# Transcript of Record — Universal Oil Products Co. v. Globe Oil & Refining Co > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386404_0029%3A02 ## Record - **Collection:** Supreme Court brief - **Document type:** Transcript of Record - **Published:** January 1, 1944 - **Citation:** 322 U.S. 471 ## Text _ TRANSCRIPT OF RECORD © * —-. (Pages 551 to 1022a) ee — ae an nr i - Supreme Court of the United States OCTOBER TERM, 1943 _ No. .392 | UNIVERSAL OIL PRODUCTS COMPANY, | . PETITIONER, oh ee Us. ‘GLOBE OIL & REFINING COMPANY ‘ON WRIT OF CERTIORARI TO THE UNITED STATES CIRCUIT COURT OF APPEALS FOR THE SEVENTH CIRCUIT " PETITION FOR CERTIORARI FILED SEPTEMBER 28, 1943. CERTIORARI GRANTED NOVEMBER 15. 1943. . VOL. Il pp. 551 to 1022. "TRANSCRIPT OF RECORD ~ IN THE - Supreme Court of the United States Ocroper Term, A. D. 1942: r NIV ERSAL “Ol PRODUCTS ( ‘OMP ANY, ne | ; Petition: r, Us. Ps GL OBE OIL & RE FINING. COMPANY, Responde nt. ON WRIT OF CERTIORARI TO THE UNITED STATES CIRCUIT COURT OF APPEALS FOR THE SEVENTH CIRCUIT. : ———EE———— THE GUNTHORP. WARREN PRR T ING COMPANY, 210 WER ceCRRUw, Om c40c > IN THE ae Supreme Court of the United States _ OctosER — A. D. 1942. UNIVERSAL OIL PRODUCTS COMPANY, Petitioner, V8. : po GLOBE OIL & REFINING COMPANY, = arr Respondent. , ; , ON WRIT oF CERTIORARI TO THE UNITED STATES ‘CIRCUIT COURT oF APPEALS FOR THE SEVENTH CIRCUTT.. I *..--- - -3585 Clerk’s Certificate .....-.. peseenccocesceosseons 3587 VOL. HI pp. 551 to 1022. _ TRANSCRIPT OF RECORD — - Sines as out of Anneals | - the Seventh _ No. 7912 UNITY ERSAL OIL. PRODUC TS COMPANY, Plaintif- Appellant, ° vs. ° ' GLOBE OL & REFINING COMPANY, | Defendant- Appellee. g 5.0. C. A.-T.. ] FIgD ws CS | Sub 8114942 — | sl ; va i t NETH. CARRIOK = [- |. \ * CLERK os e [ Appeal fr ‘om the District Court of the United States for the Northern District of Illinois; Eastern Division. THE GUNTHORS. WARREN PRINTING COMPANY, 230 WEST JACKSON, CHICAGO ; “DOCKETED JAN. 14, 1942. TRANSCRIPT FILED APRIL 2, 1942. Write States iret ne of PAnpeals “Ror the Seventh Circuit. No. 7912 _ UNIVERSAL OIL PRODUCTS COMPANY, Plaintiff-Appellant, vs. GLOBE OIL & REFINING COMPANY, Defendant-Appellee. Appeal from the District Court of the United States for the - Northern District of Hlinois, Eastern Division. ee INDEX. Certificate of counsel as to abstract of record. Kinebaks | Docket Entries | AEE PE ON ALES isanetekuas Bill of Complaint, filed July 22, 1931......... agjaeainx 15 Statement of stipulation re Winkler-Kock. — sie 23 Aman, Mel Mas. 9, TO. oo ini oaks 80 oe ic ie. 23 Statement of stipulation re substitution of parties - ig Ce: cadkheuieaacss nds cenunak. Bee ee ee 37 Amendment to Answer, filed May 11, 1932 Penne Sakae 38 ; Agreed statement as to exhibits. aks ve POR EOE 39 EXCERPTS FROM EVIDENCE ON ‘RES ADJUDICATA ISSUE. : Prawerirr’s Witnesses. Testimony of : a eee 3 Dunham, Robert J., Sr Masaka Vrrerer npeenwaxkes , 39 Hamilton, David Phillip......:........... baccas a: Heil, Henry F............6. Dien s Seton wes sane 42 Meh, Pred Oise vic ccciccssceisess iv dpeauneunas 43° _ --Lamprecht, William Henry, eccect penn’ verre Te 41 Stipulation re expenditures, etc.. Sata: Ware Maa waa . 44 | ‘Derenvant ’s Wirnras. ' Testimony of: oe O’Shaughnessy, I. A. ae TEE PETC eT Ce uae aoa 52 — Motion to dismiss sii and amendments on ‘the - ground of unclean hands, | filed Jan. .). agoee 7. Vol. %, pp. m 1808 to 1803; Vol. Wi pp. 851 to 1082; Vol. pp. 1083 to 1503; Vol. Viiy'pp. sues te seer Pp. 1995 to 3 Vol. BP..2496 to 3084; ABSTRACT OF PROCEEDINGS ON MOTION TO DISMISS_ COMPLAINT FOR UNCLEAN HANDS. Statement by Mr. Von Holst. Tere ere ixekunean 58 Affidavit of J. Bernhard * Thiess (Read in). wrees ve . Colloquy ...... beeen nba t eee ee te gereeeeeees need be 62 Amendment to Answer, filed Jan. 5, 1938......:....:. 66 ‘ Petition for i Duees cue to Behimer, - Samh. G, WEBB. 6 Loi o wc aghc ts camsinsassaanvenezcguc | ~ Petition for Subpoena | Duees Tecum to Plaintiff, filed WD, Thy TEs oa gas 50 h0b5s Ves danhsineeendangs cen 74 . Stipulation re hearings on Subpoenas. Pr eaae Stans tae 77 Interrogatories propounded to Plaintiff, filed Jan. 14, ee ey Ra nee 78 Stipulation re hearing on Tateeciaishontes ereperta: i -Plaintiff’s Answers to Interrogatories............... 80. - Amendment to Answer, filed Feb. 9, 1938...:....... .» @&§8 Motion of Defendant. to a ~~ vane June 2, 1938 Cbocccesevadddusees cb ebdededstedsedencoasees 81. 28, 1938 . oe Pereveriey seeeeee Te © _ STATEMENT OF EVIDENCE ON ISSUE OF | UNCLEAN HANDS. Cnet 5 iiiesiscans Fecscccerececene ik Geeaaa . 283, 367 Derenpant’s WITNESSES. Testimony of: payer Behimer, Otto ..... Pree Pry e weer Vy oe ee 290 . Beyt, Maurice S...... Bere eee tn re 347 Brunow, G. H.......... 4h 6a can ens ean I NS cca tes ctes olen ayeueel 100 Dearborn, Richard J. (Deposition a ahead a ae 182 Vol. I, pp. 1 to 580; Vol. I, pp. 651. 6° 1088; Wol., 1 Epp. 1003 to 1503; Vol. IV. ve 1506 to 1983; S ooee 1995 to vem Voi, 2495 to .7e. A. 3 » Pp. PP. = Wok WEE, ee ee ot | iii Egeler, i Nhe a aN inet wun es 168 ea ha kk cea Spache bah abd ¥Sd0 ess 105 Murray, R. L....:... POST PEPE OTT Eee OPES PIE 176 Ringolsky, I. J....... EPR Ee FT OO 85 Stratford, William. Malcolm (Deposition of)... é. 243 Thompson, Lloyd H................seeeeeeeeees 170 Wannack, RE Ae et eee wee 249 Id oils dank a cidawacdisieeeassncie ee . White, G. D..:....... OE POE Pe REC he RT RY « 135 Piaintirr’s WITNESSES. Testimony of : ; 2 ee Behbreus, W. Meredith. EES I ORIN ve dancese wee Dubbs, Carbon P............. akiaes ais davekixins 391. Dunham, Robert J., Sr ere ‘neneans re a... 440 Halle, Hiram J...... es a akan. anaes X aca Se Hoffman, Dr. Harry R.......:....... ceeieaki :. 456 Norbary, Dr. Frank Garm. .. “php a SS 4 -1717 521A—Agreement between, U. O. P. and oe oe Roxana, dated Dec. 12, 1919........ “4- 1734 © 521B—-Agreement between U. 0. P. and a acal y Roxana, dated Dec. 22, 1919...... ee 4 1737 Vol 1 to 550; Vol. Pp. 581 to 1082; Vol. Pp. 1023 to 1503; Vol. IV, Sees to seer. Vol. V, pp. 1995 to 3 Vol. PP. 2495 to 3084; 521C—Abstract of agreement between | U..0. P. and DeBataafsche Pet. Co., ee ebsieen yeeees ruse At OS at Roxana bbs suctEbsedseneds deceu gly of Dubbs flashing —Photographs of Dubbs ogre . aa 1, Standard of California . 559 4 1767 552—Excerpts from Certified copy a: File Wrapper of Halloran & Strout application, Serial No. 176,990 (now Patent 2,070,124) ...........60000. 2 560 4 1771 566—Notice of Suit filed Jan. 26, 1926, eee omerars = secesessgecoes 4 1789 > - _567—Notice of commencement of action, of Jan. 28, 1926, U. O. P. v. Standard | 5} eee atvodeds 568—Notice of suit filed April 11, 1930, - U. O, P. v. Standard of N. J.....6... 569- ; P plication No. 144 979 eadeveseccnves eee ae DEFENDANT’S EXHIBITS. a (Abstract) List of ‘patent in- ° 163 a-m fringement suits by Uni-. 164 > versal against usefs of - 13ak | Winkler-Koch stills, who ane 1748-4 ) contributed to defense fund 5 1995 -175—Excerpts from Texas Company re employee efficiency — for Be- I ae SEE eee 1 183 5 1997 176—Excerpts, from certified copy of File Wrapper of Behimer Appl. 263,562, Patent 2,027,014 .......... 1 183 5 2001. Vol. I, pp. 1 to 850; Vol. tI, pp. 551 to 1028; Vol. ee Vel. Iv, 1898 to 1993; 23; Vol. V, 5 one eee Voi, vel. De. to 3567 DP. : PP. 2495 to —— - Described or , “Testimony Exhibits Vol. Page Vel. Page 177—Excerpts from certified ‘copy .of File Wrapper of; Behimer patent . a 1,883,850 Ane GRE sa vncaseca 1 184 5 2008 178—Excerpts from certified copy of File Wrapper of Interference No. 49,355 entitled ‘‘Dubbs’ v. Holmes, Manley and Behimer’’ ............ 1 184 5 2052 179—Excerpts from certified copy of File Wrapper of Interference ‘No. _ } GND iin Win ce iets eec iene 1 184 5 2118 -180—Behimer’s letter of Resignation , | to Texas Co., Aug. 24,1927 ...... 1 185 _ 181—Letter, Holmes to Behimer, Aug. | We a accuses: peekisucoe eats 1. 186 182—Letter Behimer to Holmes, Sept. OO, 1987 amd: heck ........0.ic0500- 1 188 183—Letter,, Dearborn to Behimer, Oct. 3, 1927 .......2..--6. sin hade bs 1 188. 184—Letter, Dearborn to Behimer, Oct. Be EE cuig hn 6.0 Madu CEA Eee taeee 1 190 -184A—Copy of - Behimer’s s Contract with Texas Co., dated“December 15, - SESE PAST dex Dorner ry > Mm. :: . 185—Letter, C. M* Thomas to Dear: ~ . : born, Oct. 22, 1927 .....:.......0.. 1 192 .186—Letter, Dearborn to es Oct. eal WR OO ones cn prninsee ) | ' 208—Excerpts from File No. 2, Inter- Company correspondence of. the « Texas Company, re Behimer ....... _ #& oe 209-—Letter, Dec. 5, 1927, Stratford to . Ge Se See eee *§ 2236 210 for ident.—Letter, how. 1, 1927, ) Stratford to Dearborn PEPE See 1 -.244 . 5 - 2239. 211—Letter, Sept. 10, 1926, Stratford | I icc ciavacuekaxscsee “1 246 212—Affidavit. of G. H. Von. wehitttite dated Mar. 11, 1926 . ewe ey 5 2241 - 213—Letter, sent. from Clark Hotel | Los Angeles, to “Dear Harry,”’ u signed, Oct. 23, 1926 .....:..:.-... 1 256 5 2246 © VoL Z, pp..1 to 880; Wol. x2, pp. 651° to 1088; ‘1083 to 1803; Vol. IV, pp. 1508 to 1993: Vol. V, pp. 1606 to sees: Vol. TE, 9. 2495 to 2004; Vo}, Vit bp. s0es to aser, Vel. or od in Page Vel. Page - 214—Letter, undated, sent from Rich Hotel, Houston, to ‘‘Dear Friend Harry,”’ unsigned ...............% ki 215—List of employees of The Texas Company given by Wannack to SET -s o0nscosdsonshensaduace saa 216—List of Texas Company refinery operators oven. - Kaufman to White 2.5.0... ccecccenscccceseceds Beyt, unsigned. peveussueudhuseeiees ‘* | Beyt, ee ere, a a 219—Affidavit prepared — for iiatioe Beyt, unsigned ................. a 220—Abstract of Bill of Complaint and . Answer, and Amendment to Answer | in Universal Oil Products Co. ‘v. Dickey Refg. Co. (Equity No. 822-N) 1 221—Letter, Nov. 30, 1926, Fantz to WE dcacuctcudedeeuscuccbineerts 1 SE P56 cWagnWewiecdamnceehac: 1 WE Gos ed cW edocs duceewcues exe 1 224—Telegram, July 17, 1927, C. P. Dubbs to Robert J. Dunham....... “e 225—Telegram, July 17, 1927, C. P. Dubbs to Robert J. Dunham........ 1 5 2260" Vow f, 1 to 850; Vol. IZ, pp. 561 to 1082; Vol. Zrz, Vol. Iv, pp. 1808 to 1988; Vol. ¥. 1 BP. 1995 to 9683; Vol. VI, Vol. VIZ, pp. 3085 to ser. 227—Office Record Copy of Telegram, July 18, 1927, R. G. Danielson to L. H. Thompson .........--++s+e0-00% Dubbs to R. J. Dunham: 4 ealgah euie 229—Telesram, July 21, 1927, Reich- mans to C. P. Dubbs..... PIP 230—Telegram, July 22, 1927, A. F. Reichmann to C. P. Dubbs.......... 231—Photostat of. contract between Universal Oil Products Company and Otto Behimer, dated Aug. 20, 1927.. 232—Agreement between Otto Behimer and Universal Oil - Products. Co., = dated Nov. 16, 1927 Pe Wa mhadae 233—Letter, Nov. 16, 1927, R. J. Dun- ham to Otto Behimer...........-.-- 234—-Wannack Expense senisineiile (51 pages) for 1925 and is éctecs: rh e 235—Wannack Expense item dated TE. ot cclewsccepnacesen “of Universal v. Texas mpany and Universal v. Standard Oi Company (Ind.) in-1996 and 1927....\, Ree 1 414 §& 2355 246—Telegrams (15) from “Cal”? to M. Egeler and telegram from. C. Smith to Dubbs, Feb. to Sept. 1926... 1 431 5 2356 247—Telegram, Aug. 3, 1925, Wannack \ to Egeler; Telegram, Nov. 17, 1925, Wannack to Egeler; Telegram, ‘Jan. io 18, 1926, ‘‘W’’ to Egeler; Letter;— ye _ Aug. 3, 1926, Wannack to. Egeler; F Note, Oct. 16, 1926, ae to ‘‘Dear " i * EE? nw cccccccccecececcccccecooss ' . 5). 2360 248—Affidavit of C.-P. Dubbs, Dec. 2 reierk. % RF. ...4 inshngenanniebinenswaaeis oe sr. 249--Letters and | telegrams between Dubbs and Wannack, vues, 1925 to WI os fics ose rd Sak es 5e: 5.2361 Vol I, pp. a® ; Ve ne Sees ee ere Pep. 1998 to 9463; Vol. Pp. 2495 to 3084; aS "Described or - Reproducedl Mites | Reproduced in in Book of Vel. Page Vol. Page - 307—-Settlement agreement as of Apr. 1, 1939 (typewritten) between Uni- . | _- versal and Root Petroleum Co....... 5 2376 308—Supplemental: letter, Jan. 25, | 1939, signed by Universal and Root . - Petroleum Co. modifying Paragraph ee cs hin chit xtiiasac.. 5 2381 311—Letter, Jan. - 26, 1939, Rost i es Petroleum Co. to Thiess............-. —=&§ «2383 525—Pyzel patent Tt 7 .3436 526—Jesse A. Dubbs patent 1,123,502. 7 3174 527—Trumble patent 1,281,884..... eg . 7 38286 528—Pyzel patent 1,506,444.......... 7 3424 529—Pyzel patent 1,891,218..........° 7 3506 530—Pyzel patent 1,622,737.......... 7 3444 " .. §54—Hanna patent 1,449,226......... a 7 3394 555—Hanna patent 1 449,227... eer °. 7 3402 : 556—Drawings of Richmond (Hanna) | ae Presstire Still .:..'............0020: 2 568 , 557—Dra ing of: Halloran. and Strout Still, dated Aug. 30, 1923............ 2 570 558—Drawing of Halloran and Strout apne ‘Still, dated Jan. 22,1924.......... .. 2 570 559—Flow sheet of proposed modified ‘Richmond (Halloran and Strout) ‘-ehacking process, dated March ie ME Suba und basasatosesoe ss oeeeese 2 578 5 2385 “ 561—Hanna patent.1,655,603........... 7. 7 3462 - WoL %, pp. 1 to 580; Wol. £1, pp. 551 to 1042; Vol. IIZ, pp. 1023 to Vol. IV, pp. 1505 to 1993: Vol. V, Dp. 1995 to 2493; Vol. Wi, pp. 2490 to 3084; Vol. Vii. pp. 3085 to 3567. xxii (Dubbs furnace) ..... Memon é eeeeee 2 692 _ (Dubbs farnace) ........... Thiet, 2 592 June 1926 ....... sdteataliindin Chee’ 582 Bem. 21988 oc ccccevcccees A Se 588—Defendant’s request for admis- 7 ’ gion of getiuineness of documents. . _ §& 2387 589-—Plaintiff’s answer to request ‘ee : admission of genuineness of docn- MORES ccc cece ccccercnecscccces 5 1924-25 owe eee eee e eee eeeeeees 2 63 5 GS hn tok GUN Ss ch SKN es cp 2 6% 593—Hnuff Patent 1,638,735........... 595—Huff Patent 1,937,959.......... 7 596—Huff Patent -2,039,797.......... 599—Patent application A (Homes, anley &- Behimer), delivered to esbitt by Mackenzie to be forwarded DE ic danecanvavascssdeanaeedens 3 1023 600—Excerpt from letter, Mackenzie to Nesbitt, March 22, 1918... voéece eeeee 3 1023 601—Telegram, Mackenzie to Holmes, March 23, 1918..:....... Cheek eees 2392 2393 1925-26 ...... sis caieiltaxdies vecse 2 625 5 2395 2401 3450 a a ou : Cee bee ape te et va a = . Pege = (Vel. 602—Excerpt from Totter, Mackensio. i? to Holmes, Apr. 27, 1918........... 3 1027 603—Excerpt from letter, Mackenzie to Nesbitt, May 3, 1918......:........ 3 1028 604—Letter, Nesbitt to Foster, Free- - mah, Watson and Coit, May 4,1918.. 3 1028 5 2414 605—Letter, Coit to Nesbitt, May 6, Rechts ackuaaindddcaeseoese 3 1028 5 2414 606—Letter, Mackenzie to Coit, May 9 = WT nedhbctnaknbengsedidondtecser 3 1028 607—Letter, Coit to een, May Pe ee acdccecescOcnctestomccpese 3 1028 608—Letter, Mackenzie to Holmes, May PE Silat nsec desdheseacdec« 2 979 hai 3 1028 609—Excerpt from letter, Coit to Nes- ~ bitt, June 3,.1918................... 3 1029 610—Excerpts from letter, Nesbitt to Coit, June 13, 1918 (Mackenzie’s GUND sccccctucccdccccvcdcccszovcs 3 1029 611—Letter, Coit to Nesbitt, June 15, , Di Gcntitesnteivibpahtaneweeedenhes 3 1030 : 612—Letter, Nesbit to Holmes, July. 23, 1918, and attached copy of letter from Coit to er dated J uly 22, i bicnipbadabeisedesaneventens 3 1031 Bee TED ccccctcccccasqcccccesscece “3 1031 614—Excerpts from letter, Mackenzie to Holmes, Sept. 9, 1918............ 3 1033 Vol 2 pp. 1 to 550; Vol x. pp. soy ‘1082; Vol. “pp. 1083 to 1803; Vol. EV. yp. 1506 to. 1983: Vol. W. pp. } 995 to 9483; Vol. PP. 9495 to 2084; Vol. VI, pp. 3085 to S547. ‘ xxiv. ‘ Fe ‘ ; ae ; - De cribed or Reproduced ; in in Book of - Vel. Page Vel. Page &15—Letter, Thomas _ to "“Madcenaa, : Sept. 13, 1918, enclosing letter from ‘ Coit, dated Sept. 11, eae cute Mie 616-Letter, Mackenzie" to Thomas,’ | Sept. 24, 1918 ..... ee cckhbiveaw kes 3 1034. 617—Letter, Mackenzie to Holmes, | Oct. 1, ses Pere eT re . 3 1034 618—Letter, Mackenzie to Van Gundy, ; NR Te: BOR ss 5 vans cecddgecceetines 3 - 1035 619—Letter, Tan Gundy to Mackenzie, a. + SS weer ie eee aie’ 3 1035_ . 620—Letter, Behimer to Mackenzie, Pie eS eee Cais beeen "2 -915 ae aa me ues ie 3 1035 621—Letter, Mackenzie to Holmes, ag ee Sh Se EE 0 6k ko hedss cccawncs w+» 8 10386 5 2415 -622—Letter, Mackenzie to Thomas, : | ° Nov. 18, DE ante sa wees inntes sends 3 1036 623A—Flow diagram by De Florez, of | | operation at Bayonne (Hall Process) 2 847 5 2417 626-—Excerpt from report, Mackenzie — a s to Holmes, Feb. 28, 1917, Runs 12 to | a 24 of Hall Process....... Se huewenee 2 853 — ; eee Se 627—Report, Mackenzie to Holmes, ' ” April 12, 1917, Runs 25, 26, 34 and 33 4 1044 5 2419 628—Exeerpts from final report on | _ Hall Process, May 9, 1917: ore ae 6 phages from report on Hall Proc- | ; Mackenzie to Holmes, May 7, : | 1917 eee Dyin ewes ae euce wha 3 1045 - on to ee e to to Vol, pp. ! . 551 to 1082; Vol. 1023 to 1503; | wol. FW. pp. 1806 to 1983; Vol. V pp. 1995 to 2493; Wol. WE, pp. 9495 to 3004; Described or Reproduced in in Book of Exhibits - ‘ Vol. Page Vol. Page : : 630—xcerpt fr from cepaet on » Hall, Pree. - ess; Mackenzie to ow ad 29, - OU Seip rite ae tec bates, 3 1040 632—Excerpt f rom report, Mackenzie to Holmes, Oct. 17,1917, Summary of . _ Runs 101 to 109 on Hall Process.... 3 1040 634—Report, Mackenzie to Holmes, ’ Oct. 26, 1917, on Hall Process ...... 3 "a 1042 5 2436 635—Report, Mackenzie to Holmes, EMORY Jan. 17, 1918, Summary of October, | November and December operations at Bayonne on Hall Process ........3 1042 5 2444: —641—Cady drawing of apparatus to ‘or: demoustrate vapor pressure ies +. 2 792 5 2449 642—Cady curve of vapor pressure of ay ME ooh el ashen eeidipeucibedauses 2 793 5 2451 644—Cady photograph of column of : bide a Swedes ans acne 2 882 5. 2473 | 667—Photostat of blue print from orig- © ‘inal tracing 1648 showing coil and’ drum Experiment 8, with marks by . Behimer (See DX 754) ............ 2° 883 5 2475 - 667A—Enlargement’ of box title of DX 667, showing date of Nov. 6, 1916.... 2 883 5 2477 668—Photostats (front and rear) of blue print from tracing Y- 1703, dated: Dec. 7, 1916 ...... ee aeaiak 6 2 88 5 2479 669—Photostat of tracing Y-1703 as re- : Pe vised, dated Jan. 29, 1917.......... 2 885° 5 2483 670—Letter, Mar. 23, 1917, Detwiler to , Mambey 0.65.0: 0sccevereceeseies 2 1008" 671—Sketch #15 for jet pump No. 1 for’ | a Experiment 6 .......2.....0068 :... 2 886-5 2485 672—Test data on jet pump, dated ene 2 886 5 2487 €73A—Earnest drawing No. 23 (page | “t, 1) of apparatus erected in coil and . drum Experiment 8 ............... 2 .887 5 2489 673B—Earnest drawing: No. 23 (Page : . 2) of apparatus erected in coil and drum Experiment 8 ............... 2 887 5, 2491 674—Group of textbook excerpts, re PAG vaporization .......... whe Saawex os ; 5 2493 ol ta aPP adel nl Sac Ful wp ted ts sal Sus? By, Sis 8 BSE PP- ° PP. s Vo PP. 2495 to 3084; Vol. VIZ, pp. 3085 to 3567. : 675—Behimer’ sf ractioning equipment = eer tt ore rere 2 892 6 2495 675A—Behimer’s vondenser ‘for frac- tionators (Sketch #9) ......:..... 2 892 6 2497 676—Records of Run 6, Experiment 8 . (coil and drum) ............ Tebwe'es 2 896 6 2499 | nah eee of Run 7, Experiment 8 : _- (coil and drum) TTT Te Te ree 2 900 6 2539 678—Records of Run 8, Experimental 8 - a (coil and drum) Sakae caankeeneen as 2 900 6 2559 679—Records of Run 9, Experimental 5 | a (coil and drum) ...':...........5. 2 900 6 2579 680—Behimer’s distillation note book 2 902 6 2615. 681—Behimer’ 8 permanent record book _ pages for Runs 6-9....... Vuseuntans 2 +902 | 682—Behimer’s index cards for ae on Experiment 8 ..... aissbsceahenenas 2 902 683—Excerpt of letter, June 27, 1917, Manley to Detwiler ............... 2 904 - 684—Excerpt of letter, Aug. 14, 1917, Manley to Detwiler ...:........... 2 908 685—Behimer’s sketch - of proposed _ semi-commercial appartus TTC. ae 686—Drawing Y-2200 of proposed semi- commercial “apparatus, dated ' Sept. 24, 1917 err “ukeues erento ua 3: 687—Letter, Nov. 5, 1917; Dawson to Bailey, with enclosed letter, Nov. 1, | 1917, Collings‘to Dawson .......... 2 911 -6 2643 6 2639 6 2641 i Tbe yee bos te ibe, Vol Wi pp. 551 to 1022; Wol. pp. 1023 to 1603; . Ved. SV, Oe 1088 So 1eee 90 Pp. 1995 to 2493; Vol, PP. 2495 to 3084; Vol. VII, pp. 3085 to 3567, in in Book of Ver Fess, Va Page 668—Excerpt from letter, Behimer me Vs Bailey, Nov: SP errr yee rer 2 911 689—Letter, Bailey to Behimer, Nov. mas rn Meee eee 2 912 -6 2644 ma 690-—Hxcerpt from letter, Manley to. + (is we TR WORE civic vs cdanses 2 912 691—Letter, Bailey to Dawson, Dee. er NE TT Tee TTT ITT Terres 2-.912:. 6 2645, 692—Letter, Risdon to Bailey, Jan. 3, ; OO fn EN 00 as sighs dates cadbanens 2 912 6 2646 - (693—Drawing Y-2282; incomplete Hartzler drawing-of proposed coil \ and drum semi-commereial apparatus 2. 912 6 2649 - 694—Donaldson’s ‘working copy of _ Behimer . patent application _ draft). .... Perret rrr LiRiw dean 914 695—Tracing U-2310 for patent speci- — | | fication, dated Jan. 4, 1918 ...... 10 2-914 6 2661. 696—Certified copy of Holmes, Manley aD _ & Behimer application No. 263,562, | . Pe gtr epee Cpe ree erry ame 6 2653 -697—Drawing p. 169, dated Dec. .24, 1917, showing Batteries 2 ‘and 3. of 34 Experiment _ Sr very er ee 2 915 6 2671 698—Drawing of heating coil of Bat- tery 3, dated July'2, 1918 .......... 2 915 -699—Letter, Risdon od hasta June 18; | \ A cece evRdG cat has back dhactd en 2 915 6. 2673 yal baa dado as seo ened Sn ea Wp - Described or ia in Beok of estimony Exhibits 700—Letter, Vilter Mig. Co. to Texas Olin AR We BO onc eeasssareecs +. 2 916 701—Excerpt fi rom letter, Behimer. to Manley, Sept. 13, SE kas aueceusas -2 916 703—Letter, Capen to Schutte-Koert- Bees Ws SE a Cb akeaneaekdecas 2 917 6 2675 704—Letter, Schutte-Koerting to Texas i Se Co.,: Des. 3, I088: 6.05 cieeas’ hgetave 2 917 6 2675 705—-Excerpts from Ru shevata of Run 5, Battery 3, Experiment 18, dated — aes . Dec. 9-14, 1918 ........... iketewen 2.917 6 2677 . 706—Excerpts from report on eile | 2, Run 14 (with preheater coil), dated | eee Dee. 14-23, 1918 ..... nk Gaede ---- 2 919 6 2680 707—Excerpts from report: on Run 7, ai Battery 3, Experiment 18; dated Jan. 11-13,.1919 ..... Niky S. 2 6 Oe 708—Excerpts from report on Run 8, Battery. 3, Experiment 18, . dated : Feb. 25-27, 108. 5. 20: (Awa eae ee Ans 2 919 6 2688 - 709—Drawing H-405—Alterations to | oA we batteries 1‘and 2 (making a four-still battery), dated Dec. 4, 1918........ 2 920 6 2691 710A—Letter, Miller (Hancock Inspira- tor Co.) to Behimer, Mar. 29, 1919 2 920 6 2693 710B—Letter,-Behimer to Hancock In- : spirator Co., April 21, 1919........ 2 921 6 2697. 710C—Letter, ‘Berthold (Hancock) to. ie anhe) Ps _ ' Behimer, May 6, 1919 seaesecsevned 2 921 6° 2698 — Vout pp. 3 to, 690; Vol i yp. 681 v0 1082, Vou DP. 1083 to. 1503; Vol. IV, pp. 1505 to 1993; Vol. V, pp. 1995 to 2483; Vol. Wi, pp. 2495 to 3084; Vol. VIZ, pp. 3085 to 3867. ee Yaead xxxi in Book of tn te rin Vel. Page Vel. Page 7 = ¥ from letter, Manley to _ Behimer, May 20, 1919........ a a. oo 711—Excerpts. from Run 3, Battery 4, | Experiment 18, April 26, 1919...... 2 921 6 2699 _712—Letter, Behimer to. Holmes, Dec. EL rn, = I Raa tee pe eenee 2 924 713—Letter, Holmés to Bebimer, Dec. , ss dia ca viscncan anes 2 924 ; ‘je X-3595A of preheater and economizer of Experiment 11B, dated April 3,.1920........... ceases 2 925 715—Drawing ‘Y-3619A—Apparatus of . Experiment 118, dated April 38, ; ane Giawieias Koch aan ass boxe xi 6 2705 - 716—Behimer’s notations; re jets #6 7 and #7 for Experiment 11B, tested — BORO Be, Tees en escccnes baeaueae 2 925- 717A—Letter, Behimer to Am. eens Pump, Feb. 19, en a, 2 925 717B—Letter, Am. Steam Pump ra | Texas Co., Feb. 25, 1920.:..:...... 2 . 925 718A—Letter, Behimer to W. E. Quim- > by, Inc., Mar. 3, OR ;: eS 718B—Letter, W. $. Quimby, Ine., to — aoe Texas Co., Mar. 13, Ds «iss 00 .. 2° 926 719A—Letter, dimer to Obie -In- .: jector Co., May 20, 1920........... 2 926 719B—Letter, ‘Ohio’ Injector. Co, to. ‘Behimer, May 25, 1920...:........ 2 926 ' ‘WoL Z, pp. 1 to 580; Wol: 2%, pp. 551 to 1022; Vol. pp. to 1503; -_ Jeb Tu, vo. 1506 00 10a Vel. Wr bn 1908 te sada; Wot PD. 2495 to 3084; Reproduced — 720—Blueprint. ‘of tracing Y-4422 of _ centrifugal pump, dated Mar. 8, 1920 2 926 721A—Drawing of Parish rotary pump, marked “——_ eee 2 927 721B—Drawing of plunger type pump, marked “9D 2.56. .ccsevewecccece 2 927 - 722A—Letter; Bender to Behimer, Sh Te Fess cece asccecsabonses 2. 927 722B—Letter, Behimer to Bender, Si Ts ee ecttabsncane bewnuie 2 927 723—Drawing Z-4346, showing hori- . --gontal, double acting, plunger type pump, dated Mar. 4, 1921......:... 2 927. 6 2707 an Dow Pump Co. to Texas ad - Co., Mar. 23, 1921....... pesheunaan 2 927 6 2709 _725—Behimer notegram to Capen, ) April 9, 1921...... sashadbatedsenes 2 928 6 2713 726—Notegram, Behimer to a : o BE Ey, MENS Se Boe svsecdescsvscces 6 2713 727—Notegram, Behimer to Dodge, gone hs BO B, FER. ccccces ‘seestbeadiceta 2 928 6 2717 . 728—Drawing X-4644, Surge art ‘dated May 28, 1921..............:. 2 928 6 2719 729—Flow diagram of original com- ’. mercial batteries of the Texas Co. — started March 1920:.............:. 2 929 6 2721 730—Drawing - Y-4630 dated May 21, 1921, showing Battery 14 — Surge , Uo cccgecicagcacseccs'sccewe ~—. ae oo, ann Described or in in Book of “Vel. — Vol. Page , 731—Drawing Y-4871, showing modi-— fied Surge pump eteatien, dated eon Be We Mews vind coxcsdassteaice 2 ‘930 6 2725 | 732—F low diagram of Run 63, Battery 14, using Surge pump return of re- flux to the coil; Oct. 31, 1921 to ee Re ere piweeK ens 2. 931 6 2727 — 733—Tracing record of trssing Y-1703 2 987 6 2729. _ 734 for idént.—Behimer’s statement to the Texas Co. in 1996:..:........-. 2 952 6. 2731. 735—Excerpt from - letter, Alther to Backus, Oct. 23, 1924.............. 2 837 186—Excorpte from letter, Bergman to. Hoff. Mar. 19; 1925....... Vaseseeens -2 737—Excerpt from letter, Bergman to ae EB OR eee 2 .738—Distillation report of Dubbs resi- 739—Distillation ie. of’ Dubbs charging stock .......... frretetens 2 740—Distillation report of, Dubbs resi- due from Unit ee Aer = SLAs 2 745 for- -ident. —Exce! from aw . Behimer to Dodge, Mar. 21, 1924.... 2 953 746A- O—Photographis of Bayo nne ap- — a - paratus for Hall Process..... eee 2 -850 6 2749 838 839 Mr -wiichoue pehocs shee shbe sun ede¥ee 2 840° R40) 840 747—-Log sheets of Run 24 at Bayonne-~ ;. (See Summary, DX 850)-~....... : 2 853 Vol I, pp. 1 to 550; Vol PP. 551 to 1083; ; Vol. IV, pp. 1505 to 1993: Vol. V, pp. 1995 to 2483; Vol. Wi, pp. 2495 to 3064; Vol. VIZ, pp. 3085 to 3567. Hibs . _ Xxxiv Vc~ YEE, pp. 3085 to ey Sas Vol. Page Vol. Page 750—Excerpts from De Forez article .- (1923) in ‘‘The Refiner and Na-. . tional Gasoline Manufacturer”’ Mag- | WR pestccctcscteoas ok Some 22 («857 - i. 751—Excerpts fron: De Florez article ° in. “National Petroleum News,”’ : | , | MOREE: ais ixicee Skexes Gea baawi 2 859 752—Tracing record of Drawing Y-1648 2 986 6 2779 753—Blueprint of tracing Y-1648 (Bur-. Ss ton stills layout), dated Jan. 29,1917 2 986 754—Smith’s recopy of. original trac- 7 * ing 1648 }(See DX-667).....:...... 2 986 6 2781 755—Donaldson’s blueprint #11955 . fie Obs x tracing 1703-Y (See DX 668, 669)... 2. 999 6 2783 756—Letter, Donaldson to eee | ‘Feb. 2, 1918, with attached .applica-_ | SK necvaskcaensvans Abb ekvanweeeas ‘ee ee lie ed eee 2 1000-.6 2785 757—Excerpt from letter, Donaldson | to Holmes, Jan. 22, 1918 ..... Suicee 971 . , J 2 1001 758—Letter, Holmes to Manley, * May att ae a | PR te died - | - 6 2795 759—Letter, (enclosures omitted) Det: ~ wiled to Manley, June 20, 1917 (See Seat ab 2 BBP 2 903 6 2796 760—Thompson ; Patent 1,250,050 vert 7 , 3254 . - 761—Letter, Holmes to Manley, Jan. af Oe ee rg sae Miebandsarue vena, 2 971.6 2800° 762—Telegram, Holmes’ to . Manley, 3 | Ph eC eric dae Mes 2 972 6 2803 CRE TT LTT BM 8 ae ond 774-A) —Flow diagram of Defendant’s or Reproduced | _———-* in Book of | ‘ estimony Exhibits ‘ Vol. Page Vol. Page 763—Letter, ‘Neate to Holmes, ‘Feb. 2, 1D1S 2.0. Koonce eres ence ees ees » 2 972 764—Letter, Holmes to Lufkin, March ae . | | ee Ledashueec cae iaiens 2 972 . 765—Letter, Donaldson.to » Manley, Feb. -: — seeeeeeioe, ap ere 2 1002 769—Detwiler™ memorandum, Novem: veers ber 29, 1916, re secrecy...-.... weee 2 1006 972 —Perspective drawing of. ~Dubbs : ae? cee 773 patent 1,392,629 ......:..... 3 1072) «6 «2805 774 - operation at Lemont, IH., : prepared by H. V. Smith....3° 1115 6 2807 775--Photograph of Defendant’ 8 plant ; ; at Lemeént, Ty 2.0. . 0.06. ecu tia. 31115 6 2809 776—Brown’s vapor pressure chart in .the Root case, with marks by H. V. pic sdistsSebancesaniins ss 3 1134. 6. 2811 777—Sketch of Jenkins still, prepared eae by H..V. Smith..... evinackewns aces 3 1139 6 2813 778—Drawing of coil: distillation. ap- ; a | paratus, prepared by Reiman.:.... 3 1179 © 6 2815 779—Atwood Patent’ 28,448.......... | 7: 8110 780—Simplified drawing of Atwood — ee Patent, prepared by Reiman..... .. 3 1184 6 2817 781—Merrill Reissue patent 7,096. . : 7° 3105 782—Dewar and Redwood aliuit + 419,937, ......... renee peek cane? ~ 7 3122 -783—Burton patent 1,105,961........° °. ° 7 3164 Ra ee ee EE 3085 to 3567. a Deecr toed tm Book of = A - 784—Humphreys patent 1,119,700.... - 7 3170 785—Edwards patent. 1,170,884.......- 7 3182 ' 786—Smith patent 1,239,423..... re 7 3224 787—Benton (Br.) patent 1,922 of 1887 . 7 _ 3527 788—Pielsticker (Br.) patent. 6,466 of a ban wedetabucscaneee 7 3545 . 789—Pielsticker os patent 1,706 of MEL. of the Dubbs still as operated at Ladependene, you were asked whether you remein- how-much gasoline was in the charging’ stock, and you said, ‘I. wasn’t yery much interested, really, in the results of that plant.’ Just what did you mean ‘by your statement that you were not interested in the Ss results of the plant? : “A. Iwas not interested in the results of the plant, ’ as it was built there, because I considered the plant, as being not very well designed, and I was more in- terested in the principle of the process than in the products as they were actually obtained in that par- ticular plant.. “*Q. You mean the mechanical construction was not well designed? ‘“‘A.. The. mechanical construction was not well de- signed. | 595 849 “Q. But did it fully exemplify the process or ‘the principle of the process which afterwards came to be known as the Dub Erceyg: ? or - - §52 Abstract of Testimony on Merits. ‘“‘A. It did... ; ‘*Q. And did it fully exemplify the principle of the. process and the. process which was afterwards a ticed in all of tliese plants, practically all these pl that you have referred to'as Dubbs process? ‘‘A, Yes, it did.’’ The charging stock used at Independence was su posed to be normal gas. oil which would not contain any gasoline. Although I testified that the reflux ra-, ~ tio was high in the Indeperidence- apparatus, I do not. } recall the reflux ratio. - 596 ‘‘Q. You testified on your cross that you were in- terested only in one point of the Dubbs process, What was that point. ‘‘A. That point gvas not returning any. of ” “cracked residué to te cracking coils,’’ 850 Recross Etomination by Mr. Thiess. t 597.. The furnace of PX524 was a furnace which we used _ in our own Trumble converter experiments. That would take it back to about 1915. In the Cross operation, in Roxana in 1921 and 1922, we never mixed in our charging stock to that still any of the distillate that did not come in the gasoline range which we got from our pressure distillate obtained mn 598 the Cross operation. We did it later’on after we m fied the plant by adding some towers to it, which pro- duced various fractions of distillate, those fractions that corresponded more-or less to the quality of the raw material charged to the Cross stills were expéri- mentally added to the’ raw charge. ‘ : The dephlegmating equipment that we used there - was not of the same type we recommended and used on the Dubbs still. The principal difference is that it was just a regular bubble tower equipment. The ef- fect with the bubble tower was a little different because it did not run under the pressure -of the cracking | 599: plant. It was a fractionating plant hook-up. When we were making the synthetic crude in the Cross operation, as we originally operated it before Deposition of Richard-W. Hanna, =~ 553 we put on the dephlegmator, those fractions of, that synthetic crude that were not in the gasoline range but * in the gas oil range were experimented with. We re- turned that to the raw oil storage for our Cross plant. We mixed this gas oil fraction from the synthetic crude with our charging stock and used that expérimentally. | ue in the Cross still when we were operating these _ —-=~~ 951 stills at Roxana dround 1921 and 1922. ae _ *Q, That was when Dubbs and Cross stills: _were both being operated at Roxana? | ‘‘A, Yes, experimentally. . eee “Q. This Cross operation was a widely used proc- _ ess, licensed -by the Gasoline Products Company, wasn’t. | it? ae 7 * a. ae 600 ‘‘A.. It was used in other refineries also. | . .... Q, And that is about the time that you were ex- . perimenting with it in 1921 and 1922 at Roxana, isn’t . that correct? cae Ee eine "i A. As far as I remember, it was used in a few other refineries. It was new at that time.’’ 852 RICHARD W. HANNA:* “514 Roehampton Road, Hillsboro, California. ae Direct Examination by Mr. Hall. 601 I am Vice-President of the’Standard Oil Company 602 of California. I have been associated with the com- , pany since 1911, and my duties have been concerned _ | with the. refining of crude oil, including cracking. — 603 The erude oil refining capacity. of the Standard Oil plants in California approximates 100,000 barrels per day. _ a oe ; - Standard Oil Company of California’s Use of Bur- 604 ton Shell: Stills and Burton-Clark Stills: Cracking - operations to produce gasoline as a primary product began in 1917 in ten Burton shell stills like that shown in PX504. These operations were unsuccessful in that _® Deposition given October 27, 1936. 554 Abstract of Testimony on Merits. the cost of production of gasoline, twenty-five cents per gallon, exceeded our realization of sixteen cents per gallon. The total cycle of the Burton shell was thirty-six to forty-eight hours, of which half was the producing period the balance was for charging the Still, cleaning out the carbon, and starting up. : PX 505A is substantially the Burton-Clark still that 605 we operated for about a:year in 1918 or 1919, to com- _ pare with the Burton sliell. The: Burton-Clark was not a practical commercial operation for us. The total ing the*tubes shell, starting up and shutti 607 ” Whb gebenuee en Gis Minden abe still was 80 and on the Burton-Clark tube still, 105 The ‘on-stream temperature on the: Burton still was 750 to 760° F.,-and on the Burton-Clark tube a _853 little higher. The Standard Oil Cémpany of Cali- fornia had a license to operate the n still ‘and the Burton-Clark still, which included right to ' operate under all of the Texas Company nts. 608 The Hanna Still: After the Burton o tions we attempted to improve the results by a circu- lation unit called the Hanna still. In the Hanna still we circulated yy Mae ony residuum by means of a pump through the heating unit and shell. The arrange- ment of the heating tubes pump and shell are illus- 609 trated in the Halloran and ‘Strout patent No. 1,765,976, PX 532. Thirty-five of these Hanna stills were built P and operated, but were found not commercial. The Modified Richmond Still: The next~develop- 610 ment was to insert baffi.a in the Hanna still in an at- tempt to have less dirty oil go through the cracki coil. This was in 1923, and was called the modi Richmond stil. It is described in the Halloran ‘and Strout patent 1,765,976. The modified Richmond still 611 was a slight improvement over the Hanga operation but was not commercial. % Cost of Experimental Work on Cracking Problems: 612 At this time we had spent upwards of five millions of dollars and employed around two hundred technical men in experimental and laboratory work in an at- ° down. . _” Deposition of Richard W. Hanna. 555 a : tempt to solve our cracking problems. The cost of - thaintaining this laboratory was a million dollars a _ year, and I had the full responsibility. - . License Negotiations Between Standard Oil Com- — pany-of California and Universal Oil Products Com- 613 con Witness was asked what was done after the _ wo ‘on the modified Richmond still, and he answered ' as follows: Y 854 ‘At that point we observed a unit operated at . the Martinez plant of the Shel] Oil Company,.a— Dubbs unit, which we were allowed to visit, and tlhiere - observed absolutely clean cireulation, and we par. diately realized that is what we were after and started to wogk on that line of development.’’ A report of this Dubbs operdtion was made to me and as a result I wrote a letter to Mr..Mason dated — October 4, 1923: . ns “elec 614 PX 533. The following is a portion of this letter: ‘‘In studying over these reports, it would seem to me that we have picked up the following: _ First: Cleanliness is next to godliness. ~=§ Second: That the Dubbs people anticipate us in appreciation of cleanliness. a ird: That circulation can be obtained without the use of a’ ; Fourth: That higher pressures are very desirable. Fifth: That it is questionable whether we have to have gill rings on our heating element. :* : Sixth: That if the maximum degree of cleanliness is 615 maintained, higher furnaee effici can be attained.’’- 616 PX 534: This is a report which Mr. Hamilton made to me on the Dubbs operation at Martinez. (Abstract of Exhibit): The unit: is described in some detail and the conditions of operation are stated, including temperature, pressure, operating time, and quantities of feed and products. A tentative estimate . of costs is given. - he 617 PX 535 is a report from Hamilton to me giving the ~ heat demands of the Dubbs cracking stills, and refers ’ to a blueprint: . ; , . PX 536, which shows Mr. Hamilton’s proposal of an additional baffle in the Hanna still. = - - 855 After our inspection of the Dubbs unit at Mar- 618 tinez, we started to modify the Richmond stills into 8 Abstract of Testimony on Merits. clean circulation units, but this work was arrested by the issuance, in March 1925, of the Dubbs overhead feed patent No. 1,488,325, PX 537, which disclosed the _ Clean circulation that we had in mind, and we asked our patent attorneys to pass on the matter before wé went any further. As a result of that investigation, Lyon and Lyon, our patent attorneys, brought to our at- ° - tention an edrlier patent, Dubbs 1 392,629, ‘issued Oc- es 621 , 622 ents tober 4, 1921. ° cis 538 is a lotter a Mr. Adams, . employed by our ipany in the capacity of superintendent of pat- Hing to my attention that the Dubbs patent 2,629° is broader in scope than Dubbs 1,488,325, No. - 623 and points out that under our licenses with Indiana we are licensed under ‘‘this Holmes, Manley and Be- himer application which is in interference with Dubbs early and broad patent.’ / 624 627. . Prior to receiving PX 538, I had a meeting with: ~ Adame, Lyon and Lyon, and others, and the control of this patent over what we were doing was pointed ont ‘to me. PX 539 is a letter from Lyon and Lyoii to Mr.. Adams which came to. my attention. A portion of this letter reads as follows: ‘‘The Dubbs patent 1 (488,325 is viel gee hit by Mr. Howard to be of any great importance Th he earlier patent No. 1,392,629 grantéd to Dubbs on October 4, 1921, “is of much greater scope and significance. This . ‘Dubbs patent 1,392,629 discloses and claims quite br oadly’ the first above mentioned sub-type of the | - ‘once-through a *tube and tank’ process: This pat- 856 ent is involved to some extent in interference pro: ceedings that are now pending in the Patent Of- fice with. The Texas Company and possibly others: We are effdeavoring to obtain from the Patent Office any available information concerning this interference, _ the difficulty being that such proceedings are not open - for inspection. This Dubbs: patent 1,392,629 does not ' disclose introducing the new stock into the top of the f ractionating tower or dephlegmator for heat exchange - and condensation purposes. This is the new feature in y This is the Dubbs patent in suit. 629 — — - 632 Deposition of Richard W. Hanna.. . 557 "Dubbs patent 1,488,325 and to which na latter patent is limited.’”” _~ | Our attorneys, Lyon and Leen: gave us an opinion on the validity of the Dubbs 1,392,629 patent and its bearing on the modification of the ‘‘modified Rich- | mond’? still, whereby clean circulation was obtained. We sent for Mr. Halle* who arrived in July of 1924.. We spent several weeks trading and negotiating, and I attempted to get rights under the Dubbs 1,392,629. and 1,488,325 patents for as little.as possible, but Mr. Halle: refused and I finally agreed to a license on Mr. Halle’s regular. basis, which included a license notronly under’ these patents but under others as well. During these negotiations Mr. Halle brought to my attention the Jesse A. Dubbs patent 1,123,502, but é was not interested in that patent or othérs referred * in PX 540 because my only interest was in the 1,392,629 . - and 1,488,325 patents. Asa result of the negotiations with Mr. Halle, the « Standard Oil Company entered into a license ai ment, PX 540: | (Abstract of Exhibit): .The License agreement is - dated August 15, 1924. Universal grants Standard a non-exclusive license under five patents and twenty’ - pending patent applications, and Standard agrees to " pay -a royalty of ‘fifteen cents (15¢) per barrel of oil treated under the license. . Universal gives Standard . the right to use any improvements - acquired by~ .: 857 Universal. Standard’s throughout under the lie), cense is limited to, 200,000 barrels daily. A min’ - - mum royalty of $20,000 annually is provided. Uni- versal agrees to hold Standard harmless against any — infringement of patents owned by, ethers by reason - of. Standard’s practices under’ “a Universal license - 7 and to,defend any suits breug ' ‘PX 541 is an escrow Peis which provided that .the license agreement PX 540 was not to become effec- ° tive until Universal had conducted certain tests w hich ‘met certain quarantees as to the output. _.* Mr. Halle was. and is the President of Universal Oil Products Company. ; 558 Abstract -of Testimony on Merits. — - oes ; a 549 is a supplemental license agreement, dated et 633 Aug. 15, 1924, extending the license agreement, PX. 540, to subsidiaries of the Standard Oil Company of California, providing for autematic reduction in roy- alty’ to equal: that of any more favored licensee, and waiving and releasing al! claims for past infringement. . PX 543 is. an agreement dated August 15, 1924. | _ (Abstract of Exhibit): The agreement enumerates the United States letters patent and applications owned by Standard and refers. to corresponding patents or applications in thirty-three foreign countries. Stand- ard assigns these patents and applications to Uni- versal for a consideration of $4,000,000 reserving od ‘itself and named subsidiaries the right to use the ents. The consideration of $4,000,000 is to be pai in monthly installments in amounts’ equal to twenty-five percent of the total of all payments received by. Uni- versal from Standard for royalties under the license — agreement PX 540, Universal being under no obliga- tion to pay any portion of the sum of $4,000,000 ex- cept out of payments under royalties paid from Stand- — ‘ard to Universal under the license agreement. PX 542 provides that after full payment of the ang: price of the Standard patents, as fixed in PX 543, the fu- ture royalty tate is permanentiy reduced by one-fourth. . 634 PX 544 is an agreement further defining the license agreement. (Abstract of Exhibit) : Standard’s right to “‘im. -provements’’ under the license agreement does: not _. cover chemical or catalytic methods or processes. — 858 PX 545 is an agreement dated August. 15, 1924,. ich excludes ‘certain eharging stock from the royalty payments. . PX 546 is an agreement dated April 27, 1925, which" -> covers a —_— royalty scale based on through- put. - PX 547 is an agreement dated April 30, 1925, which _ states that the computation of the diminishing scale 636 will be based on the combined throughput of the Stand- ard Oil Company on its subsidiaries in the United States. _. PX 548 is an ‘agreetiient dated March 1, 1926, and refers to .a waiver of certain monies’ due under the license agreement, PX 543. Deposition of Richard W. Hanna. | | 559 _ > PX 549 is an agreement dated January 29, 1929, on _ is.an amendment\further diminishing the sliding roy- alty scale: \ Pursuant to these agreements, the license agreement, . PX 540, was put in escrow awaiting the result .of 1. ‘demonstration run. made at the Associated Oil Com- pany plant at Avon, California.. These test runs ful- 637 filled all the requirements of the agreement and the in- | “struments were taken out of escrow and. delivered to. 638 the respective parties in May ,1925. . The Standard Oil Conipany of California thereafter - 639 erected eight Dubbs units at the Richmond plant and — . seven-at the El Segundo plant. PX 550 isa flow dia- - . 640 gram of the first unit built under. the Dubbs license. The dot and dash lines show a ‘‘flashing’’ operation, .. whieh was not part of the Dubbs patent. . The exhibit - shows alternate inethods of operation, but all setups include clean-circulation. The.alternate arrangements - were provided so as to compare the straight Dubbs operation with our improved method of operating Dubbs. PX 551-A and PX 551-B are photographs of - the Dubbs unit shown on the flow diagram,. PX 859 550. - - 641 | Referring to PX 550, the oil was heated in. the tubes in the furnace and discharged into the vertical 642 evaporators. Vapors and gas were discharged from 643.‘the tep of evaporators to the fractionating column. and | then passed.on through the cooler. into .a receiving drum and to storage.: The cracked residuum was re- moved from the bottom of the evaporators and never returned to the heating coil. The vapors in the frac-: tionating column were cooled by the incoming feed and. 644 a portion of the vapors were condensed, forming re- - - flux. The reflux and feed from the bottom of the frac: tionating column were returned to the entrance of the: heating tubes. *. The pressure inaintained throughout the system was 645 270 Ibs., and about the end of 1925 the oil temperature | at the outlet of. the tubes was around 900° F:, i.e., 875-910° F. The charge used was gas oil and the yield | — was 40 to 45 percent of 437° F. endpoint gaso- ine We made no ‘‘non-residuum’” runs because we had : a large fuel oil market. The residuum was made into a commercial fuel oil. 560 + Abstract of Testimony on Merits.- 647 At the conclusion of the demonstration run of the . * Dubbs unit, the modified Richmond installation was sal. | vaged and the Burton shell stills and the Burton-Clark | ; ‘stills were junked. ee | cee ; The runs on the Dubbs-stills-were standardized. to end at six hundred hours for inspection for safety. _ ~~ Such inspection disclosed ‘some carbon in the tubes -but _, hot sufficient to causc a shut-down. Ee | 648 The royalty initially paid amounted to $2,500,000, and, was based on the daily throughput, but sub. 860 seqtently a’ paid-up license was ‘taken. for - - : $3, ,000. = , . 861 The total payment made by the Universal Oil - Products Company in connection with the pur- - Chase-of-the- property that was acquired from the © Standard Oil Company under the agreement, PX-543,— 649 was ‘$600,000, and. not $4,000,000,: as provided by the y agreement, arid nothing further is due under that agreement. We considered, and still consider, that __ we have not received sufficient money for the inven- 650 tion covering the flashing set-up’ which was -sold to ‘Universal under that agreement, which at the time of ' the agreement was in application form. Said applica- tion in the-name of Halloran and Strout was filed ge 21, 1927, serial number 176,990, and forms ‘ oo : ; 862. Cross-Examination by Mr. Thiess. 651. _While I was manager of refineries and superintend- , ent of the Standard Oil Company of California, I was ° 652° acquainted -with and directed the experimental work. '. I was closely acquainted with’ the development work _ that Halloran and Strout were doing. | ‘We. paid $3,000,000 for a paid-up license under the . _Dubbs patents in June 30, 1930, and at that time my company acquired an interest in.the United Gasoline '- . Corporation, which owned: the Universal Oil Products 692 Co. I think that this United Gasoline Corporation . was.created at that time and now owns the Universal Oil Products Co. : ; ; The voting stock of the United Gasoline Corpora- . tion is-new held one-third by Standard of California, © ‘one-sixth by Gulf, and one-half ‘by Shell. ~ LS 654 Our original license agreement with the Standard | e g ae Deposition of Richard W. Hanna. -- Oil. of Indiana was before 1918, and as a result we were in a position. to utilize the-development in the way of patents and patent applications of the Texas , Company. a . ; - 655 In our operation of the Burton stills, which we con- _.._-strneted in 1917, our procedure was to try to take 656 a predetermined percentage” Tethi : | ‘per cent off. of the original gas oil charge. ° We never charged any oil other than gas oil of approximately 26 gravity. There was so much: carbon collected in gas: oil charges that it was obvious that fuel oil would not run at all. It was our opinion that fuel oil in a sly still was a-larger carbon producing stock than gas oil. , cee ihe » 657 863 . The residuum from the Burton stills.was sold as fuel oil after being mixed with our other residuum. We ‘never attempted to distill that resi-—~ duum, to get an additional charging stock for our Bur-- ton stills. The carbon deposited in the Burton shell at the end of a normal run was a very .appreciable - 658 amount.*That was the direct cause of most of the shut- . downs. Ane The charging stock which we used had‘a sulfur -content as low.as we could hold it, This sulfur con- tent gave us-some trouble as to the corrosion of: the _ _- metal of the Burton shell. : 659 As time went by, we reduced our pressure to main- tain a proper factor of safety, from 80 pounds to as - low as 40 pounds. The deterioration of the tensile . strength of the. shell stills was due both to the scrap; ing of the bottom of the shells and corrosion due to the sulfur content in the oil. Both were appreciable. A 660 large part of the deterioration in the fire sheets was - .eaused by the scraping. We had the same corrosion difficulties with all-of the units, including the Dubbs: . stills; until we started chrome plating to protect the iron from the sulfur gases. We did not use. chrome. ° plating on the Burton shell stills. The reduction in 661 pressure to 40 pounds on the Burton stills reduced our yield.’ As we reduced -pressure the hydrocarbons in the shell still would\boil ap into the tower and re- turn, resulting ina ver® great loss of heat. That -materially increased our cost of ‘production which al- ready was high. ' 562 ‘Abstract: of Testimony on Merits. - 662. We operated. these Burton stills about a year. We -opetated at 80 to 95 pounds pressure for at least six months and then had our engineers give us a new working pressure of 40 pounds when we became . frightened. During all this —" the oil temperature was :750-760° rr : 963 864—-In the “Burton-Clark Clark still we ‘used the same charging stock that we used in the Burton shell 664 stills. We did not withdraw residuum during a run. We withdrew the residuum at the end of the run when we shut down and sent it to the fuel tanks. Our regular running method was exactly the same as with the Burton shell. Of course. we‘experiinented on many . runs. This Burton-Clark -till was mostly run on as _ | nearly a commercial operation as we could make it, = —— comparing it- to the Bartow shett-— The temperatures | : and pressures used were slightly higher; that is, 105 ~ pounds pressure and a few degrees higher i in tocnpers- ture. 665. The yield on_ this Burton“Clark still was _a little | higher than our Burton shell.. The Burton-Clark was ~ not commercial because not. profitable, due to low yield, _ low production per dollar investment, —_ cost of op- - eration and short time on-stream. . 666 I know that Burton-Clark stills were being ‘used 667 maniy places, but I don’t know whether.they were prof-_ : itable or successful. I do not think any of he refin- eries in California were using Burton shells, or Bur- . ‘ton-Clark stills. We aimed for a standard run in this ' Burton-Clark still, and mostly we shut down before we had attained our objective of 36 hours on, stream. 668 In the operation of this Burton-Clark still we fed over- - -head during the operation. At the end of the run the carbon was deposited in the tubes and.in the shell of the drum. * - thon as (PX 532). This Halloran and Strout opera- _- tion developed in. the latter part of 1922 and early part of 1923. I was pretty close to this develop- 682 868 .ment and was sufficiently familiar with it so that, ~ at the time the specifications for. the patent for ‘the Halloran and Strout operation were prepared, I _ | aatis believed the statements contained in the- specifi- Re: 682 869 cations to be true and correct. The Halloran and Strout operation was called the modified Rich- . mond-arrangement. = _ After. we had seen the Martinez operation we planned . -683 on switching over from Halloran and Strout. We got out our drawings and our plans, but before we made a move to change them we were licensed under the Dubbs and started from_the ground pp again. We never changed the Halloran-Strout or modified Richmond still, to one in.which we did not return any of the - residuum to the heating tubes. I am not sure whether we closed up one of the baffles at that time, or whether “we were stopped from so by these patents. E 684 It wasa fing! it at Martinez which our organi- zation saw but I never saw it. Our men were over there te observe this unit during just one-run (PX 533); the Hamilton letter of September 8, 1923, is the only report we have on that. This observation was - 685 made just prior to this letter, on ceptemmer 7. In the Root case I testified : ‘Mr. Halloran was our research man. After that communication. was. sent to Mr. Halloran of the re- search and development department, we immediately » ‘started to convert our so-called baffle stills to abso- lutely clean circulation in not returning any of the cracked oils coming from the output of the tubes back into the inlet of the tube, but feeding merely with clean fresh feed and the clean reflux from the tower to the tubes. ‘In comparison with what we have done there- tofore.we found it solved our carbon troubles: I am aay . . Ge soe wane Sas eee ae & 1924. I did investigate the Rittman and felt that it . was not suitable for our We did not-try to use that process. Doctor at that time our chief chemist, investigated it and turned it down as impracticable. 706 Inthe stock that we used, thai had this sulfur 707 710 content, that sulfur content in the stock required in treating a r acid to reduce the sulfur to a stand- ard for ine. It made it more expensive. ’ In the opération of DX which shows the Hanna . or Richmond pressure still, oil was heated i coil in the furnace. The oil was forced through : coil with a centrifugal pump back into a 10x 30 shell. © Gas Ho ype vig oo Pog mo of the i she through the dep ting tower, 873 through the planer,. through the condensers to the receiving house, where pressure was controlled and released, thé — naphtha going to storage. were probably where I have marked ‘‘X."’ The burn- - ers. discharged their flames into a combustion cham- ber, the heating tubes in the furnace being enclosed in a convexion chamber which was divided from the combustion chamber by a bridge wall marked ‘‘Y.’’ This construction with the bridge wall -was utilized in order to protect the tubes from the flamies of the furnace. -At that time we thought. that that was an important consideration in. the cracking operation in the design of the furnace. The connection marked ‘‘Z’’ is the pipe that leads from the bank of tubes in the convection. section to roof tubes marked ‘‘W."’ The arrows show the flow ~ in that direction. - These roof. tubes would be subject to radiant heat in the furnace. As I remember, the purpose of using these radiant 3 in this furnace was for fuel efficiency. ‘This reflux and vapor fetarn line marked: “A,” that is extended — the inside of the shell and 711 ticular construction assisted the operation in that Se ee ee See wee ne i e did not, as a practice, atmospheri-— cally distill ° 714‘ At the end‘ of a run we had a very serious amount © of carbon in the tubes which controlled the length of time we could operate, and also apart was de- posited in the shell. I don’t remember the relative quantities. We set our length of run to the maximum that the carbon deposition in the tubes would permit, that is, we ran these stills until we got hot spots. _ We attempted to run for a certain length of time. Invariably hot spots started to appear earlier than that, but if we thought the hot spots were not so * serious as to cause a tube rupture, we might have continued occasionally, and did continue until the standard time had ela If the fireman and shift * foreman thought the hot spot was serious the author- ity to’shut down was left in their hands. 717 875 1921 to 1923 substantially covers the length. of | time that the Hanna stills were operated. 721 .The commercial operation of the Richmond stills ~ ee = + 370 Abstract of Testimony on Merits, ‘of PX 556 was not exactly as.good as theexperimental because we probably took more chances, and did not need to‘ have so much oil under pressure and témpera- “ ture and consequently went beyond. what would be a _ . safer condition in the larger units. 3 I don’t recall whether in our experimental work, we used that feed and reflux line which has been iden- tified by the reference letter ‘‘A’’? on. DX 556. We actually made the changes in this Richmond ‘pressure | still of DX 556, which were later incorporated in our . _ operation and known as the Halloran and Strout opera- . ion, Pata ni 722 DX 557 and DX 558 are two drawings of the Hallo- . ran and Strout operations. oo oa 723 These two drawings show the so-called baffle im- provement. On DX 558 the baffle which I have marked ‘*A’’ was placed in the suction end of the shell, which tended to separate the liquid in that end of the ‘shell from the liquid in the balance of the shell. An open- ing was left in the bottom of this. baffle so that the surplus’ liquid returning from the circulation could flow into the balance of the shell. I have marked that ‘'B.’’ The shell holding the main: body of oil had additional loose baffles marked ‘‘C’’ and ‘“‘D.” The vapors rising from the forward compartment . passed through the. vapor.lines which went through the forward baffle ‘‘A’’ releasing the vapors in the back: chamber. Soy aie ; . These vapor lines were perforated for that pur- pose and are marked ‘‘E.’’ The feed and reflux was 724 conveyed into the front compartment by the line . _* marked ‘‘F.’? (The line ‘‘F’? in DX 558 dis- 876 charged directly over the suction to the pump, ' whereas in DX 557 this return line merely went through ‘the tight baffle. ; | : In the ‘operation of this modified Richmond or Halloran and Strout still, I assume we first operated _with a.chamber in accordance with DX 557 and later . in accordance with DX 558. a. | The ‘diffcrence in dates on the two drawings, namely 8/30/23, and 1/22/24, would indicate how long a ‘period this modified arrangement according to the - showing on DX 557 was utilized. 725 The apparatus in which the Halloran and Strout, Deposition of Richard W. Hanna, 571 or modified Richmond, process was operated was sub- stantially identical with the Hanna apparatus of - DX 556, except for the modified chamber illustrated. - 702 in DX 557 and 558. In this-still the charge was 26 - gas oil gravity from which a P. D. having approxi- mately: a 50 gravity: was produced, which was ap- proximately 48 per cent. of the charge; from the P. D. approximately a yield of 39 per cent. Based - on the charge crude gasoline was recovered., The re- ~ cycle stock from the front compartment had a. gravity of 20 degrees Baume, and the residue drawn from the ' ‘rear compartment ha@ gravity of 17 degrees Baume. All the Hanna stills were converted in 1923 or 1924 into the Halloran and Strout type, and they were all abandoned by December ‘of 1925. hee . In the operation of these stills the average on-- stream period was 70 hours ‘and the complete cycle ves from 90 to 95 hours. The word ‘‘cycle’’’as I have ~ ysed it connotes the period from charge to charge in. ’ the operation of the still. ie ' 725 877 PX 532 represents a flow diagram of the way the Halloran and Strout process was operated at” . the Standard Oii Company of California. There are vapor heating chambers there which I do not recall 726 if we put.in. We operated with solvent oil a few ‘times. I do not think that solvent proved out as of any ~ material value, so we did not continue having a sep- arate solvent feed. The cost of ‘all experimental work was charged to the $5,000,000 which I have previously referred -to. If we experimented with that solvent 727 oil that was charged to it. When we did any changing» in our regular operations in the nature of experi- mental work that would be charged to experiments. _ Referring to PX 532, Halloran and Strout patent - No. 1,765,976, Fig. 2 shows a high oil level in the compartment 12, which is the rear large compartment, and a low level in the compartment 10, which is the ‘front compartment. I think our commercial opera- tions were conducted with the level in the front com- - . partment lower than the rear ~ompartment but T cannot say whether Drawing Fig. 2: properly reflects : the levels that we used commercially. |I do not know what the difference in levels would be now. 728 The withdrawal of the charge and- vapors and bank- 572 Abstract of Testimony on Merits. - ing of the vapors in the front compartment only would -seffect a. slight difference in lével in the two ends of . 728 the drum. The greater part of the vaporization which occurred in the process was effected in chamber 10, the’front compartment and it .is my-idea of what oc- - curred that the vapor thus formed in this front com- partment held the level in compartment 10 lower than ‘the level in compartment 12. The vaporization which * occurred in this front compartment 10 was the re- 878 sult of the cracking that occurred in the heating element, and to a very large extent realized in that compartment. Cracking also occurred in.com- partment 10 to a very much less degree. ‘The pressure: in compartment 10 and in the tubes was not the same; the tubes had higher pressure, with the friction and the cracking result that took place in the tubes. Q. If the pressure in the tubes was higher you would get more vaporization in compartment 10 at the lower pressure, would you not? | 7 _ A. The projection of cracking coming out in the mixed turbulent froth was released -in this,.and the separation of these cracked products would take place in that eompartmenty ° oh Q. I do not know whether we exactly understand --one another. Is it-your understanding that as soon as - eracking occurred vaporization occurred? se - 730 A. That is rather a technical question, but our | belief was, and ms belief. still is, this, that 60 per. cent of the cracked gases were generated and . pro- duced in the tubes, and that, say, 40 per cent of the balance would. be a tesult of the time element in the chambers 10 and 12. So that the 60 per cent that was created in the tubes would be released .when it was - + expanded into compartment 10, and would pass out of - that compartment through vapor lines. A litéle addi- _tional would be created from the body of oil in eom- 731 © 731 partment 10. The balance would be generated “or created from the body of the oil and soaking time cle- ment in compartment 12. As the cracking occurred in the tubes, vapors would be generated. The part of the cracking which occurred in the chamber 12 is the Tesult of the time factor that the body. permits of. 879 How long it is T do not know. We also thought that we were adding heat to the vapor line and - assisting our cracking in that manner. In other words, Deposition of Richard W. Hanna, | ‘573 we believed that our vapors were considerably hotter - and would serve to assist to reduce the temperature » drop in chamber 12, caused. by. the cracking reaction - and vaporization there. = : ss . as the vapor wliich.was released through the tubes 14 utilized to heat the oil, or was that vapor used more from the standpoint of creating a partial pres- . sure effect to cause vaporization? “ 732 733 A. Our idea, as I look at it now, must have been. heat rather than partial pressure, because partial pressure -would convert more readily into a vapor. . In other words, the partial pressure would take the liquid out of there.and defeat tle idea’ of time factor? ie. | Boor A. I do not see how it could defeat the time factor. The oil quantity in the compartment maintained a constant level. What the theoretical result would be would be a technical question. . Mr. Hanna, because of the longer time factor that was maintained in chamber.12, it is true, is it not, that the main precipitation or settlirig out of the car- bon, tarry bodies, or heavy derivatives or cracking takes place in this chamber? . A. As said before, the relative quantity of carbon deposit,. weight, I have no recollection of, but the car- bon deposition that controlled our success or failure was that which deposited in the fubes. That is all 1 733 can say. | Baers Let me ask you, Mr. Hanna, do you agree, and when this patent application was drawn did you con- sider this statement on page 3; beginning with line 101, | to be correct, reading as follows: Bae oui 880 . ‘*The reacting oil is maintained for an appre- ° eiable time in this chamber 12 and the main pre- cipitation or settling out of the carbon, tarry bodies, or heavy derivatives or cracking takes place ‘therein. _ The period of reaction is thus prolonged by the. re- 734 ‘action of the oil in the final evaporating chamber 12, _as described, without permitting this prolonged reac- ~ tion, and the consequent precipitation and settling out ~ of the oil of the heaviest derivatives, to effect the operation ofthe cyclic system, which includes, as_be- fore described, a heating zone or coil and a cycling chamber in which latter material vaporization is ef- -fected.’’ a" Wer 574 . » | Abstract of Testimony on. 1» Merits. 735 ‘A. The normal manner in which I read a. eaten’ application was to read ‘the claims, have it explained to me by the patent attorneys, and possibly the inven- tors, and release them'‘to take out a patent application on the subject. I cannot say that I read the descrip- tion-of many of these patents, and, therefore, I cannot. | say. now that I read this_paragraph- reférred to, and — .736 therefore cannot say that I agreed or disagreed with it. ' Q. Do you agree with it now? - ; A, I am not competent to agree to anything on the’ technical side. . It is a matter going back twelve years. During this period I have been away from the techni- eal end of:it. It is not a question that I would: expect to be asked or to be expected to try to answer. ' In this Halloran and-Strout commercial operation, all of our residuum went ‘to fuel oil eventually. It might have paused in two or three ‘tanks, but even- tually it got down to the fuel oil tanks. _'TKe tempera- tures: and pressure that were used in the com- . 736 881 mercial operation of Halloran and Strout would be approximately the same as the so-called Hanna . operation. The carbon in the tubes was hard and ‘difficult to remove. The carbon in the shell was rela- tively soft. 737 The purpose of the Halloran and Strout. eration - as compared to my previous Hanna operation was to reduce the amount. of carbon that we were having de- posited in our tubes. The way we hoped to effect that was by keeping the stock going into. the tubes cleaner, | from tarry, cracked bodies. -We wanted the stream to contain the maximum amount of the clean residuum and charging stock. Q. And you understood at that time, did you, that _the return of residuum would cause trouble in the . tubes, from the standpoint of ‘carbon deposition? A. Circulating carbon cracked bodies had given us 738 the carbon trouble. — Q. And you understood that the return of these cracked carbon bodies would: give you that trouble at - that time. A. I think that I knew it very definitely. The return. of the residuum to the coil, that is, the part that we did return would give usa greater amount of pressure distillate; anything we put. through the coil and cracked would oo us more distillate. - 739 Deposition of Richard W.'Hanna, .. 515. The approximate. cost of one of these Hanna stills that I.have referred to as the Richmond still is ap- proximately a little over $100,000 per unit. This ‘Halloran and Strout application, PX 552, and the patent that is to One on .said plication-were—as-— _- signed-and belong to the Daivercal Oil Products: 882 Company. .I Nallews we turned this: application - over to the attorneys of: the Universal Oil Prod- ~ uets Co., and they continued the prosecution. T eannot - 742 743 Say. accurately. _I understand that the: Dubbs unit at Martinez was a commercial unit. PX 534 describes the Martinez unit and comments on the Halloran-Strout unit, bring- — ing out that the Dubbs people realized. the value of _ keeping clean stock in the tubes. . 883 In PX 534, under the heading ‘‘Chamber’’, the : ° statement is made that it will hold 26 tons of eoke. The coke-holding eapacity of this chamber determined the length of the run when running non-residuum. As I recall it, the Shell practiced non-residuum operation. | - The coke- holding capacity of the reaction chamber on a residuum run of the Dubbs operation, as prac- ticed subsequently, never determined the length of the run with us, both in the flashing. operation and the ‘ Dubbs operation without the flash in so far.as we operated them. We operated without flashing com- paratively little. I cannot say how many runs we made - without flashing. Enough to satisfy us as to the rela- ' tive advantage of the twe systems, however. 744 In PX 534, under the heading ‘‘Pressure’’ he says, ~ ‘“‘The unit is operated at 120 pounds gage.’’ The pressures used by the Standard Oil of California, as - . indicated on PX 550, are much higher, of an order of 310 to, 375.. I think we ‘actually operated with 270 pounds, and we went up in pressure to get the higher . temperatures, on the recommendation of the Universal - Products. Co. from their experience in designs, for _ better yield and more efficient operation. The ‘tem- peratures shown on this diagram_(PX 550) at these pressures are 860 and 880 at. the.outlet of the coil. I _ don’t think we ever operated at that pressure. The. pressure indications on the drawing are not the pres- sures that we operated under in commercial operation. Q. This drawing (PX 550) was produced, was it not, to show what vou were ee commercially? = 576 | Abstract-of Testimony on Merits. A, Not necessarily, from the detail standpoint as to the pressures that we-were to operate on when _ 145 884 our-engineers decided on: the pressures, ete. It “might well have been outlined as the objective; when the unit was constructed.,the safety engineers would have to pass on the pressures we could. operate — on at that time. _ ‘oe Q. This drawing, then, is not a showing of the manner in which you actually operated, as far ax tem- _ peratures and pressures and other indications o1 that sort are concerned? = __ ne aS ae .. A. This undoubtedly was not‘ a record of runs, _ because we-kept our records in another form. This, — as it says here, is a flaw diagram, indicating the method . ‘that we would operate, the principal that we were to use, and it does outline that. 3 . 270 pounds, as I recall, was the pressure that the safety enginéers passed on.. That pressure was pos- 746. sibly used both on the Dubbs and the flashing system, the same. factor of safety controlled both in operation. _ We never did operate that. Dubbs unit at lower pres-' |, Sures, not as a commercial practice. 749 On the last page of PX 534, the fourth paragraph from the bottom, lie says: ‘‘You can see from the above that the equipment is very similar to ours, only _.that he does not use a pump to cireulate.’’ This non: - use of a pump would affect the operation only as to: . the head on the inlet end of the coil. The differential . of pressure across from the. inlet to the discharge end of the coil is substantially the head required to over- ‘come the friction through the system. . In the case of . the elevated gravity head of the Dubbs, it would all - depend upon the height of the gravity head, whether 750 it equaled the pressure developed by the pump. A " pump would give. you positive circulation. through the ; tubes. as-long as ‘it opérated. How that circula- 750 885 tion would compare with the circulation that. you | would get with an. elevated dephlegmator would depend entirely upon the capacity of your pump and the height of the dephlegmator. : Q. Would ‘you consider one better than the other, or are they equivalents? | ee A: I think we proved. the pump the practical thing. . 751 Referring now to PX 935, which is a letter of Octo- ber 1, 1923, written to me by Mr. Hamilton, in the sen- . 4 Deposition of Richard W. Hanna, 817 tence immediately ‘following the tabulation of heat demand in B.T.U.’s, a statement is made that the - “Velocity in tubes is approximately 3.7 feet per sec- 752 753 753 ond’’. I have.not got the velocity which the Standard Oil. of California used in their units as exemplified in Exhibit 550, where they used pumps, but I think it would be a considerably greater velocity in the Stand- ard Qil of California operation. “I This drawing, PX 536, was attached to the letter PX 535, and is referred to in said letter. PX 536_ shows the Halloran and Strout unit previously de- scribed with a suggestion of Hamilton to keep the coke, that was formed and carried in suspension in the discharge from the furnace, from being picked up by the suction of the pump and returned to the heating element. This was one more step in an‘endeavor to, | keep the tubes clean. | eee ae : It was proposed to put ari extra baffle marked ‘‘A”’. ‘and extend the discharge from the heating coil shown in . dotted red,, which I will mark ‘‘B’’; the discharge thus - opening on the opposite side. of this proposed baffle marked ‘‘A’’, from the suction which I have marked “C’’, The hoped for effect was to settle out the car- bon without letting it get to the pump. In,the 886 blueprint the opening I have marked ‘‘D’’ .was considerably.off of the bottom of the shell, so as to give room for this carbon to come to rest. ee I don’t know now whether we ever operated ae- cording to the showing on this drawing. The furnace there shown and the rest of the equipment, except for the changes I have indicated, are the- same, sub-. 5 stantially, as the equipment. shown in the drawing Ex- — hibit 556, as modified by the chamber of Exhibit 558. Under item 3 of PX 533 I said, ‘‘That circulatian -gan be obtained without the use of a pump.’’ By that I mean the elevated dephlegmator tower. I did not consider that advantageous in view of our develop- ment work on pumps. We had developed our centri- > fugal pump.to a point where we believed that it was better than the elevated dephlegmator tower. Un- der item 4, I said, ‘‘That higher pressures are very desirable.’’ I said that because ‘higher pressures might have better efficiency in the fuel consumption. 578 Abstract of Testimony on Merits. 757 In addition to the heat demand, higher ‘temperatures would be possible and thus give more yield in the cracking. operation. ; We never practiced the Dubbs process, using “an. elevated déphlegmator other than in the-experimental work at Avon. There I think we did not use the pump but used the elevated dephlegmator tower. Since the other day I have looked up the question | _ whether we ever actually made the changes in the - Halloran and Strout still to incorporate any as a result of what we saw at Martinez and find that this work-was only planned on \the drafting board - .. ... &8 shown by /the drawing DX 559, and. was not 757 887 put into operation in the Halloran and Strout _ etal: daira Salil | ate : . Referring to this drawing DX 559, which is the 760 drawing attached to the Halloran and Strout appli- . cation, starting at the outlet of the heating coil the heated cracked oi] was to have gone—I say that he- : cause this unit was not constructed—to the chamber 761 marked ‘‘A’’, the vapors rising from this chamber to the column marked ‘‘B’’, the naphtha vapors going on to the vapor line marked ‘‘C”’, to the condenser marked “‘D’’, to the receiver marked ‘‘K’’, where _ the gas was released and the naphtha delivered to _ Storage. The residuum from chamber A was re- leased into the tar flashing chamber marked ‘‘F’’, where the gas -oil cracked was distilled by residual heat overhead, to vapor line marked **G’’ and ton- denser marked ‘“‘H’’. As a matter of actually put- ting this into operation, the condenser marked ‘‘H’’ was not employed when we constructed, as we used . fresh feed to condense -this vapor, thus preserving the heat. The- condensate from this flashing opera- tion, together with part of the feed, was forced through the heating coil along with the balance of the _ feed which was injected into the tower and the reflux stock from the tower. . . 762 A temperature is given for the chamber of appar- ently 8°0. The temperature at the outlet would be a little bit higher. Deposition of Richard W. Hanna, 819. In this drawing the furnace is shown conventional. The fire/is indicated at the left-hand of the furnace. _ According to our practice up to that date there would have been a bridge wall in front of those tubes. Under. - those cireumstances the feed to the coil comes, in at the hottest part of the furnace and comes out at the coolest part. ‘We did not operate this so the feed did not actually go in. When we did operate, as l, . 763 888 remember the later practice, we developed a fur- | nace design to arrive at the injection of the. new feed in the hottest part of the furnace. If we did this it was only to get better furnace operation. _ This thing that we see here that is referred to as . a jet pump is in dotted line. A jet pump is a type of. pump for any purpose. As I recall,.if the pump | 764 marked ‘‘Secondary pump”’ which fed: the oil to the coil should not deliver enough oil to the coil for the proper operation, then we would withdraw to the left for the bafflle ‘‘Z’’ with our jet. pump and cycle oil from’ the chamber through the coils and that would be until we could get the fire shut down and pulled out _ to keep from blowing up the unit.. ' 765 I note that the condensate coming from the tar _ ‘evaporator ‘‘F’? comes down into what is termed the main feed line, and then in this main: feed line there are arrows pointing toward a cycle stock storage tank, and an arrow pointing away from the cycle stoqs storage tank, It was not contemplated to _ run some of the cycle stock from the tar evaporator . into a storage tank unless there was @ surplus of it. _ When we actually started to operate the flash system there never was a surplus. I have no opinions or correspondence other than I have thus far produced from our patent attorney 766 on the Dubbs ’325 and ’629 patents: = | S, r patent attorneys advised us that the Dubbs patent No. 1,392,629 was at that time in interference withthe Holmes, Manley and Behimer application, Serial No. 401,623. At that time our patent attor- neys made such investigation with respect to 766 889 this interference, No. 49,355, as they could. It ° ‘would be normal to do that befofe we sent for Mr. Halle. ar : te» . 580 Abstract of Testimony on Merits. * 767 I did not know that in the Behimer application _° the claims jof the Dubbs 1,392,629 patent had been -.copied for the purpose of the interference. Our at- torneys did not tell me that. I did not consult with The Texas Company respecting this situation to as- certain their position with respect to the Holmes, Manley and Behimer process and this interference, The attorneys may have. I do ‘not know how far they went with their investigation. I only know . that they advised us against disregarding the Uni- versal Oil Products Co. patents and recommended to us: that we had better get that coverage before we went ahead. Z "jal ee oe : 768. We were willing to take our. chances: on condensa- 769 tion under pressure, covered by -the Universal Oil Products Company patent to J esse A, Dubbs, because ' 770 we felt that we had the Standard Oil Company of Indiana as a buffer, first, and secondly, there was prior, art which was’ sufficiently clear to us so that we felt the Jesse A. Dubbs patent would never be ‘sustained. The other arguments that Mr. Halle used 769 as to his other patents were given but little weight . in my mind, as I felt Mr. Halle was trading. Mr.: 770 Halle brought up references. to many patents, most ' of which we were familiar with. He referred to- mechanical device patents, cleaning of still patents, and I took the position that if we did not have rights -to any of those patents which I . considered minor, we could possibly get around them. I told Mr. Halle this, to which he replied it would cost us & great deal. more money to try to get around any of these patents. The question as to taking chances on the Holmes, | Manley and Behimer was distinctly different from 770 890 the others, in that our patent attorneys felt that | we had to deal with Universal Oil Products Co., on these patents, whereas they advised us that we were taking no risk if we did not. deal with Universal — Oil Products Co. on the Jesse A. Dubbs, so that in both casés we were doing what our patent counsel advised. sae he 772 ~=In spite of what Mr. Howard and Mr. Adams stated Deposition of Richard W. Hanna. 581 in -PX..538 and 539 as to the possibility of Dubbs ~ Josing the interference, we were desirous to get pro- tection under the two patents in question; the ’325 patent, which included the fresh feed being’ pre- - heated in the vapor column was also a vital part.of _ our proposed operation, and the. weight we put upon 773 the advice and the study is borne out by the fact that © ; we later did sign a license agreement which cost a great deal of money, running into millions, and we . did that with our eyes open as to‘the cost.. Company had acquired riglits from the Dutch Shell | think that when'I discussed this matter with Mr. Halle he advised me that the’ Universal Oil Products to license or grant immunity under the Trumble patent No. 1,281,884. — ot ages rs -Referring to thé letter, Exhibit 539, from our at- torney, Mr. Lyon, he. again quotes Mr. Howard as . stating ‘‘Apparently Mr. Howard knows of no definite | | ground of invalidity of Dubbs patent 1,488,325, and 774 believes that this patent will have to be avoided. Mr. eward is somewhat concerned with the possibility of a suit being brought at some future date against > for infringement of Trumble 1,281,884 by The Sheil ompany. The. Shell and Dubbs interests are ap- . parently working together.’’ : ce \ a | "the Universal Oil Products Company. only paid - approximately $600,000 pursuant to PX 543 providing for a payment of: $4,000,000 for Standard of Cal- 891 ifornia patents. The remainder of the $4,000,000 was not paid because we bought a paid-up license, - 775 and if we did not pay any more annual royalties, of . course, the ——— for patents on the basis of a 25% _ refund was off. eae : : Among the patents involved in this sale are five patents. issued in my name, namely, patent No. 1,- 419,378, DX 553; No. 1,449,227, DX 554; No. 1,449,226, DX .555; No. 1,408,698, DX 560; and No. 1,655,603, DX 561. Those ate some of the patents for which this .: consideration was paid. | ae. | * 776° In this transaction in which the paid-up license’ was | _ purchased there were some notes issued at the time of the agreement. ‘The Standard Oil Company of New - Jersey took $3,000,000, the Standard Oil of Indiana ° a vv 582° Abstract of Testimony om Merits, 777 took $3,000,000, Haile retained the Shell $6,000,000 betwees them, T thiak a t6 ifornia took $6,000,000 between them, I a total of $15,000,000. These notes were not’ bonds. They were inte . . | 778 the herp ow bey, a mine hyd —e number o immunity agreemen no w the dill af tian wee. At the time that I discussed this license agreement ’ with Mr. Halle I made a stndy of the Dubbs 1,392,629" tent. Westioneny Under the Rule: Att At that time, as a man skilled in the art, what - 779 was your understanding of the in the patent that ‘the oil in the heating tube sho ty bert yoy i ae wittoet substantial vaporization? Mr Now, your Honor, that is objected to Rang outside the direct examination, and ae material. This man, of a a technical expert. He was ed merel ay & 892 testimony as to what had been done the Stand: _. a ht about it. 781 The Court: I think the ehjeltion should be sus- tained; and the matter will be read into the record. Should I afterwards change my opinion when I come to read it, I will indicate it; but at this time my opinion is that the objection should be sustained. 782. A. It would mean during this heating in the tube there would be no separation from the mass or mixture F om 7 Depasition of Richard W. Hanna. © amined as to his opinions or as a technical expert. This — ee ee ee ee Sete Ts time in this way, more particularly as he is now in- volved in the dock strike which is on at the present moment in this city, where the operations of his com- pany.are carried on, and in connection with which his corviies are a by his company.’ . **In other words,— ee ‘*The Court: His time was taken up? . ‘*Mr. Von Holst: Go on reading, Mr. Hall. ta Royebty, Mhen by Wabvereel ws des Change in Royalty Rates nive e t change in royalty rates was made in 1934. The royalty 844 was then reduced from fifteen to ten cents a barrel throughput. The reason for this change was that the competitive situation in 1934 caused Universal to be- lieve that it was necessary to reduce its royalties -in order to maintain and increase business. The next change was made effective October 1st, 1938. At this time Universal that with the expiration of the Dubbs — , it might be 845 faced with the situation that cnlecs time, royalties were reduced some of Universal’s ~ omg gy be lost. - °* _ This Dubbs patent expired in October 1 910 Cross-Ezamination by Mr. Thiess. 846 I was in sales work with Universal prior to the time that I became assistant secretary. contacted our * October 4, 1988 is the date of expiration of the Dubbs patent in sult, Testimony of Macauley. Carter. ". @ licensees and, of course, prospects for the process. 1 do not recall that I ever contacted whe © id-Continent | p * Prher patents besides the 629 patent thiat I have fe, ferred to. I don’t kiiow of my own know but I Gasoline Products Company at the time Wes tor the 848 celled in accordance with PX 571. Universal sued the Mid-Continent after that. That suit was also discon- tinued. I do not know — it was discontinued. On October the Ist, 1938 we reduced our license fee from 10 to 5 cents. In December 1937 Universal had i a license from The Texas Com y to license j nee in -eoatinnane of the second suit against the Mid-Conti- — nen . ‘ 911 The f wing exhibits, all of which’ were for- ; merly exhibits in the Root case, were offered in evidence : | 851 PX 572. Statement of royalties received year by eee from the Shell group and Standard Oil of Cali- ornia from 1922 to December 31, 1930. . - Abstract: .The grand total of royalties from these two licensees, up to December 31, 1930, was $33,576,- - 852 PX 573. Statement of the royalties received f rom licensees other than Shell and the Standard Oil Com- of California group from 1922 to December 31, — ‘ Abetract : Thirty-seven domestic and eleven foreign licensees are listed. Royalty payments up to Decem- ber 31, 1930 aggregation. $16,430,492.04. Shell Company and the. Standard Oil Company of California in the amount of one quarter of the royalties _/ $98 Abstract of Testimony on Merits. Abstract: “The amount credited to the Shell Com- y was $2,942,077.65 and to the Standard. Company 501) 026.51. Total: $3,533,104.16. 853 PX 5751. Stipulation entered irito in the Root case in lieu of. the various license agreements. . Abstract: This exhibit contains:a list of the various . licenses granted by Universal Oil Products Company _ prior. to December 31, 1929. The various patents and . te under which each license Was granted are — * | 912 ) BERNARD G. LENSKE, Oak Park, Illinois: Direct Examination by M r. Haight. 853 Lam compt roller.of the Universal Oil Products Com- _ pany and I have control of tlie journal of the Universal Qil Products Company. Journal Voucher No. 1019, PX. 576, is'a record of the receipt of $10,000,000 in ‘January 1931 from the Shell Union Qil Corporation and the Standard Oil Company of California. Note: _ The purpose of this voucher is to show that $10,000 ote: _was paid by the Shell and Standard of Sagem ep —- ies for a paid +. license. $3,000,000 was paid by . _ Standard (Hanna, R. 648) ‘so the remaining $7, 000,000 - * was paid by the Shell Company. | | 913 ; Croce tblminition by Mr. Theiss. : 855 Px 576 indicates that six million dollars in ‘notes ° — 856 were received, According to this statement we got - ‘four million in cash and six million in notes, but that - was a ‘transaction between the former stockholders of . Universal and the companies who purchased the stock ‘= at the time the-deal was made on January 6,.1931. I ' cannot say what became of the notes. Those notes did - 857 not go to Universal. Ostensibly the notes and cash . _ went fo the company. But I assume instead of that the -. notes went directly to the stockholders as a dividend. I do not know that some of those notes went to others — besides stockholders. The $253,000 item represents interest on the ten mil- lion dollars at the rate of 5 per cent for six months, covering the period from July 1, 1930 to-December 31, 858 Testimony of L. C. Huff. | 302 = 1930, and the amount would be $250, 000. That was treated. the same as the $10,000,000 to which we re- ferred and was handled by Mr. Halle and Mr. Dunhani, who were president and vice-president respectively at that time and I don’t know how it was distributed. The next item, 61, is a credit to the surplus account of the $250,000. The surplus is the account to which the earnings from the corporation are credited at the end of the year. When books are closed, the profit ac- counts are closed into a surplus account, and this trans- ) action reflects the record of the $250,000 eash paid as interest on the $10,000,000 deal from July 1 to Decem- ber 31, 1930. That again was disbursed in such 914 a way that I don’t know who got the money. — The next itent, ‘Profit and loss 1931”’ refers to the interest on the same $10,000,000 but covering the six-day: period from January 1, 1931, to January 6, 1931, which was the effective ‘date. of the deal. The next item, ‘‘To record interest on cash and ndtee | received for royalty grants fully paid and advanced for the period July 1st to December 31, 1930’’; is an ex- planation for the debits and credits as they appear in this journal, afd covers the very same matter which I have just explained. This sheet. does not purport to show the rebates granted-to the Shell and California companies: on ac- count of the — of their’ patents. 915 L. C. HUFF, Winnetka, Illinois? 861 862 863 Direct Examination by Mr. Thomas. Qualifications: I am employed in the engineering department of the Universal Oil Products Company and have been associated with this company since May, 1921. I served as chief engineer for about foyr- teen years in charge of designing and: constructing cracking units.. My first assignment in May 1921 " was to obtain operating experience and to become - familiar with the construction of the Dubbs Unit No. 1 ‘of the Roxana Refinery at Wood River, Illinois: - This still was designed under the direction of Robert a. Pollock, who was chief engineer of the Universal 864 Oil Products prior to May 1921., After my arrival Abstract of Testimony on Merits. - at Roxana I modified this still by’ redesigning certain ~ 865 . 867 868 oil lines in order to provide for expansion and contrac- ° tion, and made other changes which improved its operation. These modifications were made as soon as the necessary materials were obtained. Dubbs Roxana Unit No. 1: PX 522 comprises the drawings of the original’ Dubbs No. J unit constructed at the Roxana Refining Company. PX 577 is a sim- plified diagrammatic flow sheet of the No. 1 Dubbs unit prepared under my direction. PX 578 is a ‘mounted enlargement of this flow sheet. ° The equipment shown on PX 577 comprised three major items: (1) a furnace which contaiied four banks of tubes marked F; (2) two sets.of vaporizing chambers marked H which were mounted immediately © over the furnace but in a separate compartment ; and (3) a dephlegmator, marked C, which was mounted some distance above the rest of the apparatus. . The dottel lines shown adjacent to the coils are the out- 916 lines of the walls which separated the combusion chambers from the coils. The ray oil to be charged tothe process. was re- ceived from storage by a pump A ‘and was charged through a line B into the top of a dephlegmator C_. wherein it flowed downward ovér pans countercurrent « . to the rising vapors therein. The arrangement of 869 these pans is shown in the cross section of the . dephlegmator C. The raw. oil as it entered the dephlegmator partially condensed some of the vapors rising therein, and the condensate from these vapors, called “reflux”, gravitated: to the bottom of the dephlegmater in admixture with the raw oil, and passed into the reflux leg D, and. then through the combined feed line E into the inlet of the eee heating coils F. The four-inch heating coils were identical in con- struction, but each was independent and located in a different ‘furnace compartment. Each coil consisted of twelve four-inch outside diameter tubes twenty feet long. The four coils were independent, but the ‘tubes in each coil were connected in series by return bends. The heated oil from two of the coils joined into the transfer line G and passed to one set of vaporizing coils H. The heated oil from the other two coils joined Testimony of L. C. Huff. | . 601 a similar transfer line G@ and entered into the other -. set H of three vaporizing coils. - 870 The-heated oil and generated vapors entered the 871 chamber No. 1 of the vaporizing tubes H, flowed to the far end of that chamber, crossed. over into the No. 2 chamber, and then flowed to the far end of that chamber. Vapors were taken off overhead through a vapor line K and entered the dephlegmator C where- . in they were subjected to partial condensation by 917 the incoming raw oil, as previously described. “The unvaporized liquid remaining in the vapor- izing chamber H crossed-over and flowed into the chamber marked 3 and then to the opposite end of that chamber where it was: continuously withdrawn through a line W and sent through a cooler to stor-. age. The uncondensed vapors from the dephlegmator ( passed .overhead through a line L imto the final vertical condenser M and then were passed ihto a receiver N. In the receiver N the separation of the uncondensable gas and the condensate took place.. Originally a portion of the combined feed from the reflux leg was pumped to the'top of the dephlegmator in regulated quantities for the purpose of controlling the temperature at the top of the dephlegmator, but at a later time pressure distillate was, recirculated from . the receiver N into the dephlegmator ( by pump S through line T. , | ; The remaining distillate from the receiver N was . withdrawn ‘from the bottom through a valve P and sent to storage. The pressure distillate contained the’ gasoline, which was the prime object of the crack- ing operation, and the gasoline was recovered by dis- tillation. The uncondeusable gas was withdrawn from .. - the top of the distillate receiver N throngh the valve R. ‘ A pressure of 135 pounds was usually maintained on the apparatus and was controlled by ‘regulation of the outflow of gas through the valve R. |.‘ . - The reflux that collected in the reflux leg D in ad- - mixture. with the raw oil was returned by gravity through the combined feed line FE to: the heating 918 coils. The dephlegmator C was set at such an elevation that the head of the liquid that built up in the reflux leg D was sufficient to overcome the friction in the tubes and force. the oil through the ee 602 + Abstract of Testimony on Merits. - heating coils.. The ay was about 26 feet ~~ with a net head of about 12 feet. - Throughout the operation of the No. 1 unit, the residuum withdrawn from each set of vaporizing 874 chambers marked H through residuum connections: marked W was not returned to the heating coils. | The oil received its entire cracking heat in the four banks of heating coils marked F. The vaporizing chambers were located in a separate compartment mounted premrary A over the furnace. . This compartment was unheated but was heavily in- sulated to prévent' radiation losses. The charging stock forthe unit was gas oil. During normal on-stream operation the approximate temper- ature of the combined feed that. accumulated in the ; reflux leg D was between 700 aud 760° F. 3 876. The cracking coils were four inches outside diameter - and twenty feet long. There were twelve tubes in _ each bank and each independent bank was about 240 feet long. The vaporizing chambers consisted of three 16-inch outside diameter no. approximately twenty ~ - feet long giving a-total length of about sixty feet. ‘The | dephlegmator was approximately three feet six inches in diameter by. twenty-one feet ee ® During the normal on-stream operation of the unit. ___ the temperature of the hydrocarbons leaving the 919 heating coils, called the transfer temperature, was | within the range of 840>to 865° F., but on the earlier runs of this unit the transfer temperature was 878 __ on the order of 800° because of the newness of the . 920 unit. The pressure was maintained at approxi- mately 135 pounds, = 7 | _ It was the usual: practice -to start out a run with the liquid level approximately one-third the “way up: _ the diameter of the vaporizing chambers.’ This level - was allowed to build up until it reached the halfway _ point towards the end of the run. The indication of ' the liquid level was obtained by means of ‘liquid level 879 lines which are indicated on vaporizing chamber #2. __The rated capacity of the unit was betwéen 200 and _ 250 barrels per day of charging stock. Ten regular runs were made,and they were all complete with the exeeption of two runs, one of which was shut’ down because a-rag was found at the inlet of one of the banks of heating tubes, and the other of which was - a Testimony of L..C. Huff. . 603 terminated while coming on stream due to a leaky. gasket. In all there were eight complete runs. A typical run made on this unit, made during the early part of August, 1921, on a 35° Be. gravity gas oil at 135 pounds: pressure, lasted fourteen days on stream. The through-put. was about 235 barrels per day, and the transfer temperature was between 790 and 820° F. The yield of Navy Specification gasoline was approximately 28 percent by volume based on the _raw oil charge. About 40 percent by volume of residue based on the charge was withdrawn from the vaporiz- — ing chambers, and this residue had a gravity of about 25-to 29°.A. P. I. oe The ‘reflux condensate from. the dephlegmator, in admixture with the raw oil charge, was returned to the heating coils, The unvaporized liquid in the vapor- izing chambers was withdrawn and was not returned to the cracking tubes. In general, this was typical of ‘all the runs made on the unit in that the refiux ‘ from: the dephlegmator ‘in admixture with the raw | | 886 _ oil was always returned to the heating coils and 921 the residue from. the vaporizing chambers was withdrawn from the system. Only ten runs were made on the unit because when the eleventh run was attempted an explosion occurred, which wrecked the apparatus. At that time I was — in Chicago, but immediately upon hearing of this - explosion I was sent ‘to Wood River to investigate and find out what had caused it. I reached the con- \ -elusion that the reason ‘for the explosion ‘was that in . ‘attempting to make a short cleanout, sufficient time had not been. allowed for the heating coils to cool off. -In those days it was customary to give the apparatus an air test. to make sure that there were no leaky joints. The air was being withdrawn from the system at the time when the raw oil was charged to the unit. The mixture of oi] and air entering the heating tubes reaehed the ignition point and the explosion which .- wrecked the unit occurred. - Dubbs Roxana Unit No. 1-A : Following the explo- | sion of the No: 1 unit, another unit called No. 1-A "was installed on the same site. The design and con- struction of this unit was under my supervision. The construction work began in’February, 1922 and it was _ placed in operation in June 1922. » 604 887 889 | Abstract of Testimony on Slevite: ¢ PX 579 A, B and C comprises drawings 621- F, 690- F and 691-F, which are the drawings of unit 1- A. PX.523 is a simplified diagrammatic flow sheet show- — ing the construction and operation of Unit No. 1-A, prepared under my direction from the detailed draw. ings. In general, this plant was of the same design -as Unit No. 1, with the exception, that the furnace, instead of. having four coils, had only a single set of coils. The fubes were four inches in outside diameter and thirty feet long. There were thirty-three tubes in © the coil, giving a total length of about 990.. linear feet. 922 The vaporizing or expansion ccanbie was situ- | ated alongside the furnace in a separate compart- ment that was insulated but unheated. The rest of the _. apparatus was substantially the same as -the No. 1 unit. In the No. 1-A unit the oil was received by the raw oil pump and charged to the top of the dephlegmator | wherein it partially condensed the rising vapors. The reflux; in admixture with the raw oil, gravitated down the reflux leg through the. combined feed line, and — - through the coil. The heated oil and generated vapors were discharged from the coil into the expansion cham- ‘ber. The vapors were withdrawn from the other end of this chamber and passed to the dephlegmator, wherein they were subjected. to partial condensation. The’ vapors not condensed in: the dephlegmator passed overhead through a coil condenser and ‘the | condensate (pressure distillate) collected in the final ‘ receiver and was continually withdrawn. to storage. 891 Regulated quantities of pressure distillate were with- drawn from this receiver and. returned to the top of _ the dephlegmator. to control the temperature therein. In some of the runs, it was found advisable, instead ° of feeding the raw oil dverhead into the dephlegmator, - to feed it direct to the tubes along with the reflux: In other cases, we practiced what was called a “split : _ feed’’; that ‘is, part of the oil was charged overhead to dephlegmator and part was fed direct. to the coils. This was all gauged by controlling the temperature of the vapors at the top of the dephlegmator. The means employed in this plant to insure’ the return of the reflux to and through the crackling coils © ‘was the: elevation of: the dephlegmator, which ia \ iii of L. C. Ruff. } 605 was at a sufficient height above: the rest of the equip- -- ment to accumulate a head of liquid in the re- 923 flux leg which forced the combined wey through : the heating coils. The oii received its entire cracking\heat in the fur- - nace cracking coil. The normal liquid level main- tained in the expansion chamber was at about the one- third point in the beginning of the run and as the run at neat the level was built up until it peaine the alfway point or a little above. — unvaporized liquid in the expansion. chamber . Was continuously withdrawn through the residue lines 892 and sent through coolers to storage. It was not re- turned to the cracking coil. -- This unit was designed for an operating pressure - ~ of 200 pounds and the pressure generally used was from 170 to 190 pounds on gas oil and 110 to 120 pounds on fuel oil. The pressure was maintained throughout the system. . Operation of Unit 1-A on Gas Oil: In a typical gas oil run the transfer temperature was within ‘the range of 840 to 880° F. - During. the later operations, tem peratures of a higher order, in the neighborhood of -900° and above, were used. I was present at this plant shortly after the higher temperatures were used and I had available to me all the records. | I recall a run made on 35° Be. gravity gas oil at 170 pounds, which lasted about 8} days. The capacity was. ‘approximately 300 barrels per day. The transfer tem- perature was within the range of 840 to 870° F. The’ yield of Navy Specification gasoline by volume based on the charge was about 37 percent. 893 Operation of Unit 1-A-on Fuel Oil: On fuel oil the -transfer temperature in the beginning was within the same rahge as that given for gas oil. The pressure was usually between 110 and 120 pounds. On later runs the transfer temperatures were also increased to _. the order of 900° F. 924 I recall a run made on about 24° gravity fuel oil at 119 pounds pressure which lasted about two and one-third days. The fapacity was about 490 bar- | rels a day.- The ‘transfer, temperature was within the same range as that giver for the gas oil. The yield of Navy Specification gasoline was 35 per cent based on the raw oil charge. —— 606 Abstract of Testimony on Merits. . _ The reason the fuel oil run was short as compared to the gas oil run-was that the expan’ion chamber ac- cumulated carbon during these runs and onthe gas oil ' there was not as much carbon. formed-as on the fuel oil. Consequently on fuel oil, which contained more carbon forming material than gas oil, the runs were much shorter. That accounts for the difference in the — of these runs. Ke ) 897 e accumulation of carbon in tlie expansion drum’ - _° determined the length of the run. I do not récall-any normal run on either Dubbs Unit No. 1 or No. 1-A that was shut down because of carbon in the tubes. In all the operations on this unit with which I am familiar, the reflux condensate was returned in admix- ture with the charging stock to the cracking coils, and | | the liquid residue that remained in the expansion cham- ber was withdrawn fo storage and was not returned to the cracking coil. - + | ‘898 The No. 1-A Unit was accepted by Roxana Company after the test runs. ree ‘ - Dubbs Roxana Unit No. 2: The Roxanna Company installed another unit, called-Dubbs Unit No. 2, the erection of which was started in April 1922 and it was. placed in operation during November 1922. The de- sign and erection ofthis unit was under my immediate The following exhibits. are blueprints from the 925 original drawings of this No. 2 Unit: +#756F, PX 580; +862F, PX 580-A; #755F, PX 580-B: - #933A, PX 580-C;. #867F, PX .580-D; #866F, PX 580-E; #683F, PX 580-F.. = ~=—- : 903 PX 524 is a flow diagram which was prepared in 1923, sometime after this unit had been diated in op- eration to illustrate its construction and operation. ‘The design of unit No. 2:was almost identical to.that of Unit No. 1-A, with the following exceptions: (1) It had one additional tube in the heating coil; that is thirty-four 4-inch tubes 4” outside diameter and thirty . ‘feet long and (2) it had a vertical reaction chamber 10 ' feet in diameter by 10 feet high. The reaction cham- ber was set alongside of the furnace in an insulated housing. “ The process carried out in Unit No. 2 was identical with that carried out in Unit No. 1-A. ° a * and between 100 and 150 pounds for fuel oil. Testimony of L.C. Huff. = 607 In the earlier operations of Unit No. 2, the transfer temperature usually range between 860 and 890°. The temperatures were increased shortly after the unit was — built to the order of 900° and above. This applies to both gas oil and fuel oil charging stocks. . In typical . representative operations the temperature range of the combined feed that accumulated in the lower. part of the dephlegmator leg .in the overhead feed operation was between 700 and 750°. On ‘‘direct feed’’ it was _ somewhere between 500 and 600° F. ; 926 . The pressures employed on the No. 2 Unit were between 140 and 170 pounds when —— gas oil | he type of charging stock and the yield desired determined the — operating pressure. . In the normal on-stream. operations of the No. 2 unit at Roxana the reflux.condensate, in admixture with the raw oil was returned to the cracking coils, and the un- vaporized liquid that remained in the. reaction cham- ber was withdrawn from the system and was not re- turned to the cracking tubes. - ' I was in charge of the first run made. on the No. 2 unit. It was made on a 35° Be. gas oil at a pressure of . ‘145 pounds, and the unit-remained onstream for ap- proximately six days. The through-put was approxi- mately 300 barrels a day. The transfer ‘temperature - was about 860°: F. The temperature of the’ combined 907 ‘was about 31 percent of Navy feed was between 720 and 750° F. The yield of Navy Specification gasoline was 38 per cent based.on the raw oil. About ten percent of residue was produced dur- ing the run. It was a salable fuel oil: The second run-on the unit was made on fuel oil. ‘This run was made at 100 pounds pressure and the unit remained on stream for seven days. The through- “put was approximately 450 barrels a day. The trans- fer temperature was about saa or yield of gasoline Specification by volume based on the raw oil. About 40 percent of residue was 908 —— and the residue had/a gravity of about’ 16° © \ Be. After the second run-made on this unit, fuel oil was generally charged. _—_; 's os. Dubbs Standard 500 Barrel Units: The next unit ~ explained in the industry by the Universal Oil ‘Prod- ucts Company was the so-called ‘‘500 barrel standard “ ~* 608 © 909 3 Abatoait of Testimony on Merits. plant’’. That plant is fairly typified by the flow dia- 927 gram, PX 524, illustrating No. 2 Roxana Unit. _” The standard 500 barrel unit was designed for a nominal capacity of 500 barrels of charging stock. . This capacity was selected mainly because it was rather — high in those days and we entt it would serve the needs of most of the refineries and because we thought . by standardizing on a set design we would be ie to obtain better delivery on materials, better prices, etc., and as a result give our licensees a less expensive unit. Construction work on the first standard 500-barrel . _ units was started in the summer of 1922 and the first 910) 1924, 912 onés were operated in February 1923. In November 1922, while the Roxana No. 2 Unit. was © in operation,’ the Roxana Company ordered four of these standard 500 barrel plants and construction work was started immediately. During the construction of these four units, Roxana ordered two additional units and construction work on these latter units was started. in December. This made a total of six of. the standard 500-barrel units ordered by Roxana in 1922. The first of them began operations, as I recall, in June, 1923, and the last was placed in operation in January, - Model of ‘Standard 500 Barrel Unit: PX 581 shows © two of the standard 500-barrel plants. The furnace of . each plant contained fifty 4-ineh tubes 30 feet long located in a box-like structure. The total length of ‘the coils was approximately 1500 feet. Adjoining the tube bank was the éombustion chamber, containing fuel oil burners located at-each end. The hot gases from the combustion chamber passed overhead and down- ward through the bank of tubes to the flue leading to the stack. - A vertical reaction chamber was set along- side the furnace. The dephlegmator was mounted on a high steel supporting structure. ~ -/928° The oil to be processed was charged to the top. . of the dephlegmator by means of pumps located | inside the receiver house. The charging oil, in admix- _ ture with the reflux condensate, ‘passed dawn the re- flux leg and entered the lowermost heating coil. Leaving the heater, the oil and generated vapors: passed through the transfer line and discharged into the top of the vertical réaction chamber. Here the separation of the vapors from the unvaporized liquid — Testimony of L. C. Huff. 609 took pl place. The vapors pene upwards. Seren. the 913 vapor line, entered the bottom of the dephlegmator and ‘were partially condensed by the incoming raw oil and by the recirculation of pressure distillate withdrawn from the final receiver and returned to the top of the ; yy sone e remaining vapors passed fiom the top of the dephlegmator and then through the condenser coil la- cated on top of the receiver house. . The condensat¢ from this coil condenser flowed into the pressure dis- . _tillate. receiver w which was located. at the back of the receiver house. In the pressure distillate receiver the separation of the uncondensable gas from the pressure distillate took . _ place. The pressure distillate-contained the gasoline which was the’ prime object.of the cracking operation. It was withdrawn from this reteiver and sent to stor- ‘age. , \ The uncondensable gas was ¥ithdrawn from the top =>: Of the receiver and sent to the refinery fuel storage. . The control ‘valves were located-inside of the re- . ceiver house. - The unvaporized portion of the oil that remained in due lines: located on the side of the vessel, and 929 passed through a cooler and: then sent to storage. ere were three residue lines located.on.the side of the chamber. It was the practice. to start the run using the bottom fesidue connection. As ‘the coke level. built-up, the residue line became successively clogged with coke and it was usually necessary to withdraw residue from the next higher line. In some cases, however, complete runs were made wherein the chamber filled almost. completely with coke, and yet the bottom.residue line was used. 915 Ina normal operation the coke level in the reaction chamber built up within about. three or four feet of the top manhole, but in many cases the coke level was allowed to build up higher. This caused carbonaceous material to be carried up into the vapor tine and some- times into the dephlegmator and reflux leg, but aside _ from that it did not interfere with the ee of the | unit. In the early standard 500- hatrel units various .sized - chambers were used.’ In some of the units chambers 914. the reaction chamber was withdrawn through the resi- . ; 610 Abstract of Testimony on Merits. ten feet in diameter by ten feet high were-used. In others ‘two chambers were installed with the idea of» * using only one chamber at a time. The No. 2 unit pre- 916 viously referred to had two small chambers, the pur- pose being to operate one chamber until it filled with coke and then during the cleanout to switch the.trans- fer line and the r line over to the other chamber. In this case we only to clean the tubes and then start the run and the coke was cleaned from the first ‘mentioned chamber at the operator’s convenience while the run was in- progress. On later units the reaction chambers were increased |. in size to ten feet in diameter by fifteen feet high, and sometimes two of these vessels were used. size was increased to obtain longer runs, particularly 930 on heavy stocks, and for that reason we increased the size to -10 x 30 foot vessels, and some of the eats Sek ee SS Later 10 x 40 oot chambers were installed and on some of the larger plants of about 1000 barrels capacity, two 10 x 40 foot gy rene y re dente ll of the re of. ize of the chambers in all o standard 500-barre pits. the reflux condensate, in ad- mixture with w oil, entered the heating or crack- "ing coils and the liquid residue from the reaction cham- ber was withdrawn through the cooler to storage with the exception that in some of these operations we . tieed a ‘‘non-residuum’’ operation. -A non-residuum operation is one in which no residuum was withdrawn from the chamber and~the residuum collects in the chamber and is permitted to go to coke. The raw oil feed, was fed in many instances to the top of the dephlegmator to control the temperature therein. In some cases the raw oil was fed directly to the tubes, at other times it was split, part going over- head. and part direct. The reason for this was that the temperature of the vapors entering the dephleg- mator was between 775 and 820° F. and the vapors : coming from the top of the dephlegmator were between 540 and 560° F. is difference in temperature had 918 to be brought about by doing a certain amount of cool-: ing in the top of the dephlegmator. The raw oil ac- . complished part of this cooling. The other part was accomplished by recirenlating regulated portions of the pressure distillate. Testimony of L. C. Huff. 611 The recirculation of regulated portions of pressure _ Eettiake was chtained by withirowing « portion of the in the form of a spray into dephiegmator, . ‘931 wherein it was vaporized and immediately passed ty ane This partially condensed the "condita pas eer and Gin: aonb portion or. reflux te passed down to the refux leg and returned 919 Be ee vGireet feed or the split feed operation the charging stock which went direct to the coils en- tered the combined feed line just before it entered the heating coil wherein the raw oil was preheated at the. —— of the température of the reffux. . installation of the standard 500-barrel units was begun in 1922 and continued thronghout the years until 1929. During the latter part of this period twelve additional tubes had been added to the heater and man - of the units were equipped with hot oil pumps but wi these exceptions wy Oy substantially the same, ex- cept as to size, as 500-barrel units previously de- 920 scribed. Approximately one hundred of these stand- were constructed and placed in operation as a mg feed’* plants. The gravity feed was obtained by the long hydrostatic leg shown in the model, PX 581, and was the means for forcing the combined feed through the coils. charging stocks usually cha to the standard - §00 barrel units were gas oil, fuel oi and topped crude. “In a typical operation on gas oil ch [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386404_0029%3A02. Public record. Not legal advice.