Industrial Heat Responds to Rossi’s Complaints

As expected, Industrial Heat has responded to the complaints Andrea Rossi has made in the lawsuit.

Here’s a link to the main document, there are other files for various exhibits which will be added later.


There is lots of reading to do and I am sure there will be lots to analyze and discuss. More to follow.

Thanks to LuFong for putting all the Exhibits mentioned in the IH answer in a Google Drive folder here:

Here is a key allegation made in the counterclaim by Industrial Heat:

“7.Beyond the fact that Guaranteed Performance could not be achieved in the required time period, Leonardo and Rossi knew that the Plant could not produce a COP of 10.0 or greater (or even a COP or 4.0 or greater) for 350 out of 400 days. As a result, Leonardo and Rossi manipulated the testing process by, among other things, 1) insisting that the Plant be relocated to Miami, far away from Industrial Heat’s offices, to provide steam to a purported manufacturing “customer” that did not actually exist; 2) manipulating, along with Fabiani, the operation of the Plant and the reports of the Plant’s purported operations, to make it appear that the Plant was producing a COP far greater than 10.0; and 3) enlisting Penon to produce a false report stating that Guaranteed Performance was achieved.

8. “Eventually Counter-Plaintiffs discovered that the test that Leonardo and Rossi
were conducting, in conjunction with the supposed “customer” in Miami, was not a real test at all,
but a carefully scripted effort to deceive Counter-Plaintiffs into 1) providing Leonardo and Rossi
with credibility in their efforts to license and promote the E-Cat IP to others and/or obtain
investments from others in their business ventures, 2) making the third payment under the
License Agreement to Leonardo, 3) paying a multitude of expenses of Leonardo and Rossi
including in connection with their operations in Florida, and 4) paying Penon and Fabiani for
services not rendered and reimbursing them for unnecessary expenses. ” (p. 25-26)

“77. Notwithstanding that Leonardo and Rossi allowed visitors to the facility in Doral
where the Plant was located on a fairly regular basis, in July 2015, Rossi denied Murray access
to the Plant without any reasonable justification. See Ex. 19. Had Murray – given his
established engineering background – been allowed to access the Plant in July 2015, he would
have immediately recognized the deficiencies in the operations that were being conducted by
Leonardo and Rossi.

“78. 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.

“79. Leonardo, Rossi, JMP, and Johnson also restricted access to the JMP area at the
Doral location, claiming that there was a secretive manufacturing process being conducted there,
when in fact it was simply recycling steam from the Plant and sending it back to the Plant as

“80. Leonardo, Rossi, JMP, Johnson and Fabiani even went so far as to create a
fictional JMP employee – James A. Bass, Director of Engineering for JMP. Despite diligent
search, Counter-Plaintiffs have not been able to identify or locate this individual, for the simple reason that he does not exist. Rather, Leonardo, Rossi, JMP, Johnson and Fabiani created this fictional person as a means of making JMP appear to be a real manufacturing company that
would need a Director of Engineering and to create a person with whom they would allegedly
interact on technical issues involving JMP’s non-existent operations and operational needs.
They even had an individual pose as James Bass in a meeting with Industrial Heat and express
JMP’s satisfaction with the steam power JMP was receiving from the Plant and using to run its
manufacturing operations. Attached as Exhibit 20 is a copy of the business card provided by this
JOHN DOE representing himself as JMP’s “Director of Engineering.” (p. 45-46)

  • GiveADogABone

    ‘No, my only problem would be with Rossi INTIMATING that Mathey was the customer, if they were NOT in any way involved. That is the fraud I refer to.

    Time has moved on and it looks like the customer could well have been Johnson Matthey Davy Ltd of London. Johnson Matthey plc bought the Davy company in 2006.

  • GiveADogABone

    Good Morrow Mr Chapman,

    I am so sorry. I missed your plea for help for eight days. Being Lumoxed for that period of time must be really distressing. Has it gone yet? If not a TASER might work or a pepper spray; good troll repellent being so hard to get?

    On the substantive issue I have, more or less, understood your technique and how it works. It did however take a while to grasp. Others might still be on the learning curve. So NO, I have never got the impression you had abandoned the cause.

    Regards and I hope you leg recovers.
    We are making some progress on the customer’s identity and their production process.

  • Slad

    Then sorry for implying anything untoward.

  • GiveADogABone
    Ameren Missouri proposed building a 1,600-MW Areva Evolutionary Power Reactor (EPR)
    In April 2009, the proposal was cancelled. In August, 2015, all plans for further expansion of nuclear-powered electricity generation at the site were scrapped.
    You’ve guessed it – its a twin EPR 2x1600MW !
    It’s a re-run of Callaway II.

  • GiveADogABone

    Good to hear from someone with once-through boiler experience. I been feeling a bit lonely on this one. I worked on two AGR nuclear power stations with once-through boilers but the control gear would be from about 1970s/80s.

    Websearch oncethrough

  • Engineer48

    Hi Bruce,

    Rossi told me there are 2 parallel condensate circulating system.

    One which delivers 85% of the volume to ALL reactors and then for each reactor, seperate topping up pumps that provide the other 15% and slightly vary their flow to maintain the desired water level in each reactor.

    If you think about it, this is how it must work.

  • Abd Ul-Rahman Lomax

    From above, Engineer48 “There are no starry eyed believers here.” Right. Just vicious, angry, obsessed fanatics who attribute what they don’t understand or disagree with to evil forces.

  • Abd Ul-Rahman Lomax

    Everything from the Answer has been reposted, and I’m not going over every document in detail, at least not yet. I am checking file sizes as a first estimate. I don’t want to download a huge pile of redundant files. However, I do have the amended Answer and the new Exhibit 26 on newvortex and the images of the Doral facility in the photo area there as reduced size jpeg files.

    This is core, from the Amended Complaint. Some here had pointed out that they had not mentioned the problem of heat dissipation. Well, now they have:

    “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.

    There is a great view of the Sekrit Customer Area.

  • GiveADogABone

    From the central computer but I submit no evidence.

  • Looks like only Exhibit 26 is new (what is it?… please be the ERV report!).

    Maybe the others were edited too?

  • GiveADogABone

    I would reverse the question somewhat.
    Q: What controls the reactor water level?
    A: Nothing directly

    Clearly the feed pumps have something to do with it but how? These feed pumps are positive displacement, precision pumps where you dial in the water flow and that is what you get.
    Q: What controls the dialed in flow?
    A: Apart from direct manual, it could be the central control computer but that is a speculation. The other point is that it is not mentioned in the Italian control schematic; the schematic only monitors the feed flow.

    In once-through boiler control(and the fin block is a once-through boiler) you move feed flow and power together and monitor the boiler outlet temperature and pressure. If the feed flow is too high, then the outlet temperature drops; if the power is too low the outlet pressure drops. You have now set up two control loops, one for power and one for temperature. Input the desired values of each and that is what you get. In other words, there is no water-level control because there is no single water level in a once-through boiler. The other thing is that once-through boilers are difficult to control and slow to respond to transients, but have little stored energy. That describes the E-cat – very inflexible; it needs steady loads at its current state of development.

    • Engineer48

      Hi Bruce,

      For each reactor, there is a water pressure sensor that tells the control box the level of the water in each reactor.

      That info is sent to the central system, which at some point of dropping fluid (remember the main central pump is providing 85% of the needed flow) commands the reactor’s auxiliary topping up pump to deliver more water into the reactor.

      • GiveADogABone

        ‘For each reactor, there is a water pressure sensor that tells
        the control box the level of the water in each reactor.’

        There are four problems with this statement :-
        1: It contradicts Rossi [1:],

        2: without a steam pressure reading there is no means to determine the saturation temperature which means there is no means to determine the superheat margin, at which point you have lost control of the boiling process,

        3: there is no water level in a once-through boiler, and

        4: one pressure sensor is insufficient to determine any water depth unless you make an assumption about the vapour pressure above.

        Andrea Rossi
        April 3rd, 2015 at 7:44 PM
        The measurement
        system of the 1 MW E-Cat is made by:
        56 thermocouples to measure the temperature of the water steam in different positions
        56 thermocouples to measure the temperature of the liquid water that flows toward the reactors in different positions
        56 pressure gauges to measure the pressure of the steam in different positions

        • Engineer48

          Hi GiveADogABone,

          However I look at the physical evidence. ie the pictures of the Blue 20kW reactors and the control box and work of the system. It may not be what Rossi has said in the past but it is what is there today and it all makes sense.

          Soon I will release my detailed 51 x 20kW reactor 1MW plant schematic.