Wong assumptions, cabbage conclusions.

First, some basic thermodynamics. Just because I can.

At this point I see confusion as to the motions in limine. “Granted in part and denied in part,” what parts? Color my mind boggled. That her reasoning wasn’t given, that’s not surprising, Altonaga can do that. But that an order is entered, that can’t be understood, that is unspecific, is unexpected.

In any case, I decided to pay more attention to the Wong opinions. This is a study of his Expert Disclosure. It’s cabbage, appalling.

The document from the docket is image; the text here comes from OCR found on thenewfire (I used the OCR of “233”).

Prof. Dr. Kaufui V. Wong, Professor of Mechanical and Aerospace Engineering, University of Miami, shall be testifying as to his opinions concerning the heat dissipation facilities designed and provided for the E-Cat plant, and rebutting the accuracy and reliability of the reports by Mr. Murray and Mr. Smith.

The context should be clear: expert reports from Murray and Smith were already provided. This opinion is reactive to them, and of particular note is the opinion about the “heat dissipation facilities,” where,  apparently for the first time, the “heat exchanger” is introduced. Wong critiques Murray and Smith for not mentioning it, but before it had been claimed, to be sure, they would not describe or discuss it. Previously, on his blog, Rossi had made claims about heat dissipation, and no heat exchanger was mentioned.



• To evaluate existing conditions, photographs, documentation, and authorities on thermodynamics to determine the feasibility of dissipation of 1MW of heat energy at the facility located at 7861 N.W. 461h Street, Doral, Florida (“Doral Facility”).
• To evaluate the propriety and accuracy of the opinions rendered by Mr. Joseph A. Murray as contained in Expert Disclosure of Joseph A. Murray.
• To evaluate the propriety and accuracy of the opinions rendered by Mr. Rick A. Smith, P.E. as contained in Expert Report of Rick A. Smith, P.E.


Leonardo Corporation is a company that purports to have invented or designed manufacturing plants and machinery for the production of energy from non-conventional sources. Leonardo Corporation refers to its energy plant as an Energy Catalyzer or E-Cat. Leonardo Corporation refers to its technology as deriving from “LENR” or Low Energy Nuclear Reactions. This expert has not been asked to opine, nor will he opine, as to the nature of the reaction underlying the E-Cat technology or whether such reaction is in fact occurring. Leonardo Corporation claims to have operated a 1 MW E-Cat plant at the Doral Facility for a period in excess of 350 days while suppling [sic] the steam generated by the plant to another business located within the Doral Facility.

In spite of this, Wong, and without knowledge, opines about the nature of the technology in his comments on COP.

On January 30, 2017, Mr. Joseph Murray rendered an Expert Disclosure in which Mr. Murray opines that:

Technically, while this was called an “Expert Disclosure,” it’s written in the third person about Murray, submitted by IH counsel. There is a deposition by Murray with far more detail.

• “[T]here is no logical reason why the COP should be changing inversely to the amount of power imputted [sic] given that the same E-cat plant was used throughout the ‘guaranteed performance test'”; and

• That given the conditions at the Doral Facility, the supply of 500 kw to 800 kw of heat would have rendered the Doral Facility “unsuited for a human working environment.”

Also on January 30, 2017, Mr. Rick A. Smith rendered his Expert Report in which Mr. Smith opines that:

• “The Penon reports, standing alone, are not valid to tabulate and compute the performance of the E-Cat. The data are suspect and the methodology is not explained,” based upon Penon’s use of COP to calculate the performance of the E-Cat; and

• “The E-Cat never produced the energy which was claimed for it. This energy had to be rejected somewhere, and this analysis has shown, by the process of elimination, that the claimed energy never existed.”

What I notice immediately is that the reason for the Smith opinion may be improperly stated. I’ll come back and review that.


This expert undertook a site visit to the Doral Facility, in order to take measurements of the Doral Facility, interview Dr. Rossi with respect to the heat exchanger utilized during the operation of the E-Cat plant, view the sources for ventilation of heat from the Doral Facility, and determine whether the heat exchanger described by Dr. Rossi would have
been sufficient to disburse 1MW of heat from the Dora! Facility. In addition to these sources of facts and information, Prof. Dr. Wong has reviewed the following in developing his conclusions and opinions:

What is the “heat exchanger described by Dr. Rossi”? There is no sign that Murray or Smith were aware of such a claim, so, of course, their opinions did not consider it.

1. The Penon Report;
2. The Expert Disclosure of Joseph A. Murray;
3. The Expert Report of Rick A. Smith, P.E.;
4. Wong, KV, Thermodynamics for Engineers, 2nd Ed. CRC Press, 2000, 370 pp, TJ265.W56, 2012;
5. Wong, KV, Thermodynamics for Engineers 11, 91 h Ed., U.M., 2014.
6. Kakac, Liu and Pramuanjaroenkij, Heat Exchangers, 2nd Ed. CRC Press, Boca Raton, FL, USA, 2002.
7. Photographs of the Doral Facility, appended hereto as Composite Exhibit A.


Based on the information I have been provided, the conditions that I have observed and my measurements taken at the Doral Facility, my opinions are:

• The Coefficient of Performance is a criterion that is suitable to determine the way the E-Cat plant functions.

What is “the way the E-Cat plant functions”?

• There are clear and logical explanations for an inverse relationship between the amount of power input into a device and the COP of that device. In fact, not only are such explanations logical, they should be expected from the way the E-Cat plant was operated.

Again, what is “the way the E-Cat plant was operated”? If COP varies inversely with power input, how is output controlled? In the past, Rossi generally showed increased COP with increased power input. I.e., a direct relationship, not an inverse one. Consider the Lugano Test, for example. Yes, if power output remains constant and does not vary with input, it is indeed “logical” that COP would increase as power input is reduced, but this would then indicate an independence of power output and input. Murray was raising a possible objection, not a proof.

The Rossi control system depends on maintaining the reactor below self-sustain temperature; there appears to be no variation in flow rate, from the Penon report, so control through cooling is not used. Thus “the way the E-Cat plant  was operated” argues against the position that Wong takes. He is clueless. Murray might be incorrect, that’s a possibility (perhaps Rossi controls the system with unspecified stimulation of some kind), but his comment certainly is not illogical.

• Under the conditions described at the Dora! Facility, it was more than possible to expel 1 MW of heat energy without rendering the Dora! Facility “unsuited for a human working environment.”

This is not under the conditions considered by Murray or Smith. It is possible to expel that much heat, but it would create difficulties that are not addressed by Wong, and would have been visible.

“Described” here must mean “described by Rossi.” 

• Under the conditions observed and described at the Dora! Facility, it was more than possible to expel I MW heat energy from the Dora! Facility consistent with the amount of energy reported in Dr. Penon’s report.

Wong did not observe conditions allowing this. What he observed, as may be shown through cross-examination, were conditions that make the existence of the heat exchanger as described by Rossi implausible. As to “more than possible,” this could only mean “as actually existed,” but Wong could not possibly know that, and nothing he witnessed confirmed that the heat exchanger actually existed, and his opinion that it, if it existed, it could handle that much heat does not appear to be soundly based. If one wanted to add a high-capacity heat exchanger, it would not have been made to exhaust at the front window, but through the roof, i.e., standard practice. Having a lot of heat blow up is not uncommon. Having it blow horizontally, out the front window, would create highly visible effects, such as damaging the trees in front of the window. It would have created high noise levels, not reported. Higher noise on the roof would be less likely to attract much attention, etc.  A roof-mounted cooling tower (as was considered by Murray and Smith) would have been less expensive to construct and would not have required the extra pump that Wong, in his deposition, acknowledges would be necessary. But, of course, this would have raised the pressure in the outlet pipe — and the Rossi FantastiHeat Miracle Box would have done this, as well. 



• This expert has been informed that a heat exchanger was located in the second floor room at the Dora! Facility. The specifications of the heat exchanger have been described to me as follows:

• Composition: (22) steel pipes

• Length: 10 meters each (excluding u-shaped connector);

• Interior Diameter: .15 meter

• Total surface Area: approx. 103 sq. m. (1,030,000 sq. cm.) (does not include pipe overlapping or u-joints)

• Encasement: wood panel insulated with rock wool shaped for thermal and acoustic insulation

• Dimensions: Aprox. 10 m (length) X 6.5 m (width) X 1 m (height)

• Air Flow: 2 Fans (25,000 cubic m/hr. each)

The cross-sectional area of each pipe is (0.15 inner dia + 0.003 walls)/2 meters, squared x π = 0.0184 square meters, and there are 22 of them, total cross-sectional area is then 0.4 square meters.

Site Observations:

• Two large air vents in ceiling in the main warehouse area at Doral Facility

• Large loading bay doors at one end of the Doral Facility

• Two large ventilation fans in main warehouse area

• 2nd Floor heat exchanger area with three bays of windows accessible for ventilation.



The equation to determine COP for a heat pump is:
COP = (Energy Output) / (Energy Input)

Is the Plant a “heat pump”? However, COP is specified in the Agreement. 

In his Expert Disclosure, Mr. Murray takes issue with the fact that on several occasions during the period recorded by Dr. Penon, there existed an inverse relationship between the COP and the amount of energy input. In fact, Mr. Murray goes to the extent to claim that “there is no logical reason why the COP should be changing inversely to the amount of
power imputed.” This statement is fallacious.

Wong’s equation is incorrectly stated. The Heat Pump COP equation would be Useful Heating Provided / Work Required. By the law of conservation of energy, energy out is always equal to energy in, if “energy” in includes the potential energy of some fuel or other source (and a few other assumptions). I point this out because it shows he is not being careful. The issue of the use of COP for measuring the performance of a Plant as is under consideration is complex. It was not a skillful measure to use, because one could easily have COP very high with a small amount of consumed fuel, provided the output power was not more than the fuel could supply. The plant was called a 1 MW Plant, but the “COP measure” would have been satisfied with a 1 W Plant, or any measurable power.

The core disagreement here, though, is about something else. Murray was pointing to something which Wong totally fails to consider. 

In the COP equation above, the energy input (i.e. the electrical energy measured by Dr. Penon) is the input power supplied by FPL.

Is it? Was that measured by Penon? Is all FPL supplied power included, or just what was fed to the Plant? The Plant did not have a separate power input from FPL. What does the Penon report say about this?

If the energy output (numerator) of the plant is approximately constant, the equation dictates that the COP of the E-Cat will increase when the plant draws less electrical power (denominator decreases). Accordingly, the data collected by Dr. Penon is consistent with this basic equation.

If the energy output is constant, yes. But then why is COP a measure of performance? The issue is the energy output, i.e., energy release by whatever is taking place in the Plant, and if this were independent of input power, as Wong assumes to come to his conclusion, input power is essentially irrelevant, and one could design a plant like this to run self-sustaining, with no or truly minimal input power, i.e., enough to run the instrumentation.

(It is fairly obvious that the use of COP as a measure for the Validation Test and Guaranteed Performance Test came from Rossi. COP has been his long-time obsession. Then, do we figure COP on power or on energy? (The Wong formula uses energy.) COP based on power can be high if power varies, due to latency in the system. What is of real interest is total energy generation, and then if that is expressed as a ratio to input power, there is a ready assumption that a high ratio could not be the result of measurement error. What Murray was pointing to was a *possible indication* of some error or artifact. Wong ignores most of Murray’s opinions and just focuses on what he can assert is wrong, based on his own incomplete understanding, whereas Murray has been working on this issue for maybe a year. And others far longer.


The use of the Coefficient of Performance is justified for the E-Cat.

Apparently Wong missed the point of that comment by Murray. Under some conditions, COP could increase with lower input power; the conditions require that the heat be, to some degree, independent of the input power. The kind of behavior seen is not ordinary. The COP of a heat pump will not ordinarily increase as input power is decreased. It appears that Rossi convinced Wong of his “Self-Sustain mode,” but a careful engineering consideration of this would be much more complex than Wong makes it to be, he only looks at the equation and simply assumes constant output power, which would be stupid-silly with a heat pump.

Whether or not the Murray statement is unreasonable depends on details, this was only an outline of testimony. Murray did not, in fact, claim that the “use of COP” was unjustified. He is pointing to anomalies in the data, and this was only one of them.


From Mr. Murray’s opinion:

“Mr. Murray will testify as to the heat simulations he ran to recreate
the thermal conditions inside the Dora! location. The thermal
simulation involved a 500 kw or 800 kw power source uniformly
distributed in a container at the Doral location, 7861 NW 46111 Street,
Dora!, FL 33166 and releasing heat into the ambient warehouse of
the Doral location. Mr. Murray’s simulation demonstrates how the
heat would typically build over time to achieve a steady state
temperature. See ‘Thermal Simulations.’ This means that the room
would have been heated to a temperature unsuited for a human
working environment.”


1. Starting from the reactor/generator of the E-Cat plant, heat could have dissipated from the energy source (however well insulated);

Would have, not could have. (Wong here is encouraging a confusion, that “dissipation” gets rid of the heat. No, it moves it from one place to another. If the place it moves it to is inside the warehouse, the warehouse will get hotter. 

2. Next, heat could have been dissipated through the pipes which led from the E-Cat plant to the heat exchanger (room);

The same. This will all heat the space. This is heat transfer, not overall dissipation into a space outside the warehouse. This could very easily confuse a jury. Rossi originally wrote on his blog, as I recall, about power being “consumed” by an endothermic reaction. Besides being preposterous, an endothermic reaction that could do that being unknown, except for phase change (e.g., melting ice, which would take enormous quantities of ice), while the “feedstock” was a few grams of platinum sponge, it was quantitatively irrelevant. This was an enormous problem with a megawatt plant. Unless there was high production (very high! with no known reaction that could handle that), there was far too much power to handle. So, yes, a heat exchanger was necessary, and would have been required from the very beginning of Plant operation, before the alleged Test began. And would have been visible, both from the necessary piping inside the warehouse, but with the windows in front with glass removed. The noise and the air movement would have been blatantly obvious. No reports.

3. Workmen who were working in the room could be called to testify that the room in which they were working felt significantly warmer when the E-Cat plant was working and generating energy;

This has nothing to do with his expert opinion. Many people visited the plant when it was allegeldy in operation and did not notice “significantly warmer.”

4. Heat dissipated by these transmission pipes could be lost easily to the large space, aided by the ventilation fans.

The large space is the space Murray is considering as being heated. Apparently the “ventilation fans” Wong is talking about were inoperative, but this is a minor detail. This would not adequately cool the space. Wong’s testimony would indeed confuse a jury.

5. Finally, heat was dissipated in the heat exchanger specially designed by Dr. Rossi. The heat that could be dissipated by this heat exchanger is at least lMW. Mr. Murray did not see or mention the heat exchanger which was designed and built to dissipate the energy generated by the E-Cat plant. Neither did Mr. Smith consider the heat exchanger in rendering his opinion. As described above, a substantial heat exchanger was constructed within the Doral Facility which would have greatly affected the
dissipation of heat within the Doral Facility.

Wong is stating as fact what is only unattested testimony from Rossi. If I’m correct, Rossi was not asked extensively about his “heat exchanger,” because its alleged existence was only revealed with Rossi’s deposition, February 10, and the Wong report (February 16, 2017) a few days later. Murray does look for some way to dissipate the heat. He does not consider, in his January  30 “disclosure,” the quite implausible construction of a heat exchanger in the mezzanine, rather than a far simpler removal of heat through openings in the roof.

(With no more words, or very few, Wong could have been accurate.)

Wong is not contradicting the Murray claim, about his simulation, and, in fact, in his deposition, he agreed that without the alleged heat exchanger, the facility would have been uninhabitable. 

Murray visited the Doral plant as it was being shut down (Feb 16-17, 2016) and apparently saw no evidence of a heat exchanger. There was another visit by Murray, June 2, 2016. There is no report of a heat exchanger in any of the depositions of those who were present, other than Rossi. Wong is correct that Murray did not consider the heat exchanger. Why would he? His report was issued January 30, before any hint of the exchanger that I’ve found. When Rossi claimed it in his deposition, February 10, 2017, Pace was obviously surprised.

Although this expert did not observe the heat exchanger during his site visit (it had been removed after the conclusion of the E-Cat test), Dr. Rossi described in detail the form, function and specifications of the heat exchanger located on the second floor of the Doral Facility. According to Dr. Rossi, the heat exchanger was comprised of a series of steel
pipes supported by a wood frame which were contained within an insulated wood structure. Within the wooden structure, two fans (each 25,000 cubic meters/hour) circulated the air over the steel pipes with the air exiting through a 3.8 square meters opening on the front of the building (consistent with the windows observed by this expert).
Based upon Dr. Rossi’s description of the heat exchanger placed at a second floor level, with 2 fans of combined capacity of 50,000 cubic meters/hour, this expert is satisfied that the heat exchanger answers the question as to where the heat energy was dissipated.

Mr. Murray’s statement that “the room would have been heated to a temperature unsuited for a human working environment” is fallacious.

That’s appalling. Wong may have qualifications, but is not at all careful in this report. Without a heat exchanger, the room would indeed have been so heated. Wong will proceed, then, to calculate how much heat could have been dissipated by the described heat exchanger. He says that he is “satisfied that the heat exchanger answers the question,” — not could answer — but he is ignoring all but the simplest calculation, which may itself be defective. Has he considered how visible such an arrangement would have been, fans blowing heated air out a front window at high velocity, day and night? Has he considered how apparent that intense air flow would have been to anyone opening a door to the facility?

50,000 cubic meters per hour through 3.8 square meters gives a velocity of 13 km/hr. How hot is this air? For his calculations to work, it has to be close to 100 C. Wong does not describe air inlet; if the flow through that window is out of the warehouse, where is the inlet? If the inlet is the front or back doors, when happens if the doors close? Does everyone die from the reduced air flow? Wong has given this only the shallowest consideration: but what does one expect for merely $350 per hour?

To roughly calculate the amount of heat energy which can be dissipated through the described heat exchanger (conductivity), we apply the Fourier Equation which is:

Q = k x A x [(Tc – Tf) / (L)] Equation 1

In this equation:

Q =heat transfer from steam/water to steel pipes. The steel pipes participate fully in the heat transfer.
k =Specific Thermal Conductivity of the C 15 steel (36 W/m° C)
A = Surface Area in meters squared (100m2)
L =Thickness of the pipe wall in meters (1.5mm).
Tc =Temperature of heat from source in Celsius (101° C)
Tr= Temperature of water outflow in Celsius (99-100° C)
mw =Flow rate of water (1500 kg/hr)

The latent heat of steam at standard temperature and pressure (“STP”) is 2257 kJ/kg. See Engineer’s Toolbox. The amount of heat two [sic] be rejected by the steam and water is 0.94 MW.

This equation purports to show that with dry steam at 101° C and full condensation, as I read this, such that the pipes are at 100° C, the heat transfer will be adequate to move a megawatt from water to pipe exterior. But I don’t see the actual calculation. It seems he is calculating the power from the flow rate, assuming full evaporation, and then full condensation. That, of course, roughly matches the assumption for generated power at the other end, full evaporation is assumed. (And Penon neglected the temperature of the returned water).


The air flow inside the heat exchanger was 50,000 m3/hr with the heat exchanger’s volume of 60 cubic meters, the air insider [sic] the heat exchanger was changed 833 time [sic] per hour.

Wong’s figure of 60 cubic meters for the contained volume of the heat exchanger box seems about right as a rough approximation.

Newton’s law of cooling is used for calculating the heat extraction from the heat exchanger by the forced convection induced by the two fans.

As per Newton’s Law of Cooling:

Q = hAΔT Equation 2

In this equation:

Q = heat transfer from steel pipes to air.

h = overall heat transmission coefficient between moderate air cross flow and carbon 1.5 steel. See [OPPO Conductibita Termica]. The value is 200 W/m2C.

A = area of heat transfer (100 m2)
ΔT = Tr- Tc.
Tc = outer surface temperature of steel pipes (100° C).
Tr= ambient air temperature (30° C).
Heat Convection Area is 100 m3
Therefore: Q = 1.4 MW.

Newton’s Law of Cooling. Wong is calculating the rate of heat transfer from the pipes to the air. However, he does not look at the time that the air is exposed to the pipes, but is assuming full transfer.

I notice he does not use the change rate figure, he simply states air flow as “moderate cross-flow.” Using the box  cross-section of 6 square meters, ignoring pipe volume, and a flow rate of 50,000 cubic meters per hour, I get a flow velocity of 8,333 meters per hour. The air transit time through the box, 10 meters long, would be 4.3 seconds.

(I am assuming air enters at one end of the box, and then exits at the other end, which is arranged to conduct the air out of the room through the window.)

(There is no consideration by Wong of back-pressure. For example, the 6 square meters of the box must be reduced to 3.8 meters square for the window. This must create back-pressure reducing flow. The fans would be rated for free air. Back pressure reduces flow. (Just as flow would be reduced if there were air inlet restriction.)

Wong does not calculate the actual temperature rise. If we have 60 cubic meters of air at 0 barg, assumed 1 bar, and a heating rate of 1.4 MW, his conclusion, we allegedly transfer 6 MJ to that air in four seconds. Using rough figures of air density at 1.0 kg/m3 and specific heat of 1.0 kJ/kg-K, I find a temperature rise of 100 degrees K, i.e., to 130 C. This is impossible by the laws of thermodynamics, from a 100 C source.

The most obvious problem to me is that as the air moves through the exchanger, it will rise in temperature, so the transfer rate by Newton’s Law of Cooling will decline proportionally. The air could not possibly get hotter than the pipe temperature, so it is limited at 100 C, and that exit air temperature, if reached (it couldn’t reach it, because the transfer rate would decline with the difference in temperature) would then lead to other problems. Like dying trees outside, birds dropping out of the air, etc, a heat plume readily visible from the sidewalk and street, etc.

This should have been common sense: air flow radiators are not built like this, they are built to have far higher surface area, to improve heat transfer to air over what one would get with simple pipes. 

Applying the two equations described above to the conditions and specifications existing at the Doral Facility, this expert was able to determine that the described heat exchanger would have been more than sufficient to expel in excess of  lMW of heat energy from the
Doral Facility.

As shown above, his determination was a shallow calculation that failed to consider major issues, such as the variation of temperature within the box. He was apparently paid to answer the question, “Is it possible?”, and he then looked as far as to see possibility, but not for any contrary problems. Yes. If pigs can fly, the heat exchanger could work.

Much better calculation could be done.


This expert has concluded that, assuming the existence of the heat exchanger with the specifications above, the heat exchanger and the fans are capable of removing at least 1 MW of heat energy from the Doral Facility. Additionally, the energy generated by the ECat plant was dissipated around theE-Cat plant itself, the transmission pipelines to the heat exchanger, and in the heat exchanger itself which was cooled by two motorized fans. “That the room would have been heated to a temperature unsuited for a human working environment” concluded by Mr. Murray, is simply fallacious .

Murray’s statement was conditioned on the assumption, rooted in his experience seeing the plant when the heat exchanger would still have been intact, presumably, that there was no heat exchanger, so his statement was not “fallacious,” it was, like all statements, conditional. The dissipation pre-heat exchanger would heat the space; Wong did not attempt to characterized that heat loss, but writes as if this would improve conditions, when the reality would be the opposite. The heat exchanger could only expel, through the mezannine windows, heat that reaches it, and the design is not how an HVAC engineer would handle this kind of heat. They would conduct it ASAP to a roof heat exchanger, blowing it up, not horizontally, and the Smith report covered that, as I recall. Such heat exchangers are commercially routine, and are large and noisy.

The Wong report is dated 2/13/2017. Wong had visited the Doral location February 10, 2017. (Is this correct? This is the same day as the Rossi deposition.)

It refers to the Murray disclosure dated January 30, 2017.

When did Rossi first claim there was a heat exchanger?

From the Murray deposition, it appears to have been disclosed by the Wong report. If it was prior to that, Murray and Smith seem to have not been informed. This was very late for Rossi to introduce what would be critical to understanding the operation of the Doral Plant. Murray had visited Doral, twice, once while the Plant was intact, without any dismantling having taken place (though critical components were being removed by Penon). It looks like IH did not suspect a “mezzanine heat exchanger,” in the least, and they were actively looking for how heat could be dissipated. They’d have seen the alleged piping to it, this would easily have been visible from the reactor area. Apparently Bass claims to have seen it, but I haven’t reviewed that yet.

In the Bass deposition, page 39,  he is asked how the steam is condensed, and answers — correctly — that it is by removing heat. However, when asked how the heat was removed, it was “by an endothermic reaction,” which was Rossi’s original public explanation (or, perhaps more accurately, Rossi accepted the suggestion on his blog). But we now know, and Bass does not contradict, that only a few grams of platinum sponge were involved. This amount would have been a trifle compared to the large portion of a megawatt of endothermy needed. Bass is simply repeating what he was told, never having carefully considered how preposterous it was. (This has been called the “Rossi force field.” Experts who should have known better have been distracted from the obvious.)

The Bass deposition was taken February 2, 2017. The alleged “heat exchanger” was not known then, apparently, so Bass was apparently not asked about it (but we have not seen most of the full depositions). Murray was asked about a “heat exchanger,” by Annesser, I think.

Rossi’s Affidavit in Opposition to the IH MSJ does not mention the heat exchanger. I see no admissible evidence in the record that it existed, other than Rossi’s own testimony in his personal deposition and for JMP. Have I overlooked something?

There was a request from Johnson for IH to allow the Plant to start up again. But if there was no heat exchanger, if it had been quickly disassembled, that would have been impossible. Rossi has not been carefully questioned about the heat exchanger, because depositions cover scheduled topics, and the heat exchanger was not a known topic until Rossi revealed it in the deposition, see below.

Why would Rossi dismantle a heat exchanger clearly necessary for Plant operation? My answer is obvious: there was no heat exchanger, and it was never necessary because the plant was not producing more heat than the input energy. However, then, iIf there was a heat exchanger, it was found unnecessary, so Rossi could, indeed, repurpose the materials and still start up the plant again if it were agreed. It might have functioned to make the plant a little more comfortable.

The whole thing so obviously stinks that if I decide to go to Florida I should bring a clothes pin for my nose. Okay, the judge will not allow that in the courtroom, at least Judge Judy wouldn’t!

Honestly, I’m considering health consequences. I have stable angina. Stress could, in fact, trigger a heart attack, and watching a lying bully, on TV, I discovered once, can trigger intense cardiac response, I was in the hospital, on continuous cardiac monitoring (my only time in a hospital since I was a small child!), and was watching the last Trump-Clinton debate, and the nurse came running in. What’s happening? My heart rate had gone to 190, and it’s somewhat of a miracle that I didn’t just keel over. Except, of course, I was already laying down…. I didn’t realize there was any problem at all…. I was not actually experiencing angina, just stress.

This seems to be the earliest reference:

February 10, 2017, Rossi, in his deposition, starting on page 234, claimed the heat exchanger existed. Pace seems to be surprised — I’d even say “blindsided,” and asks when this was removed, since he had been to the Plant, personally, February 16-17, 2016. (And there was a later visit as well, June 2.) The heat dissipation problem had been raised in the IH counterclaim, as mentioned above. It appears that Rossi had not disclosed or alleged the heat exchanger before this.

The heat exchanger would have been necessary from the beginning and from before the beginning of the “test period.” There were many people who would, presumably, have seen signs of it. The mezzanine entry is visible from the “Leonardo side,” it’s been called. Those who assumed there was no heat exchanger were not simply guessing; they were aware that it would take substantial equipment to handle a megawatt, and that there was no sign of its existence.

My conclusions:

IH raised the problem of heat dissipation, August 11, 2016, in their AACT, paragraph 82. My emphasis

82. Indeed, when Murray eventually gained access to the Plant in February 2016 and examined the Plant, the methodology being used to operate the Plant, and the methodology being used to measure those operations, he immediately recognized that those methodologies were fatally flawed. Some of the flaws that he was quickly able to identify are explained in Exhibit 5. Murray also recognized that the building in which the Plant was located had no method to ventilate the heat that would be produced by the Plant were it producing the amount of steam claimed by Rossi, Leonardo, and Penon such that persons would not have been able to work in the building if the Rossi/Leonardo/Penon claims were true. This conflicted with the claims of individuals who had been in the building when the Plant was operating, all of whom claimed the temperature in the building was near or not much greater than the outside temperature. Photographs of the building ceiling from the inside are attached hereto as Exhibit 26.

Rossi responded to this in his first Answer, with:

82. Plaintiffs deny the allegations contained in Paragraph 82 of the Counterclaim and demand strict proof thereof.

The Second Answer (filed after the AACT was amended) had the same.

There is no clue in the record of a claim of a heat exchanger on the mezzanine until much later. Rossi, discussing the heat dissipation problem, first referred to “endothermic reaction.” Bass says the same, basically, showing no knowledge of the alleged heat exchanger.

It appears that Rossi realized he was sunk with no heat sink. A heat exchanger was necessary, so he invented one, and then, of course, since it wasn’t there on the IH site visit after plant shutdown, invented that he’d dismantled it. Then he hired workers to remove and replace the windows, when Wong was there, to create the idea that previously the windows had been removed. So the windows were gone, with the heat exchanger removed, for more than a year? Rain blowing in, etc.? Water dripping through the ceiling in the office area? Really?

He designed the exchanger and gave the figures to Wong. Garbage in, cabbage out. He was hired for a purpose, to counter Murray and Smith, and Wong was not about to assume that Rossi was lying to him. Gift horse in mouth. However, as with lawyers, an expert witness must do due diligence on what the client tells them. It’s not necessarily perjury, but it’s incompetence to not do basic sanity checks.

If Wong goes before that jury, Rossi is sunk. He may be sunk anyway, it is merely more expensive to present Wong and watch him being shredded with obvious obvious, and this isn’t rocket science. Simple math.

My guess is that the Wong report was done hurriedly, since deadlines were approaching. Wong did not have time to proofread the report, hence the errors.

Corrections are, as usual, invited. Please. I make mistakes, and hopefully learn from them, whether I find them or someone else does.

Some more.

THH looked at the Wong calculations on LENR Forum. He attempts to do a more accurate calculation. He comes up with Wong being an order of magnitude off.

Rossi was asked about the ventilation and heat dissipation.

August 14, 2016 at 6:37 PM
Dr Andrea Rossi,
I imagine that the JMP plant used the thermal energy for endothermic physical and/or chemical interactions, while the excess heat, if necessary, was removed by means of air and water, am I correct?
Thank you if you can answer,

Andrea Rossi
August 14, 2016 at 7:26 PM

Warm Regards,

At this point Rossi was still maintaining the story of JMP production. That story has contracted to a few grams of platinum sponge and a small amount of graphene, all obviously irrelevant to heat dissipation. “By means of air and water.” How informative! IH first alleged the problem of heat dissipation in their AACT, 9/19/2016, as far as I know, but I think it was being discussed on the blogs before that.

April 15, 2017 at 11:05 AM

Murray, Smith and IH are not going to like this. Smoking gun stuff:

Interesting photo from Dr. Wong:


Inquisitive minds would ask why is the floor on the left clean and not walked on?

Maybe because there was a steam pipe there, that connected the bypass in the JM container to the upper story heat exchanger?

Also note a telltale lighter mark from the centre of that clean patch toward the outer edge of the landing.

Sure looks like, to this Black Swan, that a steam pipe could have been there for the duration of the 350 day test.

Best regards,

Andrea Rossi
April 15, 2017 at 12:58 PM

No comment.
Warm Regards,

Smoking gun? More like a limp noodle.

The heat dissipation was considered on E-Cat world, August 14, 2016, with the Rossi blog being quoted.

It had previously been considered August 12, 2016, and there is an Update there with the Rossi post I was looking for. I’ve added a link to the JONP post.

UPDATE#2: I asked Rossi today on the Journal of Nuclear Physics about the photos and allegations from Industrial Heat that if 1MW was produced by the E-Cat plant, it would have been too hot inside the factory for anyone to have worked. Rossi responded:

Andrea Rossi
August 12, 2016 at 1:53 PM
Frank Acland:
1 The heat was used, not vented away from the Customer
2 There was a ventilation system, to exhaust when necessary the heat excess, that has not been taken in the photo.
Nevertheless I must confess that these amendments have remarkably improved the former countercomplaints, completing their cultural reach: before they were comic, now they are tragicomic.
Obviously we will respond in Court with due evidence.
Warm Regards

When Rossi says “the heat was used”, it suggests that he means there was an endothermic manufacturing process, which some people have been discussing. From his response it sounds like that there were times when excess heat had to be vented out (apparently when the heat was not being used by the customer), but I don’t know what kind of ventilation system he is referring to here.

The first answer was the “endothermic” concept. The heat was “used.” However, there was no significant quantity of product; in addition, if one were running an endothermic reaction, it would store energy in the product. Storing a megawatt in a small volume of chemistry would create a very dangerous product. This was pointed out in the first ECW discussion.

Of course Frank Acland didn’t know what “kind of ventilation system” Rossi was referring to. And it seems he didn’t ask that question…. Rossi seems to have been referring to venting heat out the roof or maybe down the drain, those were all ideas considered at the time. The heat exchanger would not be described as a “ventilation system,” — that would refer to what would cool the warehouse — but as a heat exchanger with, then, forced-air ventilation. There was no possible legitimate secret involved in the heat exchanger. Why not just say “there was a heat exchanger?” The question had been raised, he’d eventually have to address it.

But he didn’t, not until discovery was almost complete. There are two basic possibilities. The most likely, my opinion, is that there was no heat exchanger. He made it up, as he’d made up the “customer,” perhaps believing that he could get away with it, with his “masterpiece” of a story, that he had “repurposed it” after the test was over. Planet Rossi gets more and more outre. He has a plant set up. It needs a heat exchanger to be used. Johnson even asked if the Plant could be restarted. IH apparently was willing to consent…. but it couldn’t have been restarted, the piping had been removed and the heat exchanger… no, this is simply a tangled web he’s weaving.

The other possibility — minor — is that there was a heat exchanger, never mind how well it worked. So why not disclose it? Well, if he waits till the end, it will confuse the IH defense and their counterclaim. Rossi prefers to be vague and then allow reinterpretation of what he says later. This habit has become increasingly obvious; all the JM communications. He’s lying or is massively confused, because he clearly misled IH — and Bass, and maybe Johnson, Fabiani, etc.

Author: Abd ulRahman Lomax

See http://coldfusioncommunity.net/biography-abd-ul-rahman-lomax/

4 thoughts on “Wong assumptions, cabbage conclusions.”

  1. Abd – under 2.1 SITE CONDITIONS you state:
    “These dimensions are in conflict. The cross-sectional area of each pipe is (0.15 inner dia + 0.003 walls) meters x π = 0.48 square meters, and there are 22 of them, total cross-sectional area is then 10.6 square meters. Yet the box cross-section is only 6.5 square meters. The pipes would not fit in that box.”

    You need to revisit your maths here and adjust the conclusions in a few places. This is around 6″ OD pipe (153mm) and you can get 36 of them in a square yard and around 40 per m². As it is, we’ve got an area of 6.5x1m, which if we put 22 tubes in they’ll each have around 0.5m by 0.5m to flap around in. Area is pi.r²… so area per pipe is around 0.0183m² or 1/54.4 of a m².

    The circumference is however in the ballpark of 0.48m, and since there are 22 of them and 10m long there is around 107m² total hot area. The steel will however not be 100°C on the outside of the tube, because there is a heat flow through the steel.

    The total volume for the 22 pipes is around 4.045m³ (ignoring joints), and the volume of the case is somewhere around 65m³, leaving around 61m³ of free space inside the box.

    Though it’s certain that the air being exhausted won’t be 100°C and also it won’t be free air so won’t be 50000m³ per hour (the box and pipes will introduce wind resistance), and thus that Wong’s estimate is quite a way off even if the fabled heat-exchanger actually existed, there’s still that problem that nobody noticed such a massive hair-dryer running 24/7. I see you’ve noted that the palm trees in front of it would go brown (though I’ve yet to see you pick up the point about the toupées being blown off). Assuming around 3m² for the window, that’s around 17km/h wind at somewhere around 70°C, though I’ll need to do that calculation exactly when I find the window size and see what the actual flow-rate would change to. Frankly, I don’t feel like doing the hunting at the moment, since the heat-exchanger never existed in the first place, so ball-park figures are more than adequate to show the absurdity of the proposition. Maybe someone more OCD than me will do the calculations exactly, but given that there’s a lot of data simply not there (for example, to stop the doors being sucked open or shut you’d need to divide that window area into entry and exit for the air, so it moves twice as fast and takes off the moustaches as well as the toupées).

    1. Oh, how embarrassing. It took me about half a second to see my brain fault, I didn’t even have to read much. Pi * D is the formula for circumference, not area. My excuse is I’ve been sick today…. The units didn’t work for what I did, etc. I’m going to unpublish this post until I can rewrite it. It will come back, with your comment, I don’t hide my mistakes, but there is no sense allowing this one to continue to wave in the wind. Thanks. At least I know now that I’m being read.

      1. Abd – the being sick doesn’t help, but mainly it’s that you’re working on your own. We’ve all experienced this sort of error now and again, but most of us get the chance to pass it by a colleague before the public get to read it so the errors get caught first. Wong didn’t get that chance to have someone check his figures, either, or maybe he thought he didn’t need to.

        I can’t remember when I really started bugging Peter Gluck about the problem of where the heat went, but it was somewhere getting on for a year ago. I thought he’d realise it was a major problem, being an industrial chemist and thus needing to deal with such heat transfer problems in his professional life. Still, I thought it was likely that Rossi would read Peter’s blog (it’s nice to read supportive comments), and so I had the idea that it might result in an explanation from Rossi of where the heat went at some point. Since there was no way that the explanation could be valid, as all the other ways of dissipating 1MW would have had visible consequences that would have been very obvious (and would have produced hard evidence), I was interested in seeing what Rossi would come up with. Of course I wasn’t the only one hammering that point, so I’m not going to claim that my comments had any effect except as adding a bit to the volume, but the end result was the sudden appearance of the heat-exchanger.

        The obvious errors in the design do highlight Rossi’s competence (or lack of it). What’s really surprising is the number of people who think that it would have done the job, including Wong. Given Tom’s calculations on LF that anyone could check and challenge if needed, which are even then erring on the generous side, it shows just how strong Rossi’s Alternative Reality Field must be. They must really want him to be right so all the children get cured of cancer and the world’s energy problems go away just as soon as those robots start making the devices. Even the strongest belief won’t change the physics, though.

        1. Actually, I’m not working alone. I have you to help me.

          One might think that an expert report would get careful proofreading and checking. One might think.

          I’m not convinced, so far, either way about whether the heat exchanger as described would have worked, though it seems unlikely to me. What’s remarkable to me is that Rossi presented the Murray deposition as an argument against his being allowed to testify as an expert. Murray is an engineer, and shows it in many, many ways. He might be right or wrong, but his approach is that of an engineer, and what he reveals about the test setup is devastating to the idea that there was any decent engineering involved in setting up the “test” and then the handling of the heat. Rossi has made a big deal out of Penon being a “nuclear engineer,” as if that would create expertise in handling something like a test of a LENR device, being used purely to generate steam at low pressure and temperature. I’ve not completed reading the deposition.

          Many wrote about what I came to call the “room calorimeter.” Yes, I think Rossi was feeling the heat.

          This is a blog, not a formal publication. Errors can be fixed. Normally, I will fix errors of mine, where there has been any comment, with strikeout (the norm on Wikipedia discussions) and amendment. Here, because it was so soon after publication, I unpublished it and fixed it, leaving the comments in place. Just in case someone linked to it somewhere on the planet. Transparency is critical here, not perfection in initial publication. This is quite different from, say, ECW or LENR Forum, where it is routine for blatant errors to remain forever, even if users can edit them to fix the errors, and even if admins could do that. Those are not sites that build content, it’s obvious. The administration doesn’t really care about content, it’s like the owner of a bar, who only cares about patronage, participation, and not about what agreements or disagreements patrons settle or don’t settle on. Not about fact as distinct from opinion.

          Core content here is the blog posts (largely for transient reporting and fun) and accumulated pages (for more useful content, long-term). Please, if anyone sees — or thinks they see — errors on either of these, point them out. Either they will be fixed ASAP or the discussion will be useful. I am now no longer the only blogger, THH accepted author privileges and has started to use them. If there are errors on his pages (as distinct from perhaps unaccepted opinions), I will work with him to fix them. If I am correct, he can edit his own pages, but, if they have been published, cannot delete them. But he could edit a page to say “deleted by author” and ask me to delete. If there is any doubt, I might unpublish the page, asking him not to delete it until there is agreement. What I assume for someone with author or other advanced privileges is a willingness to negotiate instead of taking prejudicial action, and deletion can remove content beyond recovery.

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