okay.

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 36 of 68 PAGEID #: 2334
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:18:18

03:18:22

03:18:25

03:18:30

03:18:34

03:18:37

03:18:41

03:18:44

03:18:45

03:18:48

03:18:52

03:18:56

03:19:00

03:19:04

03:19:07

03:19:12

03:19:15

03:19:16

03:19:18

03:19:23

03:19:27

03:19:29

03:19:32

03:19:38

03:19:43

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

37

3-D braided structure. Again, that's another form of

composite. That's one of our forms in our fan containment

cases. That certainly is pointing towards that.

And then, you know, plus or minus 30 degrees. Now you

are talking about specifics of construction. Again, fibers

and resin, right. You know, you wrap your -- you wrap your

cast around your arm, right, and if it's all one direction,

that's great.

But the key thing about composites is orientation of

fibers, right. So fiber -- fiber direction is very, very

strong. But transverse, the other direction, it's just

resin, right. So plaster of paris, I can break it, right.

So how I orient the fibers to optimize my load is kind

of critical in composites. The orientation of the fibers,

how you manufacture it, how you orientate the fibers to

maximize, again, my strength to make the lightest design.

That's key.

Q. Could discussion of the terms that you've highlighted

here, could discussion of these terms lead to discussion about

information that GE tries to keep secret about composite fan

blades and containment systems?

A. I would say that the discussions behind these would be,

yes, be considered to be proprietary, and we would not -- we

would not share that.

MS. GLATFELTER: If we could show the witness what's

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 37 of 68 PAGEID #: 2335
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:19:44

03:19:51

03:19:54

03:19:56

03:19:58

03:20:05

03:20:08

03:20:10

03:20:13

03:20:15

03:20:19

03:20:19

03:20:22

03:20:22

03:20:24

03:20:25

03:20:28

03:20:31

03:20:32

03:20:35

03:20:38

03:21:11

03:21:14

03:21:19

03:21:22

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

38

been admitted as Exhibit 6e.

And, again, if we look at the last page of Exhibit 6e.

And publish that to the jury?

THE COURT: Yes, 6e.

MS. GLATFELTER: Thank you. One moment.

THE WITNESS: This doesn't look like --

MS. GLATFELTER: One moment, Your Honor.

THE COURT: Yes.

MS. GLATFELTER: Actually, I'm not sure we need to

take a break or not, but I want to make sure I find the right

exhibit.

THE COURT: I am prepared to take a break if it

would be convenient.

MS. GLATFELTER: Yes. Thank you, Your Honor.

THE COURT: We will take a 20-minute break. During

the break, take the break. Don't discuss the case among

yourselves or with anyone else. No independent research.

Continue to keep an open mind.

Out of respect for you, we'll rise as you leave.

THE COURTROOM DEPUTY: All rise for the jury.

(Jury out at 3:20 p.m.)

THE COURT: The jury has left the room. We're going

to break 20 minutes, till 3:41.

During the break, sir, do not discuss your testimony,

please.

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 38 of 68 PAGEID #: 2336
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:21:23

03:21:27

03:21:39

03:21:39

03:21:42

03:39:27

03:39:31

03:39:35

03:39:35

03:39:35

03:39:40

03:39:42

03:39:44

03:39:45

03:39:47

03:39:47

03:39:50

03:39:56

03:41:14

03:41:16

03:41:46

03:41:51

03:41:56

03:41:59

03:42:01

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

39

We're in break until that time. When we come back, we

will proceed. I'm going to need to stop abruptly by 4:25. We

are in recess for 20 minutes.

THE COURTROOM DEPUTY: The court is now in recess.

(Recess from 3:21 p.m. until 3:39 p.m.)

THE COURT: We're back in the courtroom. Is there

anything that requires my attention before we get the jury,

from the government?

MS. GLATFELTER: No, Your Honor.

THE COURT: From the defense?

MR. McBRIDE: No, sir.

THE COURT: Forgive me. Are we now at

cross-examination?

MS. GLATFELTER: No. I still have some more

questions to go.

THE COURT: Very well. Let's call for the jury,

please.

And the witness can retake the stand and be seated.

THE COURTROOM DEPUTY: All rise for the jury.

(Jury in at 3:41 p.m.)

THE COURT: You may all be seated. Thank you.

All 15 jurors are back. Thank you for your attention.

We will continue to hear government questions of this witness.

You may proceed, counsel.

MS. GLATFELTER: Thank you.

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 39 of 68 PAGEID #: 2337
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:42:03

03:42:06

03:42:09

03:42:10

03:42:16

03:42:17

03:42:17

03:42:25

03:42:26

03:42:27

03:42:32

03:42:35

03:42:44

03:42:46

03:42:53

03:42:56

03:42:57

03:43:00

03:43:02

03:43:02

03:43:03

03:43:07

03:43:11

03:43:15

03:43:20

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

40

Before the break, I had asked if the witness could be

shown Exhibit 6e, and published to the jury because it's

admitted.

THE COURT: 6e, we'll show it to everyone.

MS. GLATFELTER: Thank you. We're looking at the

last page -- or the second page. Sorry.

BY MS. GLATFELTER:

Q. Mr. Kray, do you see that on your screen?

A. Yes, I do.

Q. And I want to go through the same exercise we did before.

We're looking at this document. If you can tell us whether

any of these terms relate to composite fan blade or composite

containment system technology.

A. Certainly. So certainly we have obviously casing here,

right. We are talking about materials, structure, and

strength, right.

Q. Mr. Kray, I am going to ask you to pull the microphone

closer to you so we can hear you while you are looking at the

screen.

Okay. Thank you.

A. So we have materials, structure, and strength, right.

So, again, how we manufacture that blade and how we design

it to optimize the strength, okay, is key.

Manufacturing. How you make the blade, right. So how

you -- again, the fibers, how you assemble the fibers,

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 40 of 68 PAGEID #: 2338
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:43:24

03:43:32

03:43:37

03:43:41

03:43:44

03:43:50

03:43:53

03:43:57

03:44:00

03:44:00

03:44:04

03:44:07

03:44:10

03:44:14

03:44:20

03:44:22

03:44:27

03:44:31

03:44:34

03:44:40

03:44:43

03:44:45

03:44:49

03:44:53

03:44:58

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

41

orientations, et cetera, are all in that manufacturing.

This right here, design flow, ideas, principles, this

guy right here (indicating), that's the whole process of,

you know, how you actually go through the design process,

how you -- what's your design principles, and how do you

know one design's good and one is not.

And then demonstration, validation steps. We talked

about the testing, right. That's all built into that

validation.

Manufacturing, certainly that's -- that's key.

Manufacturing of these products is, you know, you can design

them, but if you can't make them, you're not going to have

very good product, right. So it's all a balance of what can

you manufacture. Can you manufacture it reliably every

time, makes it a viable product.

And then implement it in engineering down here. The

drawings, certainly that is very proprietary data. The

drawing basically defines your design. The drawing is

essentially engineering's communication with manufacturing.

I can take a drawing, a physical drawing and give it to the

manufacturer and they can make that part. So the drawing

has a lot of information on it about the product.

And then experimental tests and process standards.

Again, all that learning that we go through, that 10 or 15

years of process steps: You know, how do you -- how do you

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 41 of 68 PAGEID #: 2339
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:45:01

03:45:06

03:45:09

03:45:09

03:45:13

03:45:17

03:45:19

03:45:23

03:45:27

03:45:31

03:45:35

03:45:42

03:45:43

03:45:46

03:45:48

03:45:52

03:45:55

03:45:59

03:45:59

03:46:05

03:46:07

03:46:09

03:46:12

03:46:17

03:46:20

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

42

experimentally test it, how do you design a test such that

you can maximize your knowledge of that material system is

key.

Q. All right. And if we look at the top of the document,

and there are some terms there, are any of those terms

specific to composite fan blade?

A. Certainly. Material and size, right. That certainly

is key, right. I mean, what's the size of your blade. You

know, how big can you make it. What your thickness is.

Again, all of these not only play in performance from a

pumping air perspective but also from a credibility

perspective.

I think I know an aero guy, an aero design engineer

wants the air flow to be as thin as this sheet of paper, but

we know it's not going to survive, right. The first time it

hits a rock or a bird, it's going to break. So it's that

balance of size and definition of what works and what

doesn't work.

Q. And we see down in the middle of the page "A, B,

reference, value, and confidential."

When you were describing the modeling and the software

that you use before you go into actual component testing,

could these terms relate to that?

A. Well, I don't know what it really means by A and B. It

looks like it's some type of comparison. I don't know if

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 42 of 68 PAGEID #: 2340
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:46:24

03:46:25

03:46:27

03:46:31

03:46:35

03:46:38

03:46:43

03:46:47

03:46:49

03:46:53

03:46:58

03:47:04

03:47:08

03:47:10

03:47:14

03:47:17

03:47:20

03:47:25

03:47:26

03:47:27

03:47:32

03:47:38

03:47:42

03:47:43

03:47:47

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

43

it's been redacted out of here.

But, certainly, again, it's a trail on material

systems, first of all, the material perspective, but also

the analytical perspective. We talked about building

analytical models to match testing, right. You like to do

tests, but you also like to do analytical predictions so you

can analytically iterate on design features and save

yourself some testing. Certainly, you'll test at the end,

but the more you can analytically understand the material

system, the geometry of the blades or cases, the better off

you are from a, you know, design cycle timing-wise. So if I

understand it more mathematically, I can do simulations to a

certain point. And then at some point I test. And either I

validate those simulations or I go back and modify my

simulations to say, I learned something new. I need to

modify my understanding.

Q. Thank you. Now, these are general terms up on the screen

that you've highlighted, right?

A. Yes.

Q. Could discussion of these terms by someone with knowledge

of GE Aviation's composite fan blade and composite containment

system lead to a discussion of secret GE information about

those topics?

MR. McBRIDE: Objection. Calls for speculation.

THE COURT: Overruled.

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 43 of 68 PAGEID #: 2341
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:47:48

03:47:53

03:47:56

03:48:00

03:48:05

03:48:09

03:48:11

03:48:13

03:48:19

03:48:21

03:48:23

03:48:25

03:48:27

03:48:29

03:48:30

03:48:35

03:48:41

03:48:43

03:48:52

03:48:55

03:48:59

03:49:07

03:49:10

03:49:11

03:49:15

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

44

You can answer the question. Do you need it again?

THE WITNESS: So the data behind this, yes, would be

very proprietary for all the, you know, things we have

highlighted here. That supporting data for those statements

is certainly the meat of the proprietary nature of the

composite blades and cases.

BY MS. GLATFELTER:

Q. Do you know someone by the name of David Zheng?

A. You mean Daihu?

Q. Daihu Zheng?

A. Yes, I know -- I actually knew him very well.

Q. Did you work together?

A. Yes.

Q. And on what?

A. So I first met Daihu when he worked at our Global

Research Center in Niskayuna, New York. He was a research

engineer there. He supported -- you know, we talked about

the lineage of composite fan blades on GEnx fan blades. He

was supporting that analysis of those test predictions.

And then Daihu eventually moved to Evendale and

supported the GE9X program, which is our latest composite

fan blade case program, again doing analytical predictions

and manufacturing integration of those products.

Q. And as someone working on those projects, did Mr. Zheng

have access to design data, testing files, and other

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 44 of 68 PAGEID #: 2342
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:49:19

03:49:22

03:49:27

03:49:31

03:49:35

03:49:36

03:49:39

03:49:42

03:49:45

03:49:48

03:49:55

03:49:59

03:50:02

03:50:06

03:50:10

03:50:10

03:50:12

03:50:17

03:50:20

03:50:21

03:50:27

03:50:31

03:50:36

03:50:41

03:50:46

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

45

information that GE Aviation tries to keep secret?

A. Yes, he would, as being a part of those programs.

Q. Aside from those files themselves, would an engineer --

would he know public information -- I'm sorry. Let me strike

that.

Aside from the files, would he know non-public

information about GE fan blades and containment system

technology that GE would not want shared with outsiders?

A. Yes, he would. Again, we talk about the building block

approach, right. We're taking one design and leveraging it

to another design, et cetera. He would obviously be

integral with that, to help design the new designs.

Q. Mr. Kray, a few last questions about steps GE takes to

protect information. Now, as an engineer, do you work on a GE

campus?

A. Yes, I do.

Q. And can you briefly describe what kind of physical

security measures, if any, exist around the areas where you

work?

A. So certainly there is card access to any building on

GE -- in GE campus. Whether it's an off-site building or

the main campus, you have card access. There is additional

access. If you're in a, let's say, more secured area, you

have a card and another pass code to get into the door.

Certainly that's -- that's the first level of security from

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 45 of 68 PAGEID #: 2343
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:50:49

03:50:51

03:50:55

03:50:55

03:50:56

03:50:59

03:51:02

03:51:03

03:51:06

03:51:07

03:51:10

03:51:14

03:51:14

03:51:19

03:51:24

03:51:28

03:51:30

03:51:34

03:51:39

03:51:43

03:51:47

03:51:53

03:51:54

03:52:01

03:52:04

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

46

the access perspective, physical.

Q. And as an engineer at GE Aviation, have you been issued a

laptop?

A. Yes, I have.

Q. Okay. And could you briefly describe some of the

security measures surrounding that laptop?

A. Could you repeat the question?

Q. Sure. Do you have a GE Aviation laptop?

A. Yes, I do.

Q. Okay. And are there -- is there security around that

laptop, for example, in the way that you log on or access

files?

A. Yeah. We use what we call a two-factor, or two-factor

authentication. The first one is you have your user ID,

which is a code, and then you have a password associated

with that. Okay, that's the first level.

The second level then they've gone to this chip where

you have to insert a personal chip that you are -- that you

are given to access that computer.

Q. Okay. Are there security measures in what kind of design

files and testing data about composite fan blades in terms of

accessing the data?

A. So as far as our design practices and what I call

design practices, which is, for example, when you -- when

you do, for example, let's say the fan blade-out test,

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 46 of 68 PAGEID #: 2344
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:52:07

03:52:10

03:52:12

03:52:16

03:52:20

03:52:24

03:52:28

03:52:34

03:52:40

03:52:43

03:52:47

03:52:52

03:52:57

03:52:59

03:53:02

03:53:04

03:53:09

03:53:12

03:53:16

03:53:20

03:53:27

03:53:30

03:53:39

03:53:42

03:53:45

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

47

right. There'll be documentation of that. There will be

analytical predictions of that.

We typically take that data, even in its entire or

separate sections, and record it into what we call our

design record books. This is electronic system internal in

GE, which is a named access only. So to get access to those

you have to again go through the password and key access to

get electronic access to them. And then even the -- since

composite blade is considered key technology, it's also

named access. In other words, if I make design practice

summary of a test, as owner of that design summary I would

personally give access to person X, Y, or Z on a

need-to-know basis.

Q. All right. And as an engineer working on the composite

fan blade, if you wanted to present information about that

subject, let's say, to -- publicly at a conference, what, if

any, steps would you have to take at GE Aviation to do so?

A. Okay. So there's actually -- there's two steps you

have to go through. We have what we call design boards,

which are -- which are focused boards of folks, technical

experts, that are specific to a discipline.

For example, my design board is polymeric composites.

That's a design board. There is a design board for

turbines, turbo air flow, or dynamics, et cetera.

So your first step is to take your presentation draft

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 47 of 68 PAGEID #: 2345
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:53:48

03:53:52

03:53:57

03:54:01

03:54:02

03:54:05

03:54:11

03:54:15

03:54:18

03:54:20

03:54:23

03:54:28

03:54:28

03:54:32

03:54:36

03:54:40

03:54:55

03:54:55

03:54:57

03:55:02

03:55:06

03:55:08

03:55:14

03:55:18

03:55:22

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

48

to the design board. That would be reviewed then with the

technical experts for release of information. You know, is

it something we'd want to release to the public. Okay,

that's the first step.

Once it goes through that iteration and say, yeah, the

design board feels that the technical concept is acceptable

to distribute, that package then goes to legal, and legal

has a review of that information that also says from a legal

perspective it's okay to present.

Q. And those are the steps that you're trained to go through

if you wanted to discuss this technology outside of GE

Aviation?

A. Yeah. Whether it's -- whether it's for advertisement

purposes or if somebody wants to go to a symposium and

present a paper, the same way.

MS. GLATFELTER: Just one moment, Your Honor.

(Pause.)

BY MS. GLATFELTER:

Q. When we were looking at 6e before, Mr. Kray, I forgot to

have you scroll down and look at the rest of the exhibit. And

I just wanted to do that before we end it.

We were looking at Exhibit 6e. As a reminder, whether

there were any types of words or terms on there about the

composite fan blade technology.

MS. GLATFELTER: And if we scroll down to the bottom

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 48 of 68 PAGEID #: 2346
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:55:24

03:55:24

03:55:32

03:55:39

03:55:41

03:55:43

03:55:46

03:55:48

03:55:52

03:55:56

03:56:01

03:56:04

03:56:07

03:56:11

03:56:16

03:56:21

03:56:23

03:56:26

03:56:30

03:56:33

03:56:37

03:56:41

03:56:43

03:56:47

03:56:49

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

49

of that page, Ms. Prim.

BY MS. GLATFELTER:

Q. So I think we went through all the numbers except 3 or 4.

A. Yeah, so certainly -- certainly, materials, right. I

mean, material was used and how -- you know what material

are you using in your designs.

Production processes. Again, that's the manufacturing

method, right. How do you work with the material.

Material brands, you know, this is, we buy our material

from -- we don't make our own composite material. We'll buy

it. It's commercially available. So what brand names are

you using, right.

Standards. You know, all of our material we have

specifications and standards. You know, if you go to buy,

let's say, anything from a manufacturer, they are going to

have their advertisement of how great their material is,

right. Certainly, we take that with a grain of salt. We

don't really believe it. I mean, we actually do our own

testing to say, yeah, it's right or maybe it's not really

exactly right. It's a good advertisement article, but it's

not -- for our needs it's not adequate.

So what we typically do is once we understand a

material, we write our own specifications and our own

standards to say if we are going to ship me that material to

make a composite fan blade, you have to meet these

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 49 of 68 PAGEID #: 2347
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:56:52

03:56:54

03:56:57

03:57:02

03:57:06

03:57:08

03:57:12

03:57:16

03:57:19

03:57:24

03:57:26

03:57:30

03:57:32

03:57:34

03:57:36

03:57:41

03:57:43

03:57:47

03:57:51

03:57:51

03:57:56

03:57:58

03:58:00

03:58:04

03:58:05

KRAY - DIRECT (Glatfelter)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

50

specifications or I'm not going to accept the material,

because I know that my assumptions for strength and

durability rely on these specifications of material.

Performance parameters. Certainly, how well -- how

well does the material perform. Not only from a strength

perspective but the fan blade from a -- from an overall

pumping air, right. The main thing is the fan blade is

going to pump air. And that's its whole purpose in life is

to pump air. If it does pump air very well, and how does it

deflect the load. Those are all reason for performance.

Again, highest performing engine is what we're trying to

achieve.

And then, obviously, test data. You know we talked

about test data, right. That's very important.

Q. And before when we stopped, when we ended our discussion

of this exhibit, I had asked you do discussion of these terms,

discussion of these new terms lead to discussion of GE's

secret information about composite fan blades and containment

systems?

A. Certainly. All the material behind those terms is, is

what we're trying to protect.

Q. For example, the specifications that you were mentioning

before, is that one of the things that GE doesn't share with

the public or competitors?

A. We do not share with our competitors. We share with

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 50 of 68 PAGEID #: 2348
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:58:08

03:58:13

03:58:18

03:58:18

03:58:21

03:58:22

03:58:22

03:58:28

03:58:31

03:58:34

03:58:40

03:58:41

03:58:42

03:58:43

03:58:44

03:58:46

03:58:47

03:58:51

03:58:53

03:58:57

03:59:02

03:59:04

03:59:08

03:59:16

03:59:19

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

51

our suppliers, right. When we buy material, we say you have

to meet this specification, and they obviously -- obviously

have witness to that.

Q. And the test data is another example?

A. Yes.

Q. Thank you.

MS. GLATFELTER: No further questions.

THE COURT: The lawyer for the defendant has an

opportunity to ask questions of you at this time.

Cross-examination. We're going to break abruptly at

4:25.

MR. McBRIDE: Yes, sir.

CROSS-EXAMINATION

BY MR. McBRIDE:

Q. Good afternoon, Mr. Kray. How are you today?

A. I'm very good. How are you?

Q. Good, thank you. My name is Bob McBride, and I am one of

the lawyers that represent Mr. Xu today in this case.

One of the things that I believe you testified about was

it was important to have safe vehicles and safe products for

FAA certification, correct?

A. Well, that is correct, but not only from a

certification perspective but from, you know, the overall

design, right. I mean, we can meet certification

requirements, but over and above that we want to make sure

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 51 of 68 PAGEID #: 2349
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:59:24

03:59:24

03:59:25

03:59:26

03:59:30

03:59:33

03:59:35

03:59:39

03:59:45

03:59:45

03:59:46

03:59:50

03:59:54

03:59:55

03:59:57

03:59:59

04:00:06

04:00:06

04:00:10

04:00:13

04:00:16

04:00:21

04:00:25

04:00:27

04:00:34

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

52

it's safe.

Q. Absolutely. Because people's lives are at stake.

A. Certainly.

Q. Absolutely. And I'm not contesting that in any way,

shape, or form.

I am going to try to go backwards a little bit here if I

could. I believe you testified earlier that in order for a

presentation to be made it had to be cleared by a board,

correct?

A. Correct.

Q. And cleared by legal, correct? So there are some

instances then when there are presentations made that show GE

images, correct?

A. That's correct.

Q. Are you aware if any of those kinds of presentations

include composite -- jet engine with composite fan blades and

housings?

A. Well, certainly the picture we just looked at, right.

I mean, that's a general picture of a composite blade

encased. That's certainly a public -- a public figure.

Q. And, in fact, let me ask this question. Have you looked

at the Safran website regarding the LEAP engine?

A. Can you repeat your question?

Q. Have you looked at Safran's website -- pardon me -- CFM

International's website?

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 52 of 68 PAGEID #: 2350
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:00:35

04:00:38

04:00:40

04:00:41

04:00:45

04:00:48

04:00:51

04:00:58

04:01:01

04:01:05

04:01:09

04:01:10

04:01:13

04:01:15

04:01:16

04:01:20

04:01:22

04:01:24

04:01:27

04:01:29

04:01:29

04:01:32

04:01:33

04:01:36

04:01:37

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

53

A. I may have looked at it once or twice, I'm sure.

Q. Seen the images of a LEAP engine there?

A. Sure, sure.

Q. So the technology itself or the fact that there are

composite -- let me rephrase. The fact that there are

composite fan blades and containment housings in and of itself

is not a secret that GE wants to keep?

A. I think the fact that composites are out in industry is

something we want to promote because it is our commercial

advantage. Now, how to make those certainly is something we

want to protect.

Q. I understand. But these vehicles -- pardon me. These

jet engines are sold all over the world; is that correct?

A. That is correct.

Q. In fact, it's one of GE's best selling products in terms

of jet engines, is it not?

A. That is correct.

Q. And that's because it is a more durable and lighter jet

engine you can build?

A. Correct.

Q. And that makes it easier to make a larger and lighter

aircraft too?

A. That's -- that is our goal, yes.

Q. Very generally.

A. Yes.

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 53 of 68 PAGEID #: 2351
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:01:37

04:01:43

04:01:47

04:01:51

04:01:55

04:02:00

04:02:02

04:02:06

04:02:11

04:02:14

04:02:18

04:02:21

04:02:25

04:02:27

04:02:28

04:02:30

04:02:35

04:02:38

04:02:43

04:02:48

04:02:54

04:02:56

04:02:59

04:03:02

04:03:05

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

54

Q. Obviously, I don't have the technical knowledge.

One of the things I believe you just talked about, sir,

was buying the materials. You will get specifications from

various vendors; is that correct?

A. So we -- we get specifications from a supplier of a

very general nature. Okay. Now, certainly, they like to

sell their product, right, so they'll say how great it is.

Again, we -- we take that as a first step.

Second step is we go and validate. You know, there is

no perfect world, right. So we make sure that what they say

is true and house, you know -- if I have a manufacturing

material that's balanced on a pin of a head, right, which is

sometimes what they'll try to sell --

Q. Um-hmm.

A. -- as soon as they deviate on their material from one

way or the other, it has a big debit. And that's what we

try to understand when we put specifications in. If I say

that I manufacture our material at, let's say, 200 degrees,

for example, I manufacture my prepreg at 200 degrees. If I

manufactured it at 205 degrees, are my properties consistent

or do they fall off?

So, again, understanding that when we call design space

around the -- all the products, whether it's material or

even the design itself, is critical.

Q. So the consistency of the material, particularly the

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 54 of 68 PAGEID #: 2352
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:03:07

04:03:12

04:03:13

04:03:19

04:03:19

04:03:23

04:03:26

04:03:30

04:03:31

04:03:33

04:03:34

04:03:39

04:03:44

04:03:47

04:03:49

04:03:50

04:03:54

04:03:59

04:04:01

04:04:05

04:04:09

04:04:09

04:04:12

04:04:12

04:04:13

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

55

fibers, is important in the ceramic matrix design and

manufacturing process, is it not?

A. So ceramic matrix is a little different.

Q. Metric. Pardon me.

A. So we talk about polymeric matrix, right. Ceramic

matrix is, again, it's a composite but it's in the back of

the engine. It's a very, very high temperature capability.

That's not in the fan.

The polymeric, which is epoxy-based composites, are

what we are dealing with here.

Q. My apologies. I meant polymetric composite.

But in the design and manufacturing of the polymetric

components, it's very important to have a consistent and

stable fiber, is it not, that you start with?

A. That is correct.

Q. And if you were to start the design process with a

different fiber, that would impact the entire cycle design,

manufacturing process cycle, would it not?

A. It would -- you would have to go back and repeat a lot

of that characterization to understand that material just as

well, yes.

Q. And, in fact, it would impact the computer modeling

codes --

A. Certainly.

Q. -- would it not?

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 55 of 68 PAGEID #: 2353
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:04:14

04:04:14

04:04:18

04:04:22

04:04:27

04:04:31

04:04:35

04:04:37

04:04:41

04:04:42

04:04:46

04:04:53

04:04:56

04:04:59

04:05:00

04:05:10

04:05:10

04:05:11

04:05:14

04:05:20

04:05:24

04:05:27

04:05:31

04:05:35

04:05:40

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

56

A. Certainly.

Q. So even a change as minor as a fiber can impact the

entire design-build process, correct?

A. Yes. Whether it's fiber size, fiber direction, even --

even the supplier of the fiber. You know, whether I buy it

from Company A or Company B, fiber is not always fiber,

right. You have to make sure that you understand that

potential subtle difference which could make a big

difference in design, yes.

Q. So were one to hypothetically try to replicate GE's

process, they would have to know exactly the fiber you buy and

exactly the tests you need and what the tolerances are that

you evaluate it at; is that correct?

A. I would say that's correct.

Q. You spoke, sir, about coupon testing and component

testing.

A. Um-hmm.

Q. What is that general process called?

A. Well, again, I don't know if you'd really call it a

process. We call it the hierarchy of learning, the pyramid

of learning, right. So the very basic level when you're

trying to sort out, let's say, again when you talked about

fiber size and parameters, right. It's sorting out, you

know, material A versus material B verses resin A versus

resin B and a combination thereof. All that gets done at

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 56 of 68 PAGEID #: 2354
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:05:43

04:05:48

04:05:52

04:05:55

04:05:59

04:06:00

04:06:00

04:06:06

04:06:09

04:06:10

04:06:13

04:06:16

04:06:19

04:06:22

04:06:26

04:06:29

04:06:32

04:06:35

04:06:36

04:06:36

04:06:40

04:06:44

04:06:45

04:06:49

04:06:51

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

57

the very basic level, which is you can go through a lot of

coupons rather quickly versus trying to build the parts and

build tooling and test parts, yes, sir.

Q. So is this process generally known as the building block

process?

A. That is correct.

Q. And so the building block process is well-known in the

industry for making composites, correct?

A. That is true, yes.

Q. So if I wanted to make a composite flying pig, I may want

to use the building block process, correct?

A. You can make golf shafts or whatever, sure.

Q. So almost anything made of composites will use this

building block process; is that fair?

A. Typically, that's -- that's the industry standard, yes.

Q. And within the building block process, the industry

standards that you have mentioned is to start with the coupon

test, correct?

A. That's correct.

Q. And the coupon test -- and correct me if I'm wrong,

sir -- is a very tiny bit of material when you begin the

testing, correct?

A. It is limited in size. The coupons are typically, you

know, on the order of an inch by a couple inches. It's

rather small material.

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 57 of 68 PAGEID #: 2355
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:06:52

04:06:54

04:06:55

04:06:57

04:06:57

04:07:00

04:07:04

04:07:05

04:07:06

04:07:11

04:07:12

04:07:17

04:07:22

04:07:25

04:07:29

04:07:30

04:07:33

04:07:37

04:07:37

04:07:38

04:07:42

04:07:46

04:07:51

04:07:55

04:07:58

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

58

Q. Relative to the size of the fan blades and --

A. Oh, yes.

Q. -- the fan case, they are pretty small, aren't they, sir?

A. Yes.

Q. So -- and the purpose of this is you will take a coupon

with the fibers and the epoxy and you will test it for its

performance, correct?

A. Correct.

Q. And that performance is in terms of stretching the

material, correct?

A. It's -- it's stretching. It's twisting. You know, you

build up internal shears. It's fatigue. Again, the paper

clip, how many times can I bend it back and forth before it

breaks. All that -- all that type of basic, I am going to

call it basic testing, yes.

Q. So just for point of reference, the shear that you

mentioned, sir, is shearing of the layers of the coupon; is

that correct?

A. That's correct.

Q. And then as I understand the process -- and my view is

very simple -- you will then put components together, coupons

together, and test larger pieces of the coupon test?

A. Yeah. You'll -- you'll go from a coupon testing up to

basically then you might have some specific feature testing,

right.

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 58 of 68 PAGEID #: 2356
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:07:58

04:08:02

04:08:06

04:08:11

04:08:14

04:08:21

04:08:27

04:08:31

04:08:31

04:08:31

04:08:34

04:08:36

04:08:40

04:08:41

04:08:41

04:08:45

04:08:51

04:08:51

04:08:52

04:08:53

04:08:53

04:08:56

04:09:00

04:09:01

04:09:05

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

59

So let's talk about composite fan blade, for example.

The retention system, how I hold it in a disk. I may test

only that feature in a -- in a static type of pole test just

to understand how those shears and capabilities work

together when I go from a coupon level to a more complex,

multi -- multilayer or composite construction that might be

similar to the architecture of my proposed design.

Q. So you are basically going from the bottom up, and you

have --

A. Right.

Q. And you have a -- you have coupons large enough, and then

at some point you are going to want to get to do some more

sophisticated testing, correct?

A. Correct.

Q. So, for instance, you were mentioning a more complex

geometric shape that you might want to test, like a bend in a

blade, correct, sir?

A. Correct.

Q. Is that fair?

A. Sure.

Q. And there are also other tests that you do. You, like,

punch a whole in a block of coupons and test how that reacts

when you pull it, correct?

A. Yeah. Damage -- we typically call that damaged

tolerance. We will intentionally put damage in the material

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 59 of 68 PAGEID #: 2357
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:09:08

04:09:11

04:09:11

04:09:12

04:09:16

04:09:19

04:09:23

04:09:23

04:09:27

04:09:30

04:09:34

04:09:38

04:09:42

04:09:44

04:09:47

04:09:52

04:09:53

04:09:56

04:09:59

04:10:03

04:10:06

04:10:09

04:10:13

04:10:18

04:10:23

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

60

and see how it reacts. Again, you know, safety, right. If

I --

Q. Sure.

A. -- pick up a rock off the runway, it hits a composite

part, does damage. The aircraft's in the air. Is it going

to propagate and cause more damage? I want to know that

ahead of time.

Q. Absolutely. So each piece that you test, you essentially

test it to destruction of that coupon or component, correct?

A. Typically to destruction, yeah. We want to know the

thresholds. Certainly, what I'm going to call the elastic

portion. You know, how much it bends and deforms under --

just on the elastic load.

And then ultimate load. How it breaks. What is the

failure mode. Does it -- does it split apart or do the

fibers break.

All that understanding is critical to take it to the

next level of actual component design.

Q. And as I understand it, with the results of this

destructive test, whichever type it is, you will then do a

modeling, a computer modeling for the next?

A. That's right. That's correct. We try to -- we try to

build these computer models, simulations, to again capture

that capability because, again, if we can use that

understanding to drive the design at the next level higher,

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 60 of 68 PAGEID #: 2358
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:10:28

04:10:32

04:10:36

04:10:38

04:10:42

04:10:45

04:10:48

04:10:52

04:10:54

04:10:57

04:11:01

04:11:05

04:11:13

04:11:16

04:11:19

04:11:24

04:11:25

04:11:26

04:11:30

04:11:34

04:11:38

04:11:40

04:11:43

04:11:45

04:11:49

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

61

which is the blade level or the case level, that certainly

will help us, you know, shorten that design cycle and get a

little bit of learning, yes.

Q. And the program -- correct me if I'm wrong about this --

that GE generally uses is LS Dyna, correct?

A. That's correct. That is a commercial code. It's

available across the board. But it's like -- it's a very,

I'm going to call it, open architectural program.

Q. Um-hmm.

A. So you need to put in your material, I'm going to call

it material models, your material understanding. And let's

say a typical composite material model may have 15 or 20

constants to have to be put into that computer language so

it understands how it breaks under tension, compression,

shear, all right. And all those constants are derived off a

coupon testing.

Q. Sure.

A. And feeds into the overall material model.

So, yeah, Dyna is a very generic code. It's very --

you don't buy it with composite material properties in it,

right. You have got to put those in yourself.

Q. Understood. But there are other similar programs out

there that are commercially available?

A. Oh, sure. There is Abacus, there is Dytran, there is

Dyna. You know, again, it's user preference. We have

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 61 of 68 PAGEID #: 2359
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:11:52

04:11:57

04:12:02

04:12:05

04:12:06

04:12:14

04:12:17

04:12:20

04:12:26

04:12:30

04:12:31

04:12:34

04:12:38

04:12:41

04:12:42

04:12:42

04:12:48

04:12:51

04:12:56

04:12:59

04:13:03

04:13:08

04:13:11

04:13:23

04:13:24

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

62

built -- basically over the last probably 15, 20 years

maybe, Dyna has been our choice of software. We've used

others before that, but it looks likes Dyna is becoming the

industry standard.

Q. So within the modeling process and the computer model

generation, that's all based on what I will call trial-anderror testing that you have done in the past?

A. Yeah. So as I might have mentioned earlier, that

builds your basic understanding, builds your constants for

materials.

Now, as you get into, let's say -- let's take it to the

next level up. A bird ingestion, for example. I use that

model, that computer simulation code to predict what might

happen when a bird hits --

Q. Right.

A. -- the airfoil. I predict it. I adjust my

thicknesses. I kind of optimize my design to make it work.

At least on the computer it works. And then I do a test.

And the test may come back and say, yes, your prediction is

good. So you go to the next level. If it's not good, I

need to go back and understand why and adjust my material

assumptions or my material model of why it didn't work

because I certainly need to understand that to make my

efficient design.

Q. Let me follow on with -- and I think this is what you're

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 62 of 68 PAGEID #: 2360
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:13:27

04:13:29

04:13:35

04:13:36

04:13:41

04:13:44

04:13:48

04:13:52

04:13:52

04:13:55

04:13:57

04:13:57

04:14:00

04:14:02

04:14:04

04:14:05

04:14:05

04:14:05

04:14:07

04:14:09

04:14:09

04:14:09

04:14:12

04:14:14

04:14:15

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

63

saying, sir -- is that to a certain degree building a

polymetric composite component part is dependent on the

in-house processes?

A. I would say it's built on the learnings, yes. Again,

you are leveraging a building block. And in our case, since

we are on, what I will call, almost our fifth generation of

composite families, is building upon the hierarchy of those

generations.

Q. So let me run down a list of things that I want to ask

you if they're significant.

A. Um-hmm.

Q. So I think you've already talked about a knowledge base

regarding your design; is that correct?

A. Could you repeat that again?

Q. So the company's knowledge base --

A. Yes.

Q. -- and the design --

A. Yes.

Q. -- is an important thing, and that's all in-house,

correct?

A. Yes.

Q. And then the preferences regarding the modeling codes we

just talked about, correct?

A. Correct.

Q. Something that GE develops over time, correct?

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 63 of 68 PAGEID #: 2361
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:14:20

04:14:24

04:14:25

04:14:28

04:14:31

04:14:35

04:14:38

04:14:41

04:14:43

04:14:45

04:14:48

04:14:52

04:14:56

04:14:59

04:15:03

04:15:04

04:15:08

04:15:11

04:15:11

04:15:13

04:15:15

04:15:22

04:15:23

04:15:26

04:15:31

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

64

And then the in-house guidelines you might have for the

product itself, correct?

A. Yeah. And we talk in-house guidelines, it's, okay,

what kind of stress levels can I live with for either

fatigue, right, my bending, my -- you know, go back to my

paper clip. You know, how much, how much bending can I do

to make sure it fatigues right. All that is kind of built

into that learning.

Q. Right. And then the manufacturing expertise and

limitations, that's an important component, correct?

A. Certainly manufacturing because, again, if you

manufacture on the pin of a head, you need to understand any

deviation to that manufacturing so I don't put a product out

the door that I assume is this capable and it's only this

capable (indicating).

Q. I'm not looking at my watch because I am concerned about

your testimony. I want to make sure I don't blow the judge's

timeline.

THE COURT: I'll take care of that.

MR. McBRIDE: Thank you.

BY MR. McBRIDE:

Q. And GE, of course, is a global manufacturer and has --

tell me if this is fair -- compared to most of its

competitors, huge personnel and financial resources to develop

technology, correct?

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 64 of 68 PAGEID #: 2362
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:15:31

04:15:35

04:15:38

04:15:44

04:15:47

04:15:50

04:15:55

04:15:56

04:16:04

04:16:08

04:16:09

04:16:11

04:16:15

04:16:19

04:16:24

04:16:25

04:16:28

04:16:34

04:16:37

04:16:42

04:16:46

04:16:50

04:16:52

04:16:53

04:16:56

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

65

A. Yeah, I would say. You know, when you look at jet

engines, right, you've got three main players and maybe a

couple smaller players. You've got GE, Pratt & Whitney, and

Rolls-Royce are the three main players in the industry.

And you have Safran and Honeywell, which I want to call

it -- are also players but probably not as big as the top

three.

Q. So I believe you told us that the building block is a --

building block approach is a basic way to building component

structures, sir; is that correct?

A. The building block understanding, yes.

Q. And this is essentially the process that General Electric

has -- GE Aviation has used in building its components,

polymetric component fan blades and housings, correct?

A. I would say yes.

Q. And it could -- and other organizations, if they spent

the time and the money, could also build polymetric fan blades

and housing using the same basic method, correct?

A. I would say that is correct, but others have tried and

not succeeded.

Q. Well, you mentioned Rolls-Royce. I believe in the '80s,

sir, it almost went bankrupt. Is that what you said?

A. Yes.

Q. In the '80s, I think you would agree with me that

computer capabilities were not quite what they are today.

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 65 of 68 PAGEID #: 2363
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:17:00

04:17:05

04:17:07

04:17:11

04:17:16

04:17:21

04:17:24

04:17:28

04:17:30

04:17:33

04:17:36

04:17:37

04:17:41

04:17:44

04:17:45

04:17:47

04:17:52

04:17:57

04:18:02

04:18:06

04:18:10

04:18:18

04:18:22

04:18:25

04:18:29

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

66

A. I would a hundred percent agree.

Q. And so that certainly might have been a factor in the

problems that Rolls-Royce had in creating the --

A. Yes, that is true, but our competitors still don't have

composite blades. And the funny thing is they have metallic

blades and they paint them to look like composite blades.

Q. So you are telling me that Rolls-Royce UltraFan's engines

do not have composite fan blades?

A. They are touting that it does, but it is not certified.

Q. Well, that doesn't mean it is not a composite fan blade,

though, does it?

A. It can look good on a shelf, but it doesn't fly yet.

Q. That doesn't mean it's not a composite fan blade, does

it, sir?

A. It's a composite fan blade.

Q. All right. Would you agree with me also that it takes a

lot of institutional resolve to develop this kind of product?

A. I think it takes a lot of dedication, certainly. I

mean, we talked 10 to 15 years of development process to do

that, and that's with a large team working on it. Not only

design but materials, certification, testing. It's -- it's

several. I will say a hundred people.

Q. But you would agree with me that were another

organization to have those skills, likes Rolls-Royce, they

could develop composite fan blades and housings?

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 66 of 68 PAGEID #: 2364
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:18:33

04:18:35

04:18:38

04:18:40

04:18:45

04:18:47

04:18:50

04:18:52

04:18:53

KRAY - CROSS (McBride)

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

67

A. I guess it's feasible.

Q. Thank you, sir. Those are all the questions I have.

THE COURT: Very well. Is there redirect of this

witness?

MS. GLATFELTER: No, Your Honor.

THE COURT: Very well. Sir, your testimony is

complete and you have appeared to have survived, and you are

free to go.

THE WITNESS: Thank you, sir.

(Proceedings reported but not transcribed.)

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 67 of 68 PAGEID #: 2365
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Mary A. Schweinhagen, RDR, CRR (937) 512-1604

68

CERTIFICATE OF REPORTER

I, Mary A. Schweinhagen, Federal Official Realtime

Court Reporter, in and for the United States District Court

for the Southern District of Ohio, do hereby certify that

pursuant to Section 753, Title 28, United States Code that the

foregoing is a true and correct transcript of the

stenographically reported proceedings held in the

above-entitled matter and that the transcript page format is

in conformance with the regulations of the Judicial Conference

of the United States.

s/Mary A. Schweinhagen

__________________________________ 31st of October, 2021

MARY A. SCHWEINHAGEN, RDR, CRR

FEDERAL OFFICIAL COURT REPORTER

Case: 1:18-cr-00043-TSB Doc #: 165 Filed: 10/31/21 Page: 68 of 68 PAGEID #: 2366