UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION BUD LEE and CINDY LUNDMAN, as next friend and as natural parents of PATRICK LEE, deceased, Plaintiffs, v. Case No. 3106-01-08 METROPOLITAN GOVERNMENT OF COUNTY, TENNESSEE, et al., Defendants. DECLARATION OF PATRICK SMITH 1, Patrick Smith, state the following: 1. My name is Patrick Smith. 2. I am a competent adult and have personal knowledge of the following facts. 3. Attached hereto is a true and accurate copy of my expert report in the Lee, et a1 . V. Metropolitan Government ofNashViIIe/Davidson County, Tennessee, et litigation. My opinions are expressed to a reasonable degree of scientific certainty. 4. I affirm under penalties of perjury that the foregoing statements are true. Date: I I With INDSOZ MCR 1007908v1 EXHIBIT 13 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 1 of 44 UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION BUD LEE and CINDY LUNDMAN, as next friend and as natural parents of PATRICK LEE, deceased, Plaintiffs, vs. Case No. 306-0108 METROPOLITAN GOVERNMENT OF COUNTY, TENNESSEE, CHIEF OF POLICE, RONAL SERPAS, Individually and in his of?cial capacity, POLICE OFFICER JONATHAN MAYS, POLICE OFFICER JAMIE SCRUGGS, POLICE OFFICER CHRISTOPHER BROOKS, POLICE OFFICERS JOHN JANE DOE 1'10, individually and in their of?cial capacities, and TASER INTERNATIONAL, IN C., Defendants. EXPERT REPORT OF PATRICK SMITH CO-FOUNDER AND CHIEF EXECUTIVE OFFICER OF TASER INTERNATIONAL, INC. Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 2 of 44 PageID 3286 TABLE OF CONTENTS EXHIBITS ..1 INTRODUCTION ..1 OPINIONS ..2 Early Medical Considerations of Electricity ..3 WHAT IS ..5 Hoover Dam Water Analogy ..6 Water Hose Analogy ..6 Joule (J) Water Analogy ..7 BASIC ELECTRICAL PRINCIPLES (HIGH SCHOOL PHYSICS 101) ..7 Power Supply Limitation ..8 50 kilovolt (W) from Small Batteries? ..8 WHY TASER DEVICES ARE HIGH VOLTAGE ..8 50,000 DO NOT ENTER THE BODY ..9 NOT THE VOLTS, THE DELIVERD CHARGE THAT MATTER THE MOST ..9 TASER CURRENT (AMPERES) DOES NOT LAST LONG ENOUGH TO AFFECT THE HEART ..12 Limited by the Battery Power Supply ..13 Power Limited by Wire Conductors ..13 Power Limited by Delivery ..13 In Summary ..15 Average Current vs. Root Mean Square (RMS): ..15 Average Current .. 15 For TASER ECDs RMS Calculations Do Not Provide an Accurate 15 Average Current Relevant to TASER Devices .. 16 2002: TASER Tried Using RMS Calculations (Learning from Experience) BASIC TASER DEVICE OPERATING PRINCIPLES ..17 Telephone Network Communication Analogy .. 19 Effects of Repeated Pulses on Muscle Tension ..20 HISTORY OF TASER DEVICE TECHNOLOGIES ..21 1967 NASA Scientist Jack Cover?s TASER TF-76 ..21 Tasertron Emerged ..21 19805: Studies and Risk Utility Comparisons ..21 Early 19903: The Need for Non-Firearm Self-Defense ..21 ICER Corporation Formed ..22 TASER 34000 - 2"d Generation TASER Device ..22 1994: TASER 34000 Limited to Non-Law Enforcement ..22 Nov. 1995: The Czech Experience: Original TASER Devices Did Not Get the Job Done! ..23 1996: ADVANCED TASER M26 Is Born ..23 Stratbucker Testing .. 23 TASER M26 Developed ..24 TASER M26 Emerges 3rd Generation TASER Device ..24 Medical and Scienti?c Research ..24 Late 1999: ADVANCED TASER M26 ..24 Rev: February 7. 2008 Page i Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 3 of 44 PagelD 3287 May 2003 TASER X26 Debuted - 4th Generation TASER Device ..25 BASIC TASER DEVICE OPERATIONS ..26 Transformers: An Electrical Lever ..26 THE TASER CIRCUIT: AN ILLUSTRATIVE LOOK ..27 Basics of Nerve and Muscle Stimulation ..28 The Neuromuscular Junction ..29 Tetanus ..29 How the TASER Device Does What It Does to the Body ..30 TASER Device Outputs and Comparisons ..31 TASER Risk Bene?ts ..35 DEGREE OF CERTAINTY ..35 Rev: February 7, 2008 Page ii Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 4 of 44 PageID 3288 TABLE OF FIGURES Figure 1 Electrotherapy 1785. From Adams (1785). ..3 Figure 2 Galvani (1790) From Beard Rockwell 1878. ..3 Figure 3 Let-go testing. From Dalziel. 1972. ..4 Figure 4 Electricity is the Flow of Electrons through a Conductor ..7 Figure 5 Mother and Daughter Experience up to 20 Million from a Van de Graft Generator .. 10 Figure 6 Common U.S. Wall Outlet and TASER ECD Comparison ..10 Figure 7 Current Comparison ..12 Figure 8 Maximum Power Battery of (8 AA) Alkaline Cells .. 14 Figure 9 M26 Battery: Alkaline vs. Batteries 10/16/06 ..15 Figure 10 Neurons. Fig. 3.1 of Reilly. 1998 ..17 Figure 11 Sensory Receptors. Fig. 3.16 of Reilly (1998). ..18 Figure 12 TASER Devices Stimulate the Nervous System with Pulses Similar to Those Used by Nerves to Communicate ..19 Figure 13 Fig. 3.22 from Reilly. 1998. ..20 Figure 14 Understanding Transformers ..26 Figure 15 An Illustrative Representation of the TASER M26 Circuit ..27 Figure 16 Air Force Research Lab Tests Show TASER M26 Muscle Contractions at 40% or less of Maximum Contraction Force ..31 Figure 17 Comparison of Current Output of AIR TASER 34000 and TASER M26 ..32 Figure 18 Comparison of Current Output of ADVANCED TASER M26 and TASER X26 ..34 Figure 19 TASER Risk Bene?ts ..35 TABLE OF TABLES Table 1 ElectricityNVater Analogy ..7 Rev: February 7. 2008 Page Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 5 of 44 PageID 3289 EXHIBITS The exhibits or list of references used as a summary of or support for the information and opinions in this report speci?cally include each illustration, graphic, chart, and video in this report, referenced in this report, or included in any of the references to this report, as well as any documents, or portions thereof, referenced or cited, or any compilation of documents, are to be considered exhibits to this report and may be utilized as exhibits at deposition and/or trial. These exhibits speci?cally include, but are not limited to: any document, information, illustration, Microsoft? PowerPoint?, lesson plan, drawing, graphic, video, compilation, etc., that is on, or included in, any of the TASER lntemational. Inc. (T ASER) training (versions 1 through the current release - which is presently version 14), TASER Fact Sheets (TFSs), as well as the TASER1 Research Compendium, the Sudden ln-Custody Death Research Compendium, TASER ECD Field Data and Risk Benefit PowerPoint presentations and Analyses, Volunteer Exposure Reports, spreadsheets, and analyses, Field Use Reports, data, summaries, and appendices, the TASER website (including updates and additions), the and 333w ipicdcom websites. etc. Exhibits also include an ADVANCED M26TM (M26), (X26), fully kitted M26, fully kitted X26, TASER cartridges, TASER cartridge wire, TASER probes, a Van de Graff generator, eight (8) AA cells, two (2) three-volt CR123 cells, stacks of 10,000, 25,000, and 100,000 sheets of copy-type paper, vehicle battery jumper cables, 110 alternating current (AC) electrical cords/cables, ground fault circuit interrupter (GFCI), and a twelve ounce can of Pepsi?? soft drink. INTRODUCTION The purpose of this report is to provide a basic partial overview of the fundamental operating principles and concepts of how TASER-brand Electronic Control Devices (ECDs, or devices) work. To many people, electricity sounds dangerous. Indeed, it can be. However, many people do not realize that life cannot exist without electricity. We are not talking about life being dif?cult without television, cell phones, and electric light bulbs. Literally, the life process cannot happen without electricity. Without electricity, Earth would be nothing but a barren rock in the cosmos. While much of what follows could come right out of high school physics 101 and biology 101, many of these concepts will be outside the existing knowledge and understanding of most people who do not study and/or keep abreast of these areas. Additionally, due to early life experiences many people are electricaphobic in that they have an unreasonable fear (or phobia) of electricity. 1 AIR TASER, M26, .and X26 are trademarks of TASER lntemational, Inc. and ADVANCED are registered trademarks of TASER International, lnc. Rev: February 7, 2008 Page 1 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 6 of 44 PagelD 3290 It is important to keep in mind that all electricity is not the same. Just as all ?balls? are not the same: a nerf ball, whiffie ball, beach ball, ping-pong ball, golf ball, racquet ball. tennis ball, dodge ball, softball, baseball, basketball, soccer ball, football, medicine ball, bowling ball, and wrecking ball are not the same, and the same is true for electrical discharge or delivered energy. A lightning bolt or a high-current power line would be equivalent to a wrecking ball. a bowling ball to a 110 AC outlet, and a handheld. battery-powered ECD would be approximately equivalent to a tennis ball. OPINIONS Bases of Opinions. The opinions stated herein are based upon my knowledge (including specialized knowledge), skill, experience, training, and education. The opinions are of a type reasonably relied upon by experts in this particular ?eld in forming opinions and inferences upon these subjects. Opinion Methodology. My opinions were developed using one or more qualitative and quantitative research methodologies, in addition to my specialized knowledge, skill, experience and education. These research methodologies may have included literature review, historical information searches, experiential studies and analyses, and case studies. Opinion Standards. Expressed opinions are to a reasonable degree of professional certainty. Right to Amend. reserve the right to amend these opinions based upon additional testimony and/or discovery documents. Attachment Inclusion. The attachments, as well as, underlying or foundational documents or references, to this report are specifically included and incorporated as an integral part of this report. Opinions. The following opinions are derived from my knowledge (including specialized knowledge), skill, experience, training, and education and the accumulation and analysis of reported TASER ECD experiential data, studies, and reports. 1. The M26 is a state-of-the art device. 2. The X26 is a state-of-the art device. 3. TASER ECDs are handheld battery-operated devices that are designed to be effective while delivering a low current under field-use challenging circumstances. 4. In field use, ECDs are deployed under a virtually endless myriad of circumstances. Factors including, but not limited to, of?cer factors, subject Rev: February 7, 2008 Page 2 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 7 of 44 PagelD 3291 factors, incident circumstances, distance to target, rapidly evolving nature of the incident, various clothing parameters, weather and environmental conditions, different subject body types and degrees of musculature, distances, varying degree of past or current substance in?uences. and many other factors can foreseeany play a role in the deployment and effectiveness of an ECD under these often dif?cult. stressful, and rapidly evolving circumstances. 5. Other opinions and explanations are found throughout this document and its references are incorporated herein. Early Medical Considerations of Electricity Figure 2 Galvanl (1790) From Beard 8: Rockwell 1878. Rev: February 7. 2008 Page 3 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 8 of 44 PagelD 3292 Figure 3 Let-go testing. From Dalziol, 1972. Rev: February 7. 2008 Page 4 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 9 of 44 PagelD 3293 WHAT IS Electricity is the ?ow of electrons through a conductor (a physical material that allows an electric current to ?ow through). Electrons are the negatively charged subatomic particles that orbit around the positively charged nucleus of every atom. Since we cannot physically see a ?ow of electrons through a conductor such as a metal wire, it is helpful to think of the analogy of water ?owing through a pipe, a fire hose, a garden hose, or a drinking straw. This will help you visualize and understand some of the basic principles of electricity that many students learn about in high school science classes. There are ?ve key elements to characterize electricity: Voltage, Current, Power, Energy, and Charge. (measured in ?volts? and symbolized by Also called electromotive force, voltage is the pressure behind the ?ow of electrons. As will be more fully explained later, it is important to note that high voltage in and of itself is not necessarily dangerous. A strong static electricity shock can be in excess of 30,000 volts (V) and a Van de Graff generator that many of us have experienced in science classes or museums can generate up to 25,000,000 V. In the water analogy, voltage would be the pressure measured in pounds per square inch. Voltage can also be analogized to height from how high does the water fall? The higher a waterfall or rain from the sky, the greater the pressure with which the water hits the ground. Voltage is measured in volts (one volt is the amount of force required to send one ampere (A) of current through a resistance of one ohm CURRENT (measured in ?amperes? and symbolized by or Current, measured in amperes (A), measures the ?ow rate, how many electrons ?ow each second. The ampere (A) is the International System of Units (SI) base unit of electric current 0r amount of electric charge per second. CHARGE (measured in ?coulombs? and symbolized by Is the total number of electrons moved over a given period of time. A coulomb (C) is the SI base unit of electric charge. One coulomb is equal to 6.24150962915265 1018, or approximately 6.24 quintillion, electrons or elementary charges. One is the amount of electric charge transported by a current of 1 A in 1 second 2 Voltage, expressed in volts (V), (often also referred to as electric or electrical tension) is the difference of electrical potential between two points of an electrical or electronic circuit. Voltage measures the potential energy of an electric ?eld to cause an electric current in an electrical conductor. Depending on the difference of electrical potential the voltage may be called extra low voltage, low voltage, high voltage or extra high voltage. Rev: February 7, 2008 Page 5 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 10 of 44 PagelD 3294 The water analogy would be the flow rate measured in gallons per second. Current is measured in amperes (A). One ampere (A) is equal to a ?ow rate of 1 (approximately 6,240,000,000,000,000,000 electrons) per second, while a very large number, is approximately equivalent to the number of water molecules in two (2) drops of water. In the water analogy, charge, measured in C, would be the total amount of water that has flowed, measured in gallons. POWER (measured in ?watts? and symbolized by or The watt (W) is the SI derived unit of power, equal to one joule (J) of energy per second. One is a small amount of power. A person climbing a ?ight of stairs is doing work at a rate of approximately 200 W. Power is thus the measure of the amount of energy generated by an electric current in one second. Power is a function of the voltage and the current. Hoover Dam Water Analogy Consider the water analogy that the Hoover Dam generates power from a ?ow of water. The amount of power is determined by how much water pushes through the generator, and how much pressure is behind the water. In fact, in electrical terms there is a very simple relationship between power, current, and voltage. Power is measured in watts. Water Hose Analogy In our water analogy, power is the rate at which energy is applied. Think of a fire, or garden, hose, with a certain amount of water being ejected at a certain amount of pressure. The power you would feel is a function of both the amount of water and the pressure behind it. A good analogy is a watenrvheel mill. If the current is low (trickling ?ow) but the voltage (pressure) is high because the water is falling 100 feet there will not be much power. Conversely, if the ?ow is rapid (high current) but the stream is level (no potential or voltage or pressure) then the power will also be low. Only when there is a heavy current and a high potential (large fall in water height) do we produce high power. So, in a water wheel, power current times pressure (or height). In an electrical device, power (W) current (A) times voltage (V). One horsepower is 746 watts. So, a high performance, SOD-horsepower (hp) car engine produces 223,800 watts. ENERGY (symbolized by Energy is the total energy from a given amount of power applied for a given period of time. The relationship between Energy (E) and Power (P or watt[W]) is like the relationship between Current (A) and Charge (C). Current is the ?ow rate of Charge (C). Power (W) is the Flow Rate of Energy. Energy is measured in joules (J). The is the SI unit of electrical, mechanical, and thermal energy. A is the unit of electrical energy equal to the work done when a current of one ampere (A) is passed through a resistance of one ohm (Q) for one second (3). Hence, 1 watt (W) of Power 1 (J) joule of Energy per second (5). Rev: February 7, 2008 Page 6 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 11 of 44 PagelD 3295 One is a very small amount of energy. One is approximately the amount of energy required to lift a small apple 1 meter straight up, the energy released when that same apple falls 1 to the ground, the amount of energy, as heat, a quiet person produces every 1/100'" of a second, the energy required to heat one gram (9) of dry, cool air by 1.39 degrees Celsius, or 1/100m of the energy a person can get by drinking a single drop of Pepsi? soft drink. Joule (J) - Water Analogy In the water analogy, think of a joule as a packet of energy. It could be the total energy from being hit with a garden water hose for twenty minutes, adding up all the power over that time (this would equate to a constant current delivered over a period of time). Or, it could be like getting hit with a single discrete pulse, such as a small water balloon (this would correspond to brief pulses of electric charge - similar to what a TASER device delivers). One joule is also 0.2388 calorie3 (as a measurement of heat, or thermal energy, created). Figure 4 Electricity Is the Flow of Electrons through a Conductor Table 1 Electricity/Water Analogy UNIT chage (in volts Volt (V) Pressure I in? or PSI Current (SI base unit - A) Ampere (A) Water Flow Rate Gal Second Charge (SI base unit C) Coulomb (C) Total Water Volume Gallons Power (V) Watt (W) Flow Rate Pressure Voltage (V) Current (A) Energy (J) Joule (J) Water Balloon Flow Rate Pressure _Po_w?r (W) Time I Tlme :Resistance Ohms (0) Diameter of Hose Centimeters (cm) I ECD Current Pulses PPS Bursts of Water Water Balloon BASIC ELECTRICAL PRINCIPLES (HIGH SCHOOL PHYSICS 101) A very important aspect to understand about electricity as used by an ECD is that in order for the ECD to be effective the electricity must ?ow in a complete circuit. In an ECD, an electric current starts at a battery power source, ?ows through a 3 A ?calorie? is a small amount of thermal energy. Often confused with kilocalorie (1,000 calories), the kilocalorie (kcal), often simply referred to as ?calorie,? is the common measure for the amount of food energy - as with those of us who ?count calories.? As an example, one drop of Pepsi soft drink has 21.14 calories or 0.02114 kcal. Rev: February 7. 2008 Page 7 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 12 of 44 PagelD 3296 circuit, and must return to the power source. In this respect, electricity seems different than the ?ow of water which simply ?ows downhill due to gravity or through a pipe, hose, or straw due to pressure. But eventually it ends up in the ocean and is recycled through evaporation and rain back into the water supply. In ECD electricity, the ?ow must return to the source. In some cases, such as the TASER device, the source is the energy cells, or multiple cells in a battery (of cells). In other circuits, such as your home, the source is the local power station that generates the power. Power Supply Limitation In any given electric circuit, the total power is limited by the power supply. In the case of the TASER device, the power supply is the battery of cells. Hence, the power delivered by the TASER device cannot exceed the power supplied by the battery of eight AA penlight cells (in the TASER M26 - the power level is even smaller in the TASER X26, with its two three-volt camera-type cells). 50 kilovolt (kV) from Small Batteries? A common question often asked is, ?How can the TASER device generate up to 50,000 peak arcing volts output from the very limited power of eight AA cells or 2 3 cells?? The answer is, the TASER device uses transformers and the principles of physics that de?ne the relationship between power, current, and voltage to generate the high voltage output from the very minimal power supply input. As will be explained later, the 50,000 do not enter a person?s body. 0 From a TASER M26 only 5,000 peak, 3400 average over the duration of the pulse, enter the body, or 1.44 average (one?second baseline). 0 From the TASER X26 only 1,200 peak, 400 average over the duration of the pulse, enter the body, or 0.84 average (one-second baseline). To say that 50,000 is delivered to a person from a handheld battery-powered TASER ECD is sensationalistic and very misleading. WHY TASER DEVICES ARE HIGH VOLTAGE Short Answer: TASER ECDs are high voltage to avoid the necessity of having to embed TASER probes into a person?s body to delivery energy. To be able to jump up to approximately 50 millimeters or 2 inches, combined air gap. Which allows for minimizing the discharge velocity of the probes from the TASER cartridge. Before we talk about how we generate the high voltage, let?s talk about why we need to generate a high voltage. If we think about a garden hose, the higher the pressure, the farther the water will eject from the end of the hose. Similarly, the TASER device uses high pressure (high voltage) to eject electrons from the tips of the darts across a gap of up to approximately 2 inches of accumulated air and Rev: February 7, 2008 Page 8 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 13 of 44 PagelD 3297 clothing and into a conductor such as the human body. Because of the high voltage generated, the darts from the TASER device do not have to penetrate or even touch the skin to deliver energy. The high voltage allows the TASER device electrical output to jump through up to 2 inches cumulative of air or clothing to complete the circuit with the target?s body. Electricity ?ows easily through metal wires. However, it cannot ?ow through the air very easily. It takes about 1,000 volts of ?pressure? to cause an electric arc to jump across a roughly 1 millimeter (mm) air gap. Accordingly, the TASER device must generate a peak of up to 50,000 to jump across a 50 mm (roughly 2-inch) air gap. Without the high peak arcing voltage, the TASER device would need to have much longer probe-tip needles coupled with far stronger probe propulsion to ensure penetration through various types of clothing a subject may wear and to ensure skin penetration to have any effect. This would make the TASER device far more intrusive and more likely to penetrate deeper into the body. In this respect, the usage of high voltage allows TASER to make the device a safer, less intrusive tool. 50,000 DO NOT ENTER THE BODY Even though the M26, ADVANCED TASER M18 and M18L, TASER X26, and TASER C2WI Personal Protector have a 50,000 peak open circuit voltage to jump the air gap, none of these TASER devices delivers 50,000 to a person's body. The M26 has an average (one-second baseline) voltage of 1.44 V, with a peak loaded voltage of 5,000 V, and a 3,400 average over the duration of the pulse. The X26 has an average (one-second baseline) voltage of 0.84 V, with a peak loaded voltage of 1.200 V, and a 400 average over the duration of the pulse. NOT THE VOLTS, THE DELIVERD CHARGE THAT MATTER THE MOST Many people ask how safe a TASER device can be since it generates a high (peak open circuit) voltage. In fact, voltage is not generally a key measure of electrical safety. While voltage indicates the pressure behind a ?ow of electrons and how far that electric current will arc through the air, voltage is generally not a key indicator of safety or effectiveness when it comes to stimulating the human body. The key indicator for safety and effectiveness is the number of electrons delivered into the body - is. the current (A) overtime, or the total electric charge (C) in very short duration discrete pulses, and not the high open circuit peak vonage. Rev: February 7, 2008 Page 9 Case Document 271-13 Filed 10/15/08 Page 14 of 44 PagelD 3298 Figure 5 Mother and Daughter Experience up to 20 Million from a Van de Graft Generator To demonstrate this principle, note the above, a picture of a mother and daughter happily experiencing millions of volts from a Van de Graff Generator at a science museum. This Van de Graft generator creates very high voltage, but nearly zero current. Accordingly, while the static forces associated with the high voltage cause their hair to stand on end, they feel no sensation or ill effects because virtually no current flows. Figure 6 Common U.S. Wall Outlet and TASER ECD Comparison Rev: February 7, 2008 Page 10 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 15 of 44 PagelD 3299 Another way to look at this is the difference between rain fall and a very large waterfall (such as Niagara Falls). Although rain fall travels thousands of feet it does not cause injury, while a very large waterfall travels a much less distance, yet, has much more force, and thus. can cause injury/damage. Another example is a ?re hose versus a garden hose, or a drinking straw. Rev: February 7. 2008 Page 11 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 16 of 44 PagelD 3300 TASER CURRENT (AMPERES) DOES NOT LAST LONG ENOUGH TO AFFECT THE HEART Consider static electricity. Every one of us has received at least one strong static electricity shock in our lifetime. The typical current pathway is from a doorknob through a ?ngertip then through the chest and down through the legs to the ?oor. The shock can be painful and cause a signi?cant muscle twitch, but it has never caused a cardiac much less a death. A search of over a century of medical, scienti?c, and electrical literature shows only one case of a static shock possibly affecting the heart - and that individual claimed he was cured of atrial ?brillation (a fairly benign chronic after a static shock.4 The current of a strong static shock would easily kill someone if it was continuous. But, it typically lasts less than a millionth [.0000001] of a second and is thus much too short to affect the heart. Also, there is an international standard that sets out the electrical characteristics of a ?strong static electricity" shock. This standard is necessary for many of the electrical devices we use today. Meaning, if a cell phone, a pager, a pace maker, etc. could not withstand a ?strong static electricity? shock, then each of those electrical devices would soon be damaged. Thus, the lntemational Electrotechnical Commission (IEC) has de?ned a ?strong static electricity? shock as having electrical characteristics of 15,000 volts and 30 amperes peak. (International Standard The maximum current output from a wall outlet is approximately 4,000 times higher current potential than that of a TASER ECD. TASER ECD: Low Current TASER M26 TASER X26 0.00036 A 0.00021 A ?110 volt wall outlet Christmas Tree Bulb 16 amperes (A) ?l A Figure 7 Current Comparison Screnock T. ?Static Electricity Stops a Recalcitrant Ann Intern Med. 130, no. 1 (January 5, Rev: February 7, 2008 Page 12 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 17 of 44 PagelD 3301 To appreciate TASER technology, one needs to only imagine a similar, very short shock (actually involving less peak current) but delivered repeatedly 15 to 25 times per second. This can immobilize a violent or resisting subject. but without signi?cant risk of affecting the heart. The TASER X26 is programmed to deliver a very short electrical pulse of approximately 100 microseconds (us) duration with about 100 microcoulombs (pC) of charge at 19 pulses per second (PPS) for 5 seconds The peak voltage delivered to the body is about 1,200 volts during the shock. The peak current of about 3 amperes is far less than that of a strong static electricity shock, which can be as high as 37.5 amperes.6 The average current from the TASER X26 is approximately 2 milliamperes (0.002 amperes). Now, let's put together what we?ve discussed about power, voltage. and current. Limited by the Battery Power Supply First, the power in a circuit is limited to the power output of a power supply (in the case of a TASER device, this is the battery of cells). TASER makes a sophisticated device, but there is no perpetual motion machine; nor is the product nuclear powered. Power Limited by Wire Conductors This power is further limited by the wire conductors between the TASER device and the target. The TASER device wires are very small, and are not capable of delivering large currents that would require much larger wires such as automobile jumper cables. Power Limited by Delivery Further, there is a mathematical relationship between power, voltage, and current: (power or watts (current or (voltage) In the next section we will discuss how transformers work to convert a given amount of power into different currents and voltages. But the big picture is simple for a ?xed amount of power, the HIGHER the voltage, the LOWER the current must be. For example, if the battery of cells in a TASER device could output a maximum of 50 watts (which it cannot), the table below would illustrate the maximum voltage and current it could generate: 5 This initial 5-second discharge can be interrupted at any time simply by activating the TASER device?s safety. Tutorialpdl Rev: February 7, 2008 Page 13 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 18 of 44 PagelD 3302 Power Voltage Current 50,000 0.001 A These numbers are for illustration purposes, but the point is important: With a ?xed power source and limitations such as limiting capacitors. the higher the voltage, the lower the output current must be! And, again, delivered current, or energy, is the key measurement for how electricity affects the body. Actually, a TASER M26 with a battery of 8 AA [1.2 or 1.5 per cell] cells has a peak power wattage as seen in this graph: Cm ?Velma-In 0 (I) 0793 1 1 2.00 2.9 3.00 b?Cunnt ?-Power Figure 8 Maximum Power Battery of (8 AA) Alkaline Cells Rev: February 7, 2008 Page 14 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 19 of 44 PagelD 3303 M26 Battery Alkaline Vs 18m 16.14,10.00 -- - 1 6.00 be? No} . Pulse Rate coo .0. 2.00 - - . - 0.00rnElapsed Tlrne (mmzse) woume Ultra Alkaline Pulse Rate Pulse Rate Figure 9 M26 Battery: Alkaline vs. Batteries 10I16106 In Summary 0 Voltage is the pressure that determines how far an electric arc can jump. Delivered current or energy determines how intensely the human body will react. Average Current vs. Root Mean Square (RMS): Average Current Average current is the true ?ow of the amount of charge per second. Average current is calculated by adding the amount of charge in each pulse, add all of the pulses per second, and this total provides the charge per second that is actually delivered. For TASER ECDs RMS Calculations Do Not Provide an Accurate Picture RMS current is calculated as an approximation for the current used when analyzing continuous alternating currents (AC), as opposed to pulsed current (6.9. the short duration pulses produced by TASER devices). Since an alternating current switches between positive and negative current flows if an average was calculated then the total would always average to zero because the positive and negative elements cancel each other out. In order to measure currents in AC systems. engineers frequently use RMS for two reasons. Rev: February 7, 2008 Page 15 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 20 of 44 PagelD 3304 1. RMS eliminates the negative numbers. When a negative number is squared the number then becomes positive. When calculating RMS currents a. ?rst square all the values; b. then average; c. then take the square root of the result. 2. RMS is very helpful to understand the amount of electrical power being consumed - power is a function of the square of the current (power IZR). As an example, power can measure how much thermal energy or heat an electric current can generate, or how much light a light bulb can emit. Also, since utility companies sell electricity based on power consumed (watt-hours RMS current is proportional to power and is hence a good measure for electricians and the utility company when dealing with continuous AC power. Average Current Relevant to TASER Devices The average current is more relevant to measuring TASER device outputs and far more relevant to neural stimulation, rather than heating (or continuous output), because it looks at the actual amount of charge delivered. Because of the squaring effects used in RMS, the result is not an actual measure of the charge delivered. When using RMS with pulsed currents (where there are high peak currents for very short durations of time with relatively long pauses between pulses, the RMS calculations arti?cially signi?cantly overstate the delivered current because the high peaks are squared before averaging). 2002: TASER Tried Using RMS Calculations (Learning from Experience) Back in 2002, TASER had tried using RMS to attempt to measure TASER discharge. This was similar to trying to put a large square peg into a very small round hole. Because many of the US. and international electrical safety standards are based on alternating currents, and because those standards include mathematical adjustments for comparing pulsed currents, TASER fruitlessly attempted to measure the RMS current of the TASER device for comparison to those electrical safety standards that used RMS currents. Rev: February 7, 2008 Page 16 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 21 of 44 PagelD 3305 BASIC TASER DEVICE OPERATING PRINCIPLES A TASER-brand device is an Electronic Control Device (ECD). Its intended purpose is to assist with capturing and controlling a person with minimal risk of serious injury. Prior non-lethal weapons function by merely causing pain or destructive injury. The intention with these other force tools and techniques are that the pain or the bodily injury will dissuade the subject from continuing an unwanted behavior and elicit cooperation. However, for a myriad of reasons people who are focused, under the in?uence of drugs, or who are pain insensitive may not feel pain. or may be suf?ciently motivated to attack or ?ght through pain, or even destructive injury Philadelphia barber shop incident). The proprietary Neuromuscular lncapacitation (NMI) technology in TASER devices does not solely rely on pain or on intended destructive injury for its incapacitating effect(s). Rather, the TASER device uses short-duration. pulsed. low-energy electrical stimuli to interfere with the signals sent by the command and control systems of the body, at the peripheral and motor nervous system levels, to impair the subject?s ability to temporarily voluntarily control his own body. Figure 10 Neurons. Fig. 3.1 of Reilly, 1998. F'essum Motor (muscle) and sensory neurons are responsible for movement and sensation. They operate by propagating electrical signals. Receptor The human nervous system is the command and control system of the human body. It has three primary elements: 0 The central nervous system The motor nervous system 0 The sensory nervous Muscle contraction system to) Motor neuron (bl Sensory neuron The central nervous system includes the brain and spinal cord. This is the command center, where all decision-making processes occur. One can think of the central nervous system like the computer that controls the body, including all memory and conscious thought. Out from this central computer is a network of ?wiring? that carries signals to and from the brain. This ?wiring? is composed of nerve cells, or ?neurons? that function very similarly to the wiring of a computer Rev: February 7, 2008 Page 17 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 22 of 44 PagelD 3306 network. In fact, neurons carry information in the form of electrical impulses to and from the brain. The motor nervous system includes the nerves that carry commands from the brain out to the body. These nerves are primarily involved in muscular control. Commands from the brain are transmitted as patterns of electrical impulses through the motor nerves into the muscles, causing the muscles to move in certain patterns caused by the pattern of stimulation from the brain. The sensory nervous system includes the nerves that carry information to the brain about the state of the body and its environment. Sensory nerves in the skin communicate heat, cold, touch, pressure, pain, and other sensations. Similarly, nerves carry visual data from the eyes, audio data from the ears, and olfactory data from the nose. All of this data is transmitted in the form of electrical impulses along the neurons into the brain. Figure 11 Sensory Receptors. Fig. 3.16 of Reilly (1998). . '1 Section of the skin . . . showing several types of sensory receptors. .. Sensory receptors can 5 include sensors for touch, heat, feel, pressure, cold, etc. millin- I arming Hair Padn'en receptor corpueue Figure 12 is a conceptual representation illustrating the concept of operation of TASER devices. TASER devices use very short duration low energy electrical pulses that are somewhat similar to the pulses used by neurons to communicate. If you think of the nervous system as an electrical communications network, TASER devices are like remote controls that plug into that network, and temporarily take control of, or interfere with, the communication patterns between the brain and the body. Rev: February 7, 2008 Page 18 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 23 of 44 PageID 3307 THE NERVOUS SYSTEM - . . . . . A . . ;Nerve Impulse- . TASER Impulse Figure 12 TASER Devices Stimulate the Nervous System with Pulses Similar to Those Used by Nerves to Communicate7 Telephone Network Communication Analogy One analogy helpful in understanding TASER technology is a telephone network. If person A is talking on the phone with person B, and suddenly person picks up another handset and begins yelling into the phone. persons A and can no longer effectively communicate their conversation has been interfered with. However, when person ceases yelling and disconnects, the normal conversation between A and can resume again. The telephone hardware is not damaged in any way by the yelling, it is just that the temporary over-stimulation of, or interference with the communication, the network prevented communication on a transient and temporary basis. Similarly, TASER devices cause stimulation of the nerves that is designed to be temporary in nature with minimal risk of causing serious damage to the hardware of the communication network by the interference. 7 This illustration is for illustrative conceptual purposes only. These are not intended to be scientific measurements of actual pulse characteristics. but to illustrate the basic concept for lay persons that the electrical discharge from the TASER device is a brief pulse which causes stimulation of neuron membrane mechanisms in a fashion similar to the capacitor-discharge type depolarization mechanism used by neurons in normal communications within the nervous system. Rev: February 7, 2008 Page 19 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 24 of 44 PagelD 3308 Effects of Repeated Pulses on Muscle Tension 100 200 300 400 Time (msec) Rev: February 7. 2008 Figure 13 Fig. 3.22 from Reilly, 1998. Single muscle twitches will fuse together with suf?cient repeated stimulus pulses producing increased muscle tension. TASER devices have a pulse rate of up to approximately twenty (20 1: 25%) pulses per second (ops)- Page 20 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 25 of 44 PageID 3309 HISTORY OF TASER DEVICE TECHNOLOGIES 1967 - NASA Scientist Jack Cover?s TASER TF-76 The original TASER device (the TF-76) was launched in the mid 19708 by a NASA scientist named Jack Cover, the TASER device inventor. The TASER TF-76 ?red two darts up to a distance of 15 feet. These darts remained attached to the handheld device by small, thin, insulated wires. The original TASER TF-76 used a gunpowder propellant to launch the darts. Because of the explosive propellant, the TF-76 was classi?ed by the United States Treasury Department?s Bureau of Alcohol, Tobacco and Firearms, and also now Explosives, as a ?rearm. However, the TF-76 looked like a ?ashlight. not a ?rearm. Because it did not ?t the speci?cations for either a pistol or a long gun, the TF-76 was classi?ed as a Title 2 weapon the same as a ?sawed-off? shotgun. This classi?cation meant that the TASER TF-76 could only be sold with special permits that were expensive and dif?cult to obtain (just like it would be for a ?sawed-off? shotgun). Accordingly, the TF-76 could only effectively be sold to law enforcement agencies. While the Title 2 weapon classi?cation did not adversely affect law enforcement agencies acquisition and use of the early TASER devices, it did prevent most civilians from acquiring, possessing, and using the devices. Shortly after the TF-76 was classi?ed as a Title 2 weapon, TASER Systems (the company that made the TF-76) collapsed. Tasertron Emerged This early company eventually raised funding, re-emerging as a company called Tasertron, but struggled over the next decades and sold only a limited number of devices into the law enforcement marketplace. The Tasertron devices were originally offered in seven-watt versions and then later in eleven-watt models that had a 15-foot range and still used gunpowder propellant and were still classi?ed as special class ?rearms. 19803: Studies and Risk Utility Comparisons In the 19805 there were numerous studies and risk utility analyses performed on ECDs. These included the Greg Meyer Los Angeles Police Department use of less-lethal force study and the Ordog mortality and morbidity study. Early 19905: The Need for Non-Firearm Self-Defense In the early 19905, two friends of Rick Smith?s (Corey and Todd) were shot and killed in a traf?c altercation in Scottsdale, Arizona. This tragic event caused Rick Smith to start thinking about violent crime, and wondering why the state of the art in self?defense weapons required killing other human beings -just as it had been for centuries. Mr. Smith came to believe that, if advances in technology could provide truly effective non-lethal alternatives, many people would choose non- lethal weapons instead of lethal weapons and many lives could be saved. Rev: February 7, 2008 Page 21 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 26 of 44 PagelD 3310 ICER Corporation Formed In September of 1993, brothers Rick and Tom Smith formed ICER Corporation - a company whose mission would be to develop future non-lethal electronic weapons. As part of their early research. Rick contacted Jack Cover, the original TASER inventor. Jack Cover shared with Rick the history of the TASER technology, and he proposed a business model whereby they could develop a new, non-firearm version of the TASER device using a compressed air (or nitrogen) propulsion system. On October 15, 1993 they signed an agreement whereby Mr. Cover licensed his technology to ICER Corporation and joined the corporation as a full-time employee, infusing all of his knowledge and years of experience into the company, to help develop the next generation of TASER devices. Shortly thereafter, they then changed the name of the company to AIR TASER, Inc. TASER 34000 - Generation TASER Devlce In December of 1994, this work culminated with the launch of the AIR TASER model 34000. The design intention of the AIR TASER 34000 was to use the same electrical output as the original TASER TF-76. but with a compressed air propulsion system that would comply with federal ?rearm statutes and allow for private citizen sales. The AIR TASER 34000 implemented an innovative new user accountability technology called AFID (Anti-Felon Identi?cation), which used serialized confetti tags dispersed from every cartridge at the time of ?ring. These AFID tags would enable law enforcement to trace persons who misused a TASER device. This was another ?rst for weapons? use accountability a self-defense device that left a tracer at the scene of the incident back to the purchaser. Also, the AFle are made in both paper and clear Mylar - making it more dif?cult for a criminal to pick up the AFID evidence of his crime. Also, some of the AFle are made to literally glow under a black light, thus making them very easy for law enforcement investigators to locate and recover. 1994: TASER 34000 Limited to Non-Law Enforcement Shortly after the launch of the AIR TASER 34000 in 1994, AIR TASER Inc. was sued by Tasertron, the remainder of the original TASER systems company from the 19703. Tasertron asserted that it had exclusive rights to the underlying technology for use in the law enforcement and military markets in North America. To avoid a costly legal battle, AIR TASER Inc. signed a non-compete agreement that recognized Tasertron's exclusivity and precluded AIR TASER Inc. from selling to law enforcement or military agencies in North America until the patent in question expired in 1998. Rev: February 7, 2008 Page 22 Case Document 271-13 Filed 10/15/08 Page 27 of 44 PagelD 3311 Nov. 1995: The Czech Experience: Original TASER Devices Did Not Get the Job Done! Around November of 1995, the company received an inquiry from the Czech police seeking a product demonstration in Prague. The AIR TASER's non- compete agreement with Tasertron did not preclude foreign police or military sales. Accordingly, the company agreed to make, and was very eager to give, a presentation of the AIR TASER 34000. Around December of 1995, Rick Smith ?ew to Prague with the company's head of sales. After a brief technology demonstration, the Czech police asked for a volunteer demonstration. Prior to being hit with the AIR TASER 34000, the volunteer was strongly instructed - ordered - by his superior of?cer to ?ght through the (pain compliance) effects of the 34000 device and get to the shooter Mr. Smith. In fact, several focused and highly motivated volunteers that day were all able to overcome the (pain compliance) effects of the AIR TASER 34000. 1996: ADVANCED TASER M26 Is Born Following this highly embarrassing Czech debacle, the company set out to develop a more effective device - a device that would not only involve discomfort, but also interfere with voluntary muscle control. The result of this development was the TASER M26. Earlier generations of TASER devices such as the TF-76 and the AIR TASER 34000 caused a strong peripheral-nerve shock sensation. However, focused or pain-insensitive subjects, such as the police volunteers in Prague, could ?ght through these effects. Accordingly, these earlier-generation devices can be considered stun devices. Their effects may stun the subject, but they did not cause involuntary incapacitation. Stratbucker Testing In late 1995, TASER contacted Dr. Robert Stratbucker, MD, and retained him to conduct safety studies of the impulse generator module of the TASER device. The goal of the study was to perform an analysis to establish a margin of safety for the AIR TASER 34000 by testing signi?cant increases in relevant electrical characteristics and evaluating the physiological response. Dr. Stratbucker was chosen to test the devices because he had over a decade of experience testing a number of similar devices both physically and physiologically in his laboratory and had become quite familiar with the necessary procedures to accurately accommodate such testing. Dr. Stratbucker conducted the tests in January 1996. The studies included skeletal muscle response and assessment of any possible affect on cardiac For the cardiac testing a three-channel, battery-powered cardiograph unit was continuously employed to accomplish orthogonal lead axes. Rev: February 7, 2008 Page 23 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 28 of 44 PagelD 3312 Dr. Stratbucker?s experiments corroborated earlier ?ndings in consulting reports and peer review journals8 that the electrical emission from stun-type pulse generators, delivered to the body surface in the recommended manner did not cause serious cardiac abnormalities in the othenivise healthy adult swine heart. As the study investigated outputs equivalent to 400% the capacitance and 300% the battery voltage of the standard AIR TASER 34000, an adequate margin of safety appeared to exist. Due to Dr. Stratbucker?s quali?cations and extensive knowledge and history with electronic devices he later became Medical Director. TASER M26 Developed Mr. Smith was proud to have led the development team, designed the test methodology used to develop the TASER M26, and was the listed inventor on the patent for the electrical waveform of the M26. TASER M26 Emerges 3" Generation TASER Device Because the earlier stun devices did cause a strong overwhelming discomfort (pain) sensation, they clearly caused some degree of stimulation of the sensory nervous system. However, there was little or no interference with or impairment of volitional muscular control with these early devices. In contrast, the new TASER M26 was designed to cause signi?cant, uncontrollable muscle contractions capable of incapacitating even the most focused and aggressive combatants. Accordingly, this new technology was termed Electra-Muscular Disruption (EMD). More recently, a new term was adopted that was more accurately descriptive terminology: Neuromuscular lncapacitation (NMI). Medical and Scientific Research During the development of the TASER M26 medical, scienti?c, and engineering literature was extensively researched with regard to electrical energy. safety of electrical devices, similar forms of electrical devices, etc. This research has been continuously ongoing since the mid-19905. Late 1999: ADVANCED TASER M26 The ADVANCED TASER M26 was launched in late 1999, with an initial shipment of 30 M26 devices to the New York City Police Department. with signi?cant 8 02. Roy and A.S. Podgorski. Tests on a Shocking Device - the Stun Gun. Med. 8 Biol. Eng. Comput, 1989, 27, 445-448. Robert A. Stratbucker and Matthew G. Marsh. The Relative Immunity of the Skin and Cardiovascular System to the Direct Effects of High Voltage - High Frequency Component Electrical Pulses. Proc. Engineering in Medicine 8 Biology Conference, October 1993. San Diego, CA. Pearce, J.A.. et. al: Myocardial Stimulatoin with Ultrashort DuratiOn Current Pulses. PACE, Vol. 5. January- February 1982. Rev: February 7, 2008 Page 24 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 29 of 44 PagelD 3313 shipments starting in early 2000. By this time, the company had changed its name to TASER lntemational, Inc. to signify the company had more than just the one AIR TASER product. The TASER M26 was adopted by thousands of law enforcement agencies, and was hailed as a state-of-the?art breakthrough as the ?rst non-lethal weapon capable of stopping aggressive, focused, or drug- impaired persons. in addition to the system, the TASER M26 implemented a new accountability control technology the dataport. The dataport is a function wherein the M26 would record the time and date of every trigger pull in order to allow law enforcement agencies to monitor use of the device another use-of- force accountability break through. May 2003 TASER X26 Debuted 4th Generation TASER Device In 2003, TASER introduced the new TASER X26. The X26 implemented a newer, more ef?cient electrical stimulation pulse called ?Shaped-Pulse Technology.? This new pulse allowed for a more ef?cient power supply that enabled the X26 to be packaged in a form factor that was 60% smaller and 60% lighter than the M26. However, the X26 design was tuned in laboratory testing to deliver an incapacitating effect that caused muscular contractions approximately 5% stronger than those of the M26. The TASER X26 has been very well received and as of early 2006 accounts for the majority of the company's shipments. Rev: February 7, 2008 Page 25 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 30 of 44 PagelD 3314 BASIC TASER DEVICE OPERATIONS It is common for people to ask, ?How can the TASER device generate 50,000 volts from 12 volts or less at the battery of cells (for the TASER The answer is that TASER devices use a series of transformers and capacitors, together with the principles of physics (P V). Transformers: An Electrical Lever There?s a well-known stunt performed by acrobats using a ?see-saw" device as a lever. Two acrobats jump from a given height (say 10 feet) onto one side of the lever. On the other side, a single acrobat is launched twice as high into the air. The lever transfers the momentum of the two acrobats into one acrobat, sending him twice as high. Physical Lever Transformer: Electric ?Leverzowms- 'lul I Figure 14 Understanding Transformers a 1? One can think of a transformer as an electrical lever. As electrons enter one side of the transformer from a certain voltage (similar to the height of the acrobats? jump), the leverage ratio of the transformer transfers this energy to electrons on the output side of the transformer. Depending on the design of the transformer, it can either step-up the output voltage, or step it down. In either case, the transformer is constrained by the power input (P V). In its simplest form, the transformer ?trades? volts for amperes, or vice versa. In the example above, if 2 amperes of current at 10 volts are delivered into this transformer, 1 ampere of current at 20 volts will be the output. (Note that in the real world, transformers are not 100% ef?cient, so the actual output will be less than the input.) Rev: February 7, 2008 Page 26 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 31 of 44 PagelD 3315 THE TASER CIRCUIT: AN ILLUSTRATIVE LOOK The battery of power cells is the power supply in any TASER device. In this illustrative example. the battery of cells function like a water faucet. supplying the power to the circuit. The ?pressure? out of the battery of cells in the M26 is roughly 10 volts (it drops from 12 volts, or less, as the battery of cells is loaded) and the current is roughly 4 amperes; hence the total power from the batteries is roughly 40 watts. TASER: Simpli?ed Batteries (12 Volts) Y?x' Transformer 1 Transformer 2 a I Capacitor (2000 Vol?) Output I 50,000 Volt: am? I Open Circuit I I 5,000 V011: and) Delivered I I I I I i Figure 15 An Illustrative Representation of the TASER M26 Circuit The electric current from the battery of cells is directed into a transformer (Transformer 1) that steps up the voltage by a factor of roughly 200, from 10 to 2,000 volts. As the transformer steps-up the voltage by 200x, it also steps-down the current by 200x, from 4 amperes input to roughly 0.02 amperes (the actual output is less, about 0.013 amperes due to inef?ciencies). The output of Transformer 1 is connected to a capacitor. A capacitor is a device that stores electric energy, just like a bucket would store a ?ow of water. Similar to a bucket, a capacitor can only hold so much energy. Once the capacitor is full, it dumps its energy into Transformer 2. Transformer 2 steps the voltage up again, from 2,000 volts to a peak of 50,000 volts. Similarly, the current drops again to an even lower output current. Rev: February 7, 2008 Page 27 Case Document 271-13 Filed 10/15/08 Page 32 of 44 PagelD 3316 One important note the 50,000 volts is a peak potential voltage, or open circuit voltage; it is not what is actually delivered to the person on the receiving end. If we return to the water analogy, the wires from the TASER device to the target are like hoses that carry the current. If you place a section of plastic wrap over the end of a garden hose, the pressure will build up inside the hose. At some point, the plastic wrap will ?nally burst, and the water will ?ow out the end. When the plastic bursts and the water starts to ?ow out, the pressure inside the hose drops, and the pressure of the water ?owing out is actually lower than the peak pressure that developed within the hose itself. In a TASER ECD system, the wires do not always make contact with the skin of the target. If there is an air gap between the darts and the body of the subject, the air gap will function as a barrier, just like the plastic wrap on the hose. The voltage (pressure) will build up inside the TASER wires until it can break through the barrier (the maximum would be 50,000 volts, which can break through a barrier of approximately 2 inches of air gap). Once the barrier is breached, the voltage (pressure) drops immediately as the current ?ows through. In the case of the TASER M26, the maximum voltage delivered across the body of the target is about 5,000 volts, with only 1.44 volts average (one-second baseline). In the case of the TASER X26, the maximum voltage delivered across the body of the target is about 1,200 volts, with only 0.84 volts average (one-second baseline). The big picture from this illustrative look at the TASER device is to understand that at each level, as the voltage is increased, the output current is decreased. Basics of Nerve and Muscle Stimulation As mentioned previously, the body?s neurons conduct electrical stimuli to and from the brain. When a neuron is in its resting state, electrically charged ions are pumped across the cell membrane such that net positive charge collects outside the membrane and a net negative charge collects inside the membrane. In this state, the membrane serves as a charged capacitor. When the nerve cell is stimulated, channels in the membrane open up temporarily, allowing the positive ions to temporarily rush across the membrane (opposites attract). At this moment in time, the voltage potential across the membrane brie?y ?ips polarity as the charge balance reverses. This process is called an action potential. As an action potential occurs in one section of the cell membrane, the change in the electric ?elds causes the adjacent section of the membrane to depolarize. The result is a chain reaction of action potentials cascading down the length of the neuron, thereby carrying an electric impulse along the neuron. One important point to understand about action potentials is that they come in only one magnitude. For each neuron, there is a threshold stimulation level. Once this threshold is attained, an action potential will occur. There are not different intensities of action potential, they are an ?All-or-None? phenomenon. In other words, there is no such thing as a partial or weak action potential. Either Rev: February 7, 2008 Page 28 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 33 of 44 PagelD 3317 the threshold potential is reached and an action potential occurs, or it is not reached and no action potential occurs. Each neuron can only deliver one magnitude of impulse. Whether a muscle contraction will be strong or weak is not a function of the magnitude of the impulses of the connected neurons (again, there is no difference between impulses). The difference is the pattern of impulses delivered. The section below describes the process by which these nerve impulses cause muscular contractions: The Neuromuscular Junction Nerve impulses (action potentials) traveling down the motor neurons of the sensory-somatic branch of the nervous system cause the skeletal muscle ?bers at which they terminate to contract. The junction between the terminal of a motor neuron and a muscle fiber is called the neuromuscularjunction. It is simply one kind of synapse. (The neuromuscular junction is also called the myoneural junction.) The terminals of motor axons contain thousands of vesicles ?lled with When an action potential reaches the axon terminal, hundreds of these vesicles discharge their onto a specialized area of membrane on the ?ber. This area contains a cluster of transmembrane channels that are opened by and let sodium ions diffuse in. The interior of a resting muscle ?ber has a resting potential of about -95 millivolts The in?ux of sodium ions reduces the charge, creating an end plate potential. If the end plate potential reaches the threshold voltage (approximately -50 mV), sodium ions ?ow in with a rush and an action potential is created in the ?ber. The action potential sweeps down the length of the ?ber just as it does in an axon. No visible change occurs in the muscle ?ber during (and immediately following) the action potential. This period, called the latent period, lasts from 3?10 milliseconds Before the latent period is over, the enzyme breaks down the in the neuromuscular junction (at a speed of 25,000 molecules per second) the sodium channels close, and the ?eld is cleared for the arrival of another nerve impulse. The resting potential of the ?ber is restored by an out?ow of potassium ions. The brief (1-2 ms) period needed to restore the resting potential is called the refractory period. Tetanus The process of muscles contracting takes some 50 ms; relaxation of the ?ber takes another 50 to 100 ms. Because the refractory period is so much shorter than the time needed for contraction and relaxation, the ?ber can be maintained Rev: February 7, 2008 Page 29 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 34 of 44 PagelD 3318 in the contracted state so long as it is stimulated frequently enough (6.9., 50 stimuli per second). Such sustained contraction is called tetanus. When shocks are given at one per second, the muscle responds with a single twitch. At ?ve per second and 10 per second, the individual twitches begin to fuse together, a phenomenon called clonus. At 50 shocks per second, the muscle goes into the smooth, sustained contraction of tetanus. Clonus and tetanus are possible because the refractory period is much briefer than the time needed to complete a cycle of contraction and relaxation. Note that the amount of contraction is greater in clonus and tetanus than in a single twitch. As we normally use our muscles, the individual ?bers go into tetanus for brief periods rather than simply undergoing single twitches. How the TASER Device Does What it Does to the Body TASER devices deliver very short duration electrical pulses at a rate of approximately 15?25 pulses per second. As mentioned earlier, the ?rst generation stun devices such as the TASER TF-76 and the AIR TASER 34000 only delivered suf?cient charge in each pulse to stimulate the sensory nerves close to the skin. Very little motor nerve stimulation occurred, resulting in relatively low effectiveness against focused, motivated, or pain-resistant subjects. The TASER M26 and X26 deliver a similar train of electrical pulses, also at approximately 15?25 pulses per second. However, the M26 and X26 devices deliver more electrical charge in each pulse. This higher charge results in deeper nerves, such as motor nerves, being stimulated. As a result, the motor nerves between the two electrodes ?re at a rate of roughly 20 pulses per second. This stimulation rate is suf?cient to cause clonus, where the individual twitches fuse together into a sustained contraction. However, it is well below the 50?60 pulses per second required to cause complete tetanus (a smooth, continuous contraction of the muscle tissue). Accordingly, the stimulation from the TASER device does cause less muscle contraction than the types of contractions caused voluntarily by the brain. As noted before, both nerve cells and muscle cells can be stimulated with electricity (both nerve and muscle cells use action potentials during stimulation). The mechanism of stimulation from the TASER devices is not direct electrical stimulation of muscle tissue, but stimulation of motor nerves which then stimulate muscles in a nerve-mediated mechanism. This has been demonstrated in laboratory testing wherein a test animal was administered a drug which blocked the neuronmuscular junction (similar to curare). Before the drug administration, the application of the TASER device caused signi?cant muscular contractions. After the drug administration, the TASER device application caused insigni?cant muscle reaction, demonstrating that the mechanism of effect is mediated by the Rev: Febmary 7, 2008 Page 30 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 35 of 44 PagelD 3319 motor nerves not a direct electrical stimulation of the muscle tissue. This is an important concept in that the muscle contractions are mediated by the neuromuscular junction, just as in normal activity. Varying Parameters Can Increase Strength of Muscle Contraction Effectiveness Safety of Electro-Muscular lncapacitating Devices Nor-um force for From Kw Lon 16 November2004 -- .. - .. lr' JamesRJauchom.PhD . HunanE?octlvanosleroctorato i :2 I AirForoeRaoarchLaboratory uc- - -- 9 . Figure 16 Air Force Research Lab Tests Show TASER M26 Muscle Contractions at 40% or less of Maximum Contraction Force in fact, a study by Dr. James Jauchem at the Air Force Research Laboratory (AFRL) found that the intensity of the muscle contractions caused by the TASER M26 could be increased to more than 250% of the level of contraction from the field production M26. Accordingly, the M26 generates a muscle contraction approximately 40% or less than the maximal contraction attainable with more aggressive waveforms. The X26 has been tuned to deliver a contraction roughly 5% greater than the M26 - a level still well below even 50% of the maximal contractions found in the AFRL study. While the TASER device-induced contractions are suf?cient to interfere with and impair voluntary movement and cause incapacitation in the majority of applications, they are still within the normal operating range of voluntary muscle movements associated with strenuous activities such as weight lifting, wrestling, or other athletic, sports, or exertion activities. TASER Device Outputs and Comparisons Figure 17 is a graph depicting the current output of a single TASER 34000 pulse compared to a TASER M26 pulse. The vertical axis is the magnitude of electric current. The horizontal axis is time, measured in microseconds (1 microsecond (us) 0.000001 seconds). Rev: February 7, 2008 Page 31 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 36 of 44 PagelD 3320 Current E600 1.00 - - M26 Tater Current M34000 Tour Current Figure 17 Comparison of Current Output of AIR TASER 34000 and TASER M26 Note that for a very brief period of time (about one microsecond), the peak current output from the AIR TASER 34000 reaches about 8 amperes (remember that a strong static shock can reach a peak of 30?375 amperes). However, the duration of the primary phase of the impulse is extremely short roughly ?ve microseconds. This is about ?200,000th of one second. To give you an idea of how short this pulse duration is: if you stacked 200,000 sheets of standard copier paper, the stack would be roughly 50 feet tall. If this stack of paper represented just one second in time. the duration of the primary phase of the AIR TASER 34000 pulse would be the width of just one piece of paper! Because the pulse duration is so extremely short, the amount of charge actually delivered is quite small. Consider if you turn on a faucet, even at a very high ?ow rate, but you turned it back off after 0.000005 seconds. Even though the ?ow rate for that moment in time might be high, a very small amount of water would actually have time to ?ow out - probably just a drop. If we look at the chart again. since the vertical axis is the ?ow rate and the horizontal axis is time, we can calculate the amount of actual charge delivered by taking the area under the curve. In the case of the AIR TASER 34000. the charge in the primary pulse is roughly 0.00003 coulombs (C) (or 30 microcoulombs The charge in the entire pulse (including both the positive and negative phases) is roughly 70 microcoulombs Rev: February 7, 2008 Page 32 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 37 of 44 PagelD 3321 However, it is the charge in the ?rst phase that appears to be the most important for causing peripheral nerve stimulation. Once the current changes polarity, it is actually shifting charge in the opposite direction. Hence, if the nerve cell has not reached its action potential threshold during the ?rst phase, the second negative phase actually works against it. Therefore, we believe it is the charge in the primary phase that is most relevant. However, in the interest of conservatism for rating purposes. we will consider the entire charge delivered. Since the device pulses roughly 15 times per second, we know that it will deliver 70 microcoulombs (total recti?ed charge) 15 pulses per second 1,050 microcoulombs per second. Since current is the flow rate of charge, 1,050 microcoulombs per second 1,050 microamperes 1.05 milliamperes. Since the pulse intensity from the AIR TASER 34000 was found to be insuf?cient to cause any motor neuron mediated stimulation of muscle, a new pulse waveform was developed for the TASER M26. Note that the M26 delivers a pulse that is both taller and wider than the AIR TASER 34000. Accordingly, the total charge delivered from the M26 pulse is also higher, roughly 85 microcoulombs At a nominal pulse rate of 20 pulses per second, this equates to an average recti?ed current of 3,600 microamperes 3.6 milliamperes (0.0036 A). Due to all the equipment law enforcement of?cers must carry, it was reportedly dif?cult for of?cers to ?t the TASER M26 on their duty belts for full-time carry. Accordingly. the company set out to develop a smaller TASER device that could still cause a similar amount of incapacitation. The result was a more complex waveform using ?Shaped Pulsem" Technology. (For more details on Shaped PulseTM Technology, see TASER Training version A new waveform developed using Shaped Pulse Technology, which delivered a comparable amount of charge to the waveform from the TASER M26, was implemented in a new device called the TASER X26, introduced in May of 2003. Rev: February 7, 2008 Page 33 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 38 of 44 PagelD 3322 Electrical Waveform Comparison Current X26 Waveform M26 Waveform Figure 18 Comparison of Current Output of ADVANCED TASER M26 and TASER X26 Note that the TASER X26 uses a lower peak current than the ADVANCED TASER M26, but a longer pulse duration. As a result, the X26 delivers a roughly comparable amount of charge in each pulse. In laboratory experiments, the output of the TASER X26 was designed to cause 5% stronger muscle contractions than the M26. The X26 delivers roughly 100 microcoulombs per pulse, at a pulse rate of 19 pulses per second, for an average recti?ed current of 2,100 microamperes or 2.1 milliamperes (or 0.0021 A). (Note, the primary phase of the X26 is actually negative in polarity compared to the main pulse - however most of the charge delivered is of the same polarity, one of the reasons that the X26 waveform is more ef?cient.) These patented pulses have proven highly effective at incapacitating even the most aggressive subjects while minimizing the risk of serious adverse effects. Due to the extremely short pulse durations used in TASER pulses, the charge per pulse and average current are miniscule when compared to continuous outputs such as AC currents from a wall outlet, industrial equipment, or power lines. Rev: February 7, 2008 Page 34 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 39 of 44 PagelD 3323 TASER Risk Bene?ts TASER device deployments have been shown to dramatically reduce of?cer and suspect injuries. More information can be located on the ?eld use reports. risk analysis PowerPoint presentations, etc. Use of Force Data Real world TASER Program Results "3 3.. ()tTucr Fm: I [maria Ingum hlm? 370-. '5 nn u- 3' no". Jv 32!. i "Qu.nl?" I M.- a ?ht-m 3 23?Im"war" u's '3 ?a FirearmMiami and Seattle Over 12 Months without 1 Lethal Force Shooting I .4 0? Comparison of Injuries vs Bene?t I user! Technology Rm mm: an our I MDIWIBMIMWIB . I Suspect Irwrec i I Officer 3 mi;de Ai'ecled .uq- i In than Capt {:th wt? or! Q: Luau RWWUM Ann-d r? . v?r Figure 19 TASER Risk Bene?ts DEGREE OF CERTAINTY While many of the statements in this report are factual in nature, or directly out of high school sciences revisited the expert opinions are to a reasonable degree of scienti?c, medical, and/or professional certainty. Rev: February 7. 2008 Page 35 Case 3:06-cv-00108 Document 271-13 Filed 10/15/08 Page 40 of 44 PageID 3324