Case 1:14-cv-01430-LPS Document 274-1 Filed 05/13/20 Page 1 of 6 PageID #: 18641
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`Exhibit A
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`Case: 17-2474 Document: 57-13 Page: 501 Filed: 06/20/2018
`Case 1:14-cv-01430-LPS Document 274-1 Filed 05/13/20 Page 2 of 6 PageID #: 18642
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`REMARKS
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`The prior Office Action has been carefully considered. In response thereto, the claims
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`have been amended as set forth above. Reconsideration in view of the foregoing amendments
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`and the following Remarks is respectfully requested.
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`The undersigned thanks Examiner Joy for courtesies extended during the interview of
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`8/29/2013. Agreement was reached that the combination of Bertin and Kato does not teach a
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`substantially flexible circuit layer as claimed in the independent claims and that the rejection of
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`claims based on the combination of Bertin and Kato would be withdrawn.
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`A explained during the interview» a substantially flexible serniconductor subslrate is a
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`necessary bul not a su[fident condition for a substantially flexible circuit layer. A substantially
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`flexible semiconductor substrate may he achieved by grinding until considerably thin, for
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`example to a thickness of less than 50 microns, and polishing the resulting surface. As noted in
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`the rejection, the primary rdf..~rcnce Benin fails to Leach polishing.
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`Kato teaches grinding the backside of a circuit layer and polishing the resulting surface.
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`The semiconductor substrate itself (part of the circuit layer) may be argued to be ,..;ubstantiat ly
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`flexible. However, there is no teaching or suggestion that the circuit layer as a whole is
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`substa11tially ficxiblc. The circuit layer may be fabricated in a manner that undoes or defeats
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`flexibility of the semiconductor substrate.
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`Appx10313
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`SAMSUNG ET AL. EXHIBIT 1021
`Page 2of3
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`Case: 17-2474 Document: 57-13 Page: 502 Filed: 06/20/2018
`Case 1:14-cv-01430-LPS Document 274-1 Filed 05/13/20 Page 3 of 6 PageID #: 18643
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`More particularly, a circuit layer requires one or more dielectric layers. Dielectric
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`material has an associated level of stress. For a circuit layer to be substantially ±1exible,
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`Applicant has found that the diel.;;ctric material must have lov,,· tensil.;; sLress, for example, 5 x 108
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`dynes/cm 2 tensile. Kato does nol contain any teaching or suggestion of the circuit layer being
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`flexible. Similarly, Bertin does not contain any such teaching or suggestion.
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`Withdrawal of the rejection of at least those claims rejected based solely on the
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`combination of Bertin and Kato is respectfully requested.
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`Respectfully submitted,
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`/MichaelJUre/
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`Michael J. Ure, Reg. 33,089
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`Dated: 9/26/2013
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`Appx10314
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`SAMSUNG ET AL. EXHIBIT 1021
`Page3of3
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`Case: 17-2474 Document: 57-13 Page: 503 Filed: 06/20/2018
`Case 1:14-cv-01430-LPS Document 274-1 Filed 05/13/20 Page 4 of 6 PageID #: 18644
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`REMARKS
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`The prior Office Action has been carefully considered. Reconsideration in view of the
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`present Remarks is respectfully requested.
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`The undersigned thanks Examiner Joy for courtesies extended in related application
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`12/497,652 during the interview ofS/29/2013. Identical issues are presented in the present
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`application, with certain relevant features of the claims and the art applied against the claims
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`being the same. In the related application, agreement was reached that the combination of Bertin
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`and Kato docs not teach a substantially flexible circuit layer as claimed in the independent
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`claims and that the rejection of claims based on the combination of Bertin and Kato would be
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`withdrawn.
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`A explained during the interview, a substantially flexible semiconductor substrate is a
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`necessary but not a sul!iciem condition for a substantially flexible circuiL layer. A substantially
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`flexible semiconductor substrate may he achieved by grinding until considerably thin, fix
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`example to a thickness of less than 50 microns, and polishing the result!ng surface. As noted in
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`the rejection, the primary reforence Bertin fails to teach polishing.
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`Kato teaches grinding the backside of a circuit layer and polishing the resulting surface.
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`The semiconductor substrate itself (part of the circuit layer) may be argued to be substantially
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`flexible. However, there is no teaching or suggestion that the circuit layer as a whole is
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`Appx10316
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`SAMSUNG ET AL. EXHIBIT 1022
`Page 2of3
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`Case: 17-2474 Document: 57-13 Page: 595 Filed: 06/20/2018
`Case 1:14-cv-01430-LPS Document 274-1 Filed 05/13/20 Page 5 of 6 PageID #: 18645
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`semiconductor device fabrication. (Kato col. 6, lines 5-20.) Since no such device
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`fabrication is performed in Bertin, it would not have been obvious to incorporate from
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`Kato this step, which is preparatory to semiconductor device fabrication.
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`Moreover, both Bertin and Kato fail to teach or suggest that at least one of the
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`first and second circuit layers is substantially flexible, and the substrate thereof is a
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`substantially flexible semiconductor substrate. Two features arc required to achieve
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`substantial flexibility. One is that the semiconductor material must be sufficiently thin,
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`e.g., 50 microns or less. Bertin and Kato are believed to satisfy this requirement. The
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`other is that the dielectric material used in processing the semiconductor material must be
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`sufficiently low stress. Otherwise, substantial flexibility is defeated. As set forth in the
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`present specification, stress of5 x 108 dynes/cm2 or less has been demonstrated to satisfy
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`this requirement. Neither Bertin nor Kato are believed to satisfy this requirement.
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`In relation to independent claim 4, which recites stress of 5 x 108 dynes/cm2 or
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`less, the Office Action cites Bertin, as follows:
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`[Bertin] Col. 3-5; vias are insulated with silicon dioxide which satisfies the
`circuit layers comprising a delectric material having stress as claimed ....
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`The oxide of Bertin referred to is actually thermally grown oxide. (Bertin, col. 4,
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`lines 30-31: "The trench sidewalls are oxidized to provide isolation from the bulk
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`silicon .... ") Such oxide is known to be high stress, typically 5 to 10 times the level of
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`stress demonstrated in accordance with the teachings of the present specification as being
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`sufficient to ensure that the substantial flexibility of sufficiently thin semiconductor
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`material is not defeated by stress of the dielectric material.
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`28
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`Appx16038
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`SAMSUNG ET AL. EXHIBIT 1023
`Page 28of33
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`Case: 17-2474 Document: 57-13 Page: 596 Filed: 06/20/2018
`Case 1:14-cv-01430-LPS Document 274-1 Filed 05/13/20 Page 6 of 6 PageID #: 18646
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`Furthermore, both Bertin and Kato illustrate and describe a stacked integrated
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`circuit formed on a rigid carrier. At no point is any portion of the stacked integrated
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`circuit allowed to be substantially flexible, suggesting that the stacked integrated circuit
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`is in fact inflexible.
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`The drawing figures of Bertin consistently show a rigid carrier 70. Nothing in
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`Bertin suggests a slacked integrated circuit without the rigid carrier, and there is
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`suggestion in Bertin that the rigid carrier be removed. Bertin does not teach or suggest
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`removing the rigid carrier at any point up to and including final packaging. One may
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`therefore conclude that the rigid carrier is a necessary paii of the stacked integrated
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`circuit of Bertin.
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`Likewise in Kato, the drawing figures consistently show a rigid carrier 46.
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`In the case of the present stacked integrated circuit, by contrast, the dielectric
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`stress is low in order Lo allow lhe iC layers to be thinned \vilhout subsequently being
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`subject to stress-related bowing. Consequentiy, follmving stacking, the first thick wafer
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`in the stack, not yet thinned, can then be thinned because the stress in the stack is near
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`Accordingly, the combination of Bertin and Kato is not believed to teach or
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`suggest the features of claim 1, including "wherein at least one of the first and second
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`circuit layers is substantially flexible, and the substrate thereof is a substantially flexible
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`29
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`Appx16039
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`SAMSUNG ET AL. EXHIBIT 1023
`Page 29of33
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