Association for Information and Image Management



Cl £difcoru1^i



PART II (1879-1886)

Douglas G. Tarr Robert A. Rosenberg al Associates

John Deasey Barbara B. Tomblln Jacquelyn Miller Marla Antonakakis

Student Assistants

Rutgers, The State University of New Jersey National Park Service, Edison National Historic Site New Jersey Historical Commission Smithsonian Institution

University Publications of America Frederick, Maryland 1987


Reese V. Jenkins Director and Editor

Thomas E. Jeffrey

Associate Director and Microfilm Editor

Assistant Editors Paul B. Israel Robert A. Rosenberg Keith A. Nier Andrew Butrica

Assistant to the Director Helen Endlck

Research Associates Douglas G. Tarr Mary Ann HeUrigel David W. Hutchings

Secretary Grace Kurkowskl

Leonard DeGraaf Alan Stein Jacquelyn Miller

Student Assistants

Joseph P. Sullivan Karen Kozak Granville Miller


Rulgers, The State University of New Jersey

Edward J. Bloustein T. Alexander Pond Tilden G. Edelstcin John Gillis

New Jersey Historical Commission Bernard Bush Howard L Green

National Park Service, Edison National Historic Site Roy W. Weaver Edward J. Petshey Smithsonian Institution Bernard Finn Arthur P. Molclla


James Brittain, Georgia Institute of Technolog)' Alfred D. Chandler, Jr., Harvard University Neil Harris, University of Chicago Thomas Parke Hughes, University of Pennsylvania Arthur Link, Princeton University Nathan Reingold, Smithsonian Institution Robert E. Schofield, Iowa State University


William C. Hittinger (chairman), RCA Corporation Edward J. Bloustein, Rutgers, The State University of NJ. Cees Bruynes, North American Philips Corporation Paul J. Christiansen, Charles Edison Fund Philip F. Dietz, Westinghouse Electric Corporation Roland W. Schmitt, General Electric Corporation Harold W. Sonn, Public Service Electric and Gas Company Morris Tanenbaum, AT&T


PRIVATE FOUNDATIONS Alfred P. Sloan foundation Charles Edison Fund The Hyde and Watson foundation Geraldine R. Dodge foundation


National Science foundation National Endowment for the Humanities


Alabama Power Company Amerada Hess Corporation AT&T

Atlantic Electric

Association of Edison Illuminating Companies

Battelle Memorial Institute foundation The Boston Edison foundation Cabot Corporation foundation Carolina Power and Light Company Consolidated Edison Company of New York, Inc.

Consumers Power Company Coming Glass Works foundation Duke Power Company Exxon Corporation Florida Power & Light Company General Electric foundation Gould Inc. foundation Gulf States Utilities Company Idaho Power Company International Brotherhood of Electrical Workers

Iowa Power and Light Company

Mr. and Mrs. Stanley H. Katz Matsushita Electric Industrial Co., Ltd. McGraw-Edison Company Middle South Services, Inc.

Minnesota Power

New Jersey Bell Telephone Company- New York State Electric & Gas Corporation

North American Philips Corporation Philadelphia Electric Company- Philips International B.V.

Public Service Electric and Gas Company RCA Corporation Robert Bosch GmbH San Diego Gas & Electric Savannah Electric and Power Company Schcring Plough foundation Texas Utilities Company Thomson-Brandt Transamerica Delaval Inc. Educational foundation Wisconsin Public Sen-ice Corporation

A Note on the Sources

The pages which have been filmed are the best copies available. Every technical effort possible has been made to ensure legibility.


Rssl duplication of the whole or of any part of this film is prohibited. In lieu of transcripts, however, enlarged photocopies of selected items contained on these reels may be made in order to facilitate research.





Edison Electric Light Co. v. United States Electric T iaht^ go Volume n

Defendant’s Proofs and Depositions


Oirouit Court of ttte United States.


IN EQUITY No. 34.45.




Yol. II.

Defendant’s Proofs Depositions.


Defendant's Solicitor*.





Of Counsel for Defendant.


Allan Man's direct.




The Edison Electric Light Company, \ Complainant I


The United States Electing Liohtino Company,


> Letters Pat- on t No. 223,

Pi oofs for fiiml hearing, taken oil holmlf of defend at. , punuaut to the 6711. rule in equity „s 1003

hoforo Samuel M. Hitchcock, one of tl.o si nmiiiurs of tho snid Court.

uudiug ex-

Ne"' 1’ohk, January 11th, 1890.

Parties meet pursuant to agreement.

Present Amos Broadnax, Esquire, of counsel for defendant.

Clarence a. Seward, Richard N. Dyer 1004 and S. B. Eaton, Esquires, of coun¬ sel for complainant.

Broadnax! to.llLTfolto« : 03Eam,ne<1 bj Mr'

oceupatfc!uaSC J'°"r mi“e’ ',g°’ ,eSitlen‘;0


A Won Man's direct.

quontly I did boiuo little work in t 0 ^

I have boon Dirn ,‘° 8PrinS of 1880. Light Company, organized in °t10 EI°ctr°-DLa»'nic exploit and carry oTZ K 8ummor oM878. to nnder the patents of William °E S°f eI°Ctrio ''Siting the sevora. "* «

fc iSittrss'sL-

I have only acted in i

«|1C0 the other comn'nuiX!?!0' witI‘ ^tor-

%°a,nic Company, Z i "r"” tl,e E1^°-

performing „„y experiments lm t dir^'t® "°rk or

O rufnrence to the same’ d,rcctlng and advis- , Q‘ St,lto whether you „‘rn ,i

"'h080 o«».n appears as joint •nve .8''lm0 AJb°n Man S^or i„ Letters Patm o "r T0TrWi l1 WilIian>E- 205,144, dated the 18 I t * U,,ite<1 States No

1608 in Electric Lamps: ^ 1878> f°r I-pror^Tt

Also Letters P„te„t v „„

18?8' for Regulators t. tecWc T05', Ju“« «*.

Also Letters. Pnto. * , ,c n Lights:

303, originally dated dVeMtl^TLo1'1'0''’ No- 2°5.- Juno Cth 1882, „nd „nmI^ re~d

Electric Lighting System: ’134 ot ru-«*uoH, for

A Won 2&ai£«


»«w“S" SM "‘ S“'“. N0.

M-STrS* *■

JS^rtsjsrtT •r“"“i.7ii’1879' »>

EtatrfcHta m OiirlioaH far

29U,l818^tarHlPnt0'?t °f 41,0 DnUed States dated June

188°- aml numbered 229,335: inn


•«. Sr^x/Yoirmir; ,b r wc n,e:

SXp,2 1881,

A. I am.





c v!:;^ ^,v:^Li,,;1.,)vfe,,tl,uitv

Counsel agreeing to produce the origin! lt

vllftTHZ' \ ;'" *«• ■•»,. iu uie

'7S .

«».«*: . . i.iifaLJt . .

» <r iw..j-,„e ki,,,,i|>lcrtU,( imJ lllU)_

-1 lion Jfni't

varying, but some of the smaller diameters being tbo greatest lengths. "

Q. In your last answer true as to the carbon-ilk minants made and used by you and Mr. Sawyer i your other lamps ? "

A. To mv best recollection it is as to all of them m copt ns to the shorter lengths.

Q. What kind of carbon illuminauts wore used b you and Mr. Sawyer iu those lamps ; give the nmterii Of which the carbons were made and also the form of- tlio llhmmmnts.

A. First as to tho forms-straight poncils of carbon V-shaped pencils of carbon, arched-shaped carbons hko circular arches, elliptical or loop-shaped arches arches with varying contour in tho gonorul form of the arch ns though the lino of the arch was laid in waves, and arches of liko shape with angular points in the lino' of the arch, and porhaps other forms; some of tho con¬ ductors of all tlieso lengths, shapes wore, some of them, flat in cross-section, sorno of thoin elliptical iu cross- 1 section, some of them round iu cross-section some of them in the form of a trough or U iu cross-section some of them tubular in cross-section and primps •thor forms; these I recollect now; tho material of the .-ui bun-illuiuiunnts we used was gas-retort carbon, elec¬ trically deposited carbon, cai lions made by carbonizing ibrous materials, carbons made out of lump-black au 1

A(t*on Jfttn'n direct.

eferring Wk to the forms of cross-sectioo of the motors, thoy were not always of the «, f01 "ghoiit the length of the conductors thus, tulml -Shaped conductors throughout their main |„„„ somatiiiBS solid, ami r mini, or, Id at the omh lat comluctors throughout their ■■lain I, mi -th i timo round at the ends, or with enlarge | ’omLs,°' uululy fluttonofl, or both.

Jorn^tothohrstr.uostior . regard to the Ugt

" ductors, these „ilu form of lamp wore sol i from five to eight inches long, r speak from r'

m'vlrvi cross

inc v ' 7" , mt tllirt)'-sccond to a (iftiotl , Ul ' ll0“ t.nished, and wore treated hv us elec


, l menu that each end of the <1T°l,-8i‘ of onrhon upon it.'" ,0U ,lt,no<l,!l‘!ro

"V"*- -

«.W,hedinthep«;o ^ ^ ^

id to Mr. Sawder ? ' 1 ,2> Ranted to

taLir,',,^n,.'.U0,'H the kinds

8011.0 tnncle of wijlmr w»<m] woro *" "r

to tlio .. ru WHM-Wiioro, ftccorili

than , V r‘'co,luctl"". from a fiftieth to 1,

tlinn a sixty-fourth of no uch in cross-section

14 Q Referring now to the car^ilZlts of powdered carbon mixed with tar, glue or sugar other carbon, zalde material, how diifyon proctl'd make such carbons, and wind was the length., nd erl section of them V b

A. We mixed up the materials into a thick nasi and rolled them out, between ineliil plates, for thomo part. I also went up to tho.Eaglo Pencil Co,„pa. and endeavored to have them formed ns they mat lend pencils, by pressing then, through a dvo we ah mixed the material „p and put then, i„ damp powderr

tlmt in! ,le"! " ‘'a8e 1,,lv,nS a follower and p,

that into a hydraulic press mid pressed it down i„t the for,,, of a thin sheet or dike, consolidating it in! a substance ; tbeso wo subsequently carbonized "m<,° »" !>r«s after cnrbonizntio partially, were cut into tbo slmpes wo desired, stmigb pt ncils or arches, and then re-oarbonized, and nil o the conductors were finished, by cementing to a Inn ,kB /; r*? °f P'ate glass or smooth metal and w J ■eg them down with files and tine emery paper - the, -re then usual.y, if not always, 01.0,5^1^2


A /Aon liftin'* t/ircct.

1629 - -

of an inch, to tlio longest, about two inches ; their cross-section usually about a twentieth of an inch, but dimneter Sn,0ller~I Kl,0nl,i tl,ink ">«>'“ half that 15 Q Are you al.lo to produce a apecimcn ofany of

lOSODyimnne Comn !’ i '""I °f 11,0 ofruL'Ls of 11,0 Kluctr°-

3 rr ° ° OXL'8 of0"rl«“H. which wore

■S7», "n *!'« »'

' r "•*

to find the other box, but think I have it nl ' T I l;avo a lamp, an old lamp, with ' of , '/ i,°UH° : m it, somo inch ami a l„.lr i , , carbons

1 now have and produc I * Himilur U> ‘lioae logically treated and is now of tl" 1)00,1 oloctr‘-

1 1’todiieo, showing tha lmt'w °f

less in cross-sect;, n o. ioro treatment it was

containing some f tl T 1 ',0'V P«<«»cu a box m-v -Ufa all the time s^eTi';; ^ h"«*

%namie Comnanv in .1 ' C frow tl10 Electro , 1'- 1,1 f'e Spring of 1879.

offered in evideuci>l<ll'U<i<!l* ^ tku witness, nation Tl r . “,,d ,,mrkei> for identiti-

1632 ducud ’by LbouUnu i*'f f *>ro-

90, S. M. H„ Ex. Jm,y “‘It,

My recollection in rear,! >

.by us has Iteei! refreshed by H 'r "T °f C‘‘rbo"s '«ed

- never gra U * °f iluM *

80 S""'11 M we desired ultlioiml ^ tliau these I produce, and If H°“° "°ro Hmilllor "orkiug them down on •, r 111 11,0 l‘«Wt of

1 I think, fully onq-half or

A lion Alan*# direct*

nioro, when wo wante,! to make conductors of higl H.sta.|co out of them, and did so very frequently

IC Q. 'these carbons that you have produced, 1 they been electrically treated ?

A. They havo not.

17 Q. Do you wish to bo understood as saying these carbons wore frequently rubbed down on a plate or lap, as you style it, and then eleetricllay t, od before they were put in the lamps for use ?

A. Yes, cemented to tbe laps, rubbed down, or down, or both, to less than half their present size then usually treated, but sometimes not alums’ ways treated. This was done in order to’ make t resistance higher.

18.,?- "’Imt Wa8 tllu electrical resistance of the Iran illiiminants used by you and Mr Sawyer in lamps?

A It was extremely various ; I know its lowest 1 was less than one ohm. I can only state the i.ighes sistuucu from recollection of surrounding circ stances, and comparative cross-setcion and lem-t' conductors. I place it, thus, as in our higher resist lam|», from thirty to fifty ohms; but nlthougl measured the resistances, I have no recollection o results of such measurements. In the treatment of carbon after they wore placed in the holders o lamps I havo reason to think and believe that I resistance before treatment was sometimes doubl

that, and I think as high as one hundred ohms. _

(Tho belief and tbe thought objected V Complainant’s Counsel.)

19 Q. I place in your hands an electric lamp ; p examino it and state if you recognize it as one c lamps made by you and Mr. Sawyer?

A. I recognize it as one made bv Mr. Sawyer myself while wo were at 94 Walker street in the ufl878, or winter following; it was in my posses

'VO left tfmt place in the spring „r "*■01 ns «n Jixhihit jn another

i,,»> iHurainant still i„ (|lis |IlI|lp, ip tlio snmi! us it was originally put

vo tl*o .form, Kfao and resistance of

l,u ,lb"'>* five-eighths „f,„n ' ends are either solid or

H " *.el'_, ,r„|, soli,l ; j,s total u> bo; ,*iIOIIt twentieth of an | outsnle m j,s Ialw,st diameter;

, ls'1 ‘rough or shell, its e.oss Si1 hl!0- t,,t! U. The shell f ‘I'ioknoss of orer

^llir’!,f f t',0I,-*]**-r«.I„„, which . .

nlU>r- *1*0 shell was e t its resistance I cannot tell butjndgo "'mis, possibly four to ten. J "

offered in evidence same I urkecl as follow .4 n * 1,11 e,nf> ISxliiliS» u CaKw 8,472, bo.


I' ami Mr. Sawyer in 1878?

or earl/u-inL'rVf1 *).j W^w""

. . . -*f «■«* i-n ni

"*w. somewhat longer than this, got broken and I J Ht-tu tod this globe, Which is one that we ,se ! , tune in order to protect the works of the lamps!

-4 tj. Is this lamp one of the same tv nr. r i that .s described, illustrated ami claimed, in the 7 tent Patent 317,070 issued to von and , c L 1 2, 1880 ? - " •’ '• ■Sn".V°r, 1

A. It is b„t parts of this htm,, are gone.

-Q. U hat parts of rhislampare missing?

A. 1 he binding rings and screws, and most of carbon illnmimint or ii c u I s . , c , ,“t , cap or cup at the base 1 t] c dm , 1 tr f

lamibwl^hwasanitrogcct, 1 * '

Q. Mint do yon mean by a nitrogen vacuum ? 27 Q The globe of the lamp being charged as I ,

d retain! you, the same substantially as d! ’r bed 11,0 Nl>- 210.809. grunted to you and Mr. S,

this 01180, Defendant’s Inhibit Sawyer- 2> Casu 9,472, and marked also in this ), Jan’y. 11, 1890, please to state whether globe of this lamp was also charged and Btl,1,u “a in Patent 210,809. aUl.e tune it was made, the fall of 1878

‘t "as tllu character of the carbon illumi- ‘»>l> parts of which I have called your nt- s morning, and which I now offer in evi- “‘me being marked Defendant’s Exhibit -Damp for horso-shoe carbon?

> of those that we made and used with an U-sImped carhon-I mean in its length,

i nost'aH UT‘"i °r U «ar-

l uos a I made of hhrons curia,, ., produced

«, "J 'U"1 Hixo‘ "ood,

tr I '"!'' 1 1,111 Ull’b mining them in a

',l!r 1,?uk<!‘1 . . carbon.

T T tl,U lli"Htl' ,,,,,, cr<|ss-soction of

Jl,0° f<,r,“ "f «*'"•» ill... . it in th J

|;';;g<b varied, between the Clamps or con.

' <mt three-quarters of „„ ilH.|, , ,

* ‘Kv

resistance, perhaps higher; I judge that some of th, were frequently from 30 to 60 ohms resistance, nf treatment l.y depositing carbon on them electrical " o measured these resistances, or rather Mr Sawy did, and I knew what they were at the time* but I cu not recollect.

32 Q. Please examine the carbon holder in tl horse-shoe lamp, so called, and state if you tin, I ai portion of the carbon illuminuut left between tl

A. There appears to he a piece left between o, |mir of tin? dumps.

33 Q. How long have these damps which make p„ jf this lamp been in your possession, and where <1 rou get them, mid are they now in the same conditi, is when yon did get them?

A. 1 got them in the s wing of 1879 from the wor 'hop of tbe Electro-Dynamic Company, No. 94 Walk, ilruut, this city; they remained in mv possession, pack, ip with other lamps of the Electro-Dynamic Eight C,

1 "‘V I'*'100’ 3 Mercer street, Xew York city, for

-10 Q. Wlmt, if anything, did you nfter tl 1,10 1,,IUI> Held, toward excluding or dr the ocelli lo I Rases from the c rl , ,11 IIuilI other internal parts of the laiup-I mean thee «».V oilier carbon-consuming gu« (lmt may In occluded by the internal parts of the lump— li final sealing thereof?

A. Wo heated up the ontside of the lamp exhaustion was going on, and turned on cn electricity and heated up to high incandeset carbon conductor; the other parts of tho lai also heated by this passage of the current to f tent. A ftet' allowing tho lamp to stand witl haunted atmosphoro for some time, wo repeat operations after again washing the lamp out w nitrogen, tho object being to carry these in out of tho lamp ; wo frequently ropeato.l thes for several times, meantime closely examining lion while illuminated or its image as project screen, and greatly enlarged.

41 Q. Referring now to your motho.l of seali typo of lamp, and of driving out tho occluded was that method pursued in making all tho d types of lamp made by you and by Mr. Saw 1878 and tho early part of 1879, or down to th you and Mr. Sawyer separated ?

A. Yes, substantially, the details were not

pruN"rvi"« tl,at »>wm


. . .

* . 3tflt


I1,’.1!1 tl"' •Sl,,i,,J! of lS7!t 'roko 'H' 1,1

„I mV oH.f"'“ ■*« Hi.- -V, . . .


«*Ui tlm conductor ; where nrchod c„rl,„Ils wnn


.< .i» Li».


•' ‘IjUBt.uont „| ,, , , U“ 1 1

.'.'“I *■* »-«

L 1,lM,,Ilce8, especially with the arch.

arc-light, lamp ?

,A' U "* ,l" '"““'“loscing l.iinp, pure and simple- tl occuirenco of an are would destroy its operation f, . , t,'"u 11,0 cn,'1,0» conductor should he fed t

intentionally to make contact with the upper hoidc or carbon -rolls by the electro-magnetic apparatus the biiHO of the lump.

mako? H°" ,,m,° °f tll<!8° l'"ups ,,i<1 Mr- Sa'v-Vl A. I cannot at this length of time pretend to re,-, lect numbers definitely; my best recollection would b or is, that he made while wo were at *J4 Walker stre,

, <loze“ to twenty lamps substantilly like tli while we were working' together; after I ceased to wo with him at that place in March, 1879, he went on ai

made a sot of eight or ten more, which were naid f by tho Electro-Dynamic Light Co.

Recess for lunch. Adjourned to 2:30 P. M. Examination lesumed after lunch.

50 Q. Please state what the average length of ci

, ;■ . * 10 my otin

ivlion wo left, hoomiso I Jmtl Siit it up with n >wn during tlio summer anil until nerlnii

IO middle or last of August. On suveral occ! lions I put up that lamp at Jaekson’s place in Centi itreot, where I had a dynamo placed, and lighted it o show to my friends whom I took there to see it, an on" ,Hr '.,loro "‘-■easious I left it running there and rc

n rued for it at night before going home from myoffiei n Aug, 1878, this lamp was taken to Howard and Ocn re street, and was run there for some weeks when,™ ..yone wanted to see it; it was finally broken by ar iilent. Of tlio lamps which we made after going to th oni e r of Walker and Kim slreots, in the month of Oe ibor, 1878, a considerable number woro in good eon ition and seomoil to bo perfect when wo left there ii 10 spring of 187!). I saw suveral of these lamps tha o made at 1)4 Walker street while we woro tliore, run mg on mie or two occasions at a place .Mr. Sa’wye iid in October or November, 187!), I think at Wes “h street. They seemed to lie in good condition tin 1,1,0 as when we left Walker and Klin streets. I wa> ""'0 I’orhaps an hour or two or three hours on one o

lose occasions ; the lamps were lighted . . . I weal

ore and remained so when I left. I have some lamps >w in which the atmosphoro of the lamp lemains per- at to all appearance at the present time. bG Q. Who woro the principal assistants of yourself d “W- Sawyer in making these lamps at 94 ' Walker

A. Mr. Edward Myers or Edwin Myers, I don’t know 11° I, Principally, with the assistance of William E. wyer and sometimes myself did the setting up, ex- nsting and charging and putting in the carbons, ’and lll"g "lb utter we went to !)! Walkerst.; Mr. William

tlio, ..Ull,i11„. . . . Sl"«10 1>

. . t.s^’rssKf

set r* . . C*

ZZt^rT * 'Vi,ls“'“ li- Sawjori

71 0 W "-r WUK "‘ 04 W«HfcT Streo

San t Q‘i " ,,lk' 'f ,l,y* knowlmlnu iliil

of ; lmv(u ,lt ll'»‘ H««o Of ,1,0 IIlllkil ' j

ofTucbJ&T1^ 1

conductors l,v which ^ f - lt,,,*1,,,t5-


"‘loo* forms iloMJofJk . 1 "‘USU

nents witli . . .. , t,.,uw of Crooks

snd superintendent, Sir. Sawy. n^X”" position to tlm Electro-Dynamic Companv i'ts Monts, the outcome of all of which was that Messrs

voreTir,r7,,‘1T‘!<I ‘I,uil ,K-C,SL 1 ‘ho patents presold out ami convoyed to the Eastern Electric ^ompany. II, u latter nnulo some ellorts to intro, luce 171 !‘ml,s m"’ otIlur apparatus into uso, under the

s,;7or’ b,,t i,,s »»<=!■ that

the end they sold out and convoyed the patents to lie Consolidated Electric Light Company.

Adjourned to meet upon agreement.

Nkw Youk, January 22, 1800. j71

Met pursuant to agreement. Present counsel as hc-

Eiamination of Albon Man continued 75 Q. You have stated that in manufacturing y<„tr m.P8- f d % took tl to ro nved the

irbons, and sot them up again for further proving 1,1 testing. Please state how you sealed your lan.i.s i' the pur|>oso of such testing '!

A. Whether I have so stated on my present esamin- loii or not I do not remember, but such was the fact. 171(1 y description in my testimony in this case of the 'ding of the lamps, the soldering up of the stop, nks and orifice of the binding nuts, and the coverim- all the Joints with a prepared sealing-wav, coverin'"

3 binding screws with a cap tilled with sealiim-wav"

■lowu to ami including x-Q. 318 <1, ami the an¬ swer thereto. From x-Q GS4 down to anil including x-Q. 7(11 and the answer thereto. From x-Q. 7G5 down to and including x-Q. 8!)7 and tho answer thereto. From x-Q. 1.987 down to and including x-Q. 2,088 and thu’ an¬ swer thereto. And,

It it is further stipulated that the Exhibits pnt in evidonco, as parts of said deposition, are to he considered as Exhibits in tho pres¬ ent case, excepting where said Exhibits ap¬ pear to ho mere duplicates of Exhibits else¬ where put in the case.

rt is also stipulated that a printed copy. With the portions omitted as indicated, may he taken from the printed record in the case re¬ ferred to, and used ns a portion of the origi¬ nal record in this ease.

Counsel agree that the following is the dopo- sition of the said Alhon Man with the parts omitted ns agreed upon, which is to stand in ewdence in this case, as a part of the record hei ein, to all mtents and purposes as if it had been taken ,llis C1ISL, j„ f,u. „„ t,JU ^ ma\ he applicable upon any issue in the case.

Albon Man’s ^position in the McKeesport

Albon Man, being called on hele.lf f i and duly sworn, testifies as follows ^

tion ?"' 1111 1S y°"r ""m0’ n«®’ rrai,louc<’ end occupa-

A. Albon Mail * lirru no .. f—, ns Putnam^aveiniifUnBi()ok]vl”!>'Vllr'lH

:;;;r . .

Q- h. Ain jou the same Alhon Man that testified ou

behalf of complainant in a certain suit in equity pend¬ ing in tho Circuit Court of the United States for the Southern District of Now York No. 3,»53, between the Consolidated Electric Light Co., complainant, and the Edison Electric Light Co., and Thomas A. Edison, de¬ fendants !

A. I am.

Q. c. How recently have you read vour testimony in that caso ?

A. Within the last week or so.

Q. d. I place in your hands a printed copy of your testimony in that case. L’leaso to examine it, and state if yon rocognizo it as your testimony ?

A. I do; it is a printed copy of my testimony that I have read and referred to in my last answer.

Q. o. Is your testimony in that case, as there print ed, a correct copy of tho testimony given by you in that caso?

A. It is, with certain verbal corrections, of which I have mado notes, nnd which nppear in tho paper I now produce, and iwitli tho exception of some other slight typographical or clerical errors, or errors in ortho¬ graphy which do not clmugo tho senso or meaning (or at least tho souse or meaning is apparent in the print¬ ed copy), of which I have not made note.

Q. f. Upon what page of this printed record does your testimony begin, aud on what page does it termi¬ nate ?

A. It commences on page 304, and ends on page 924.

Q. g. Are tho several nnswers made by you to the questions propounded to you as printed in that book, true, aud would you, if tho sumo questions were pro¬ pounded to j ou, again make tho same answer ?

A. They art true to tho best of my knowledge, re¬ collection and liolief. I notice nothing therein to cor¬ rect, except tho urrors I have before mentioned. I should make the sumo answers oow as I made then, unless I should find myself mistakuu as to any par-

A lion Man’# direct

ticular to which I testified in detalM^lid^^

W.hld"8 °"‘U ,,,0,, 11,0 Hulj 1 ‘owWohl

in I’l'.ff y°" "r° T M0meA' 1,0 y°" «*• vtMng

the nnsncrs giTou by you in this testimony that you 7"1 excepting, us pointed ont in these n te"

of correction presented hy von.

A. I (]„ „ot.

Notes of correction offered in evidence, nml ’34 marked ‘Complainant's Exhibit Mans cor

reotion 0f the deposition „H printed given by ‘"“■ e Case 3,533," and the Examiner isre- questedtoeoircctthc printed 1 position in conformity with these notes.

*• Aro yon willing to. mid do vm.

A-les, sir ; with tilocoreetions I have noted.

PoSr /,!' C0m.p,nim,nt offor" U«° »nid de¬ ferred to thorehi '^hTcna!,'1 No“ 3 r ' s’ ' ^ t?'

New Youk, April I I, 188 Parties met pursuant to agreement APPEAUANCE8 :

Messrs. Broadnax .t Bull, for complainant Messrs. Tomlinson .fc Dyer, for the defendants. Auio.v Man, a witness produced on la-half of complainant, being duly sworn and interrogated Mr. Broadnax, testified as follows t_^Q. State your name, age, residence and ore,

A. My name is Allan, Man; my residence is I utinan avenue, Brooklyn ; r am a lawyer by mo ston, and my age is sixty years. '

2 Q. Are you actually ongaged in the practice of law, or lmvo you any othor occupation ?

A. I am engnged in law practico and nlso in ele, cal work.

3 Q. What is tho uaturo of the electrical work i; wliicli you uro engaged ?

A. Tho manufacture of electrical motors stoi batteries, and tho olectrio light, with tho de’visin plans and apparatus for tho use of electricity in p,; 1111,1 11,1(1 for Hio methods of producing elect

ciirrentH cheaper.

4 Q. How long sinco you first turned your atten more especially to electrical work ?

A. To electrical work proper in tho month of J, ary or February, 1378.. Before that time from al the year 18GG, I had made electricity a special sub work "< y ^ i"formatioi! 11,1(1 pleasure, but not

5 Q. Sinco January or February, 1878, about mue i of your time has beou givon to electrical w and to Wlmt extent have you followed up the pro.,

, 1,0 'TP'ication of electricity, , rc , tc 11 electric lighting and other kindred subjects ?

, . in/n,nfloft

lIsei P,lPor. ii great variety of woods, jute ton threads, l.rooia com, „„d a Kroat v,’lric,t or substances „f tihrons, t.-xlil,. material ; bloom eer", as I now recollect, we also used ii ug, 18/8. 1 think jute ami manilhi were also

>os|/rin„. The paper and wood were positi 1 ». the spring, h„t I an, not so certain of the iimntHti.

> Q. Please to ennmerate some of the difle is of wood yon used in the spring of 1878, and different kinds of papier used hv von duriie> ii time? ' ?

First, ns to the woods ; we enrhonized a great ' of woods in the spring of 1878, among wl '• "il.ow, maple, birch, elm, hickory, lignum v nr, and others that I do not recollect distil, c got all we could find, I remember one thing I id m the spring of 1878, hut I do not . ., I say nmnilla pane,,

s strong lioiiil paper, line . ^ M

",(1",,,r.v Wotting p„,H,r. \yL. IWU

I turm-il rings ? V, 'f ", II.

t turning a ij , . . ‘-•""‘'"ill on « latliu

1 of cutting tllu , ml' "u ««lo|>teil I

l‘o carl ion we desired ,* V hn '"‘“"tinlly to the s "inizcil it 1 1 l'W(t it to shape ami tl.

lor anil of the papor« or other substances to I LMiized, until the boxes were tilleil. They were tin i0< ' <,,,wn' C0'-°'0<1 up m„l the covers fasten , h then place(1 in the fan* ami heateil until earho, After being carefully cooled, the boxes wer> ll"il the carbon taken out. ' %

io wood carbons wero carbonized in the same a

o frequently worked the carbons down •thed them off after taking them from the box. % soaked them in sugar in some instances, and fr l)le. " I0„ WU l,i<1 «<> re-earbnnize then, in a box

j,,,V0 °,DilU!<l ‘o state that the ends of paper a, carbons in the loop and arched fonns we b enlarged where they were to be attached to tl uctors, but not always. In some of the woe ous that we made of thin veneers. I think of ros am mahogany, we worked the wood down im UL t mi anil tenons sheets on a lap, or fine on '■•per, cemented to a lap, and put several of tl » together, in some instances with gbie and ' 1,,stauce8 with sucar. so that the fibre of the wo,

loctro motive force.

Tlio practice wo adopted in April, 187, S onizo tlio papers without any such treat] uttiug it in the boxes and covering it wi 11 ’on or P°w<loro(l plumbago, ns r jmvu c I'oteet them while being carbonized. In < u carbonized the paper without anv y'oml that of cutting it to the desired siz Q. Did you over treat any carbon iper or wood with plumbago after carbon A. No }, we never did.

-8 Q. You have stated that it was your

to to front the carbons after carbonization ice of hydro-carbon gas— for the purpos, ? tlio carbons and equalizing their resi L“ process reforred to by yon the same a bed in your Patent No. 211.2IW

rl'«l agreement of the Mnv lH7q -

JJS nun suction II, •' r III, "h,. i.i’iui ,'r U":

. . . —‘U?r lii„, n^ Z^r'mU,WO'

Sawyer. ‘I’li,, . ■" H,,l» iiirimtio

1 8 7S , .’"I1 of tl,u 19,|,

i,,v"iiliu„ is ''°-r'lH °r l,’n,,H> wfcr

fWii,’ t>> this, i„,f„n. H,";j;;«i,,mii.-r„niiwN,

. . . . ui,i,rn„ 18I»

. . .


|r'"l'T lintl, , 111 Suit?

f/’10 imijt,.,- of takiu

!"7 ° «K'W„I ,i„t tlmt liroi

lie legal question tlmt wlmt Was pro,

tc.r off,,et,,„,| lmv, . . . inventio!,.

i ,, i" II ,,r ,1,,t tr'"’ tlmt fro,,,

nml Mr -Sawyer start, •, 1 i„ to work ^. 'it No.i.CVn, m street, i„

1878, the in volitions made ,„„1 p„t, In m jointly wore tlio joint producti-u working togethor for a eo,,,,,,,,,, end A- It is true tlmt tliev wore our ,lH 1 lmv<-’ already state,].’

II Q. Can yon produce anv inent ::P;°:r,,lauo|,,a,,lpl„u,;1,,n tl a Kliicli llieso earl, ons were used linvo I, eon testifying, of filaments of ; 1 l,,,VB a'*d produeo « K|„s •andescont electric lamp wliiel, I ,„v

glass nnd put on in a melted state upon tlio globe proper.

In tbo month of April or May, 1878, and boforo we left 43 Centre street, wo got a mould for making the flaugo upon tbo glass at tbo same time as tbo making of tbo globe and coasod to lmvo tbo flaugo put on with a separate pieco of glass.

I distinctly recollect tbo uso of tbo papoi, wood nnd other fibrous carbons in tbo form of lamp, tbo globoof 180G "bicli I produce. We did not bare any lamp globes mndo after leaving 43 Centro street, in wl.icb tbo flange was made of a separate piece of glass fused on to the globe.

Tbo lamp globe produced by tbo witness is offered in evidence by complainant's counsel, and is marked " Complainant’s Exhibit No.

, ? 0 10 of '““I' produced by Albon Man, April 15, 1887.”

1807 p AjJi0Un‘e<1 t0 S«tur«l„v, April 10, 1887, at 1 o'clock

New Tons, April 10, 1887.


SC f 0nr,mx lt Bul1' f0r 1,10 complainant. Messrs. lombnsou & Dyor, for tbo defendants.

Parties met pursuant to adjournment.

xuetl by Mn. Buoadnas.

.is o IT; -r ,,rr,,,w tl,um- 1 >"‘<i Homo.

four Kxliil.iVxo. O!)?1"""’’ W,‘° ",n<lu tl,iH KI,UM (?!"

A. I had globes Kko t)l(!I11 Imi(]o nt tW()

111 tl"' fciwtvru District Urooklm T ° . . i, uroiiKyii. I cannot nlo

50 Q. After von 1 ul’ s'1"' t,lul“ made,

reel, i„ Af uct, 1ST ,n i" 8""y<,r ",,nt to 43 Centr

'.v . . . A'Sii ir:. n1 n-\Harer ,u!ik

"■tors were sealed it tin, ,.| ! ' , on,li,'R-i« con

fusing the glass i, non tl “''"'f ul"""1,«rof tliolnni] u glass cliai: ' m«l in wind!

issV S su,llui1 tlx. fusion of tl,,

tliu b'lolt.s Of our ‘SOm‘! "f th° f,,K0<

s!utuow,,:f^'70liuul-wl‘- Mr. Sawyer ,lid

colcS!;^ h ZttlomT 1818

p!» 5f ^

In that "av, ns I understand you, an alb-lass

Jasr * e,"“ >“

A. Yes.