Intellectual Ventures
`Management, LLC
`v.
`Xilinx, Inc.
`
`IPR2012-00023
`
`DEMONSTRATIVES OF PETITIONER
`Intellectual Ventures Management, LLC
`
`Hearing: November 7, 2013
`
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`‘609 Patent Claim 1
`
`
`1. A capacitor in an integrated circuit ("IC") comprising: 1. A capacitor in an integrated circuit ("IC") comprising:
`
`a core capacitor portion having a first plurality of conductive elements electrically a core capacitor portion having a first plurality of conductive elements electrically
`
`connected to and forming a first part of a first node of the capacitor formed in a first conductive connected to and forming a first part of a first node of the capacitor formed in a first conductive
`
`layer of the IC and a second plurality of conductive elements electrically connected to and layer of the IC and a second plurality of conductive elements electrically connected to and
`
`forming a first part of a second node of the capacitor formed in the first conductive layer, the forming a first part of a second node of the capacitor formed in the first conductive layer, the
`
`first plurality of conductive elements alternating with the second plurality of conductive first plurality of conductive elements alternating with the second plurality of conductive
`
`elements in the first conductive layer, and a third plurality of conductive elements electrically elements in the first conductive layer, and a third plurality of conductive elements electrically
`
`connected to and forming a second part of the first node formed in a second conductive layer connected to and forming a second part of the first node formed in a second conductive layer
`
`adjacent to the first conductive layer, at least portions of some of the second plurality of adjacent to the first conductive layer, at least portions of some of the second plurality of
`
`conductive elements overlying and vertically coupling to at least portions of some of the third conductive elements overlying and vertically coupling to at least portions of some of the third
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`plurality of conductive elements; plurality of conductive elements;
`
`a shield capacitor portion having a fourth plurality of conductive elements formed in at least a shield capacitor portion having a fourth plurality of conductive elements formed in at least
`
`the first conductive layer of the IC, the second conductive layer of the IC, a third conductive the first conductive layer of the IC, the second conductive layer of the IC, a third conductive
`
`layer of the IC, and a fourth conductive layer of the IC, the first conductive layer and the layer of the IC, and a fourth conductive layer of the IC, the first conductive layer and the
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`second conductive layer each being between the third conductive layer and the fourth second conductive layer each being between the third conductive layer and the fourth
`
`conductive layer, the shield capacitor portion being electrically connected to and forming a conductive layer, the shield capacitor portion being electrically connected to and forming a
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`second part of the second node of the capacitor and surrounding the first plurality of second part of the second node of the capacitor and surrounding the first plurality of
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`conductive elements and the third plurality of conductive elements; and conductive elements and the third plurality of conductive elements; and
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`a reference shield electrically connected to a reference node of the IC other than the a reference shield electrically connected to a reference node of the IC other than the
`
`second node of the capacitor, the shield capacitor portion being disposed between the second node of the capacitor, the shield capacitor portion being disposed between the
`
`reference shield and the core capacitor portion.reference shield and the core capacitor portion.
`
`2
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`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`‘609 Patent Claim 1
`
`Petition, at p. 5 (annotated FIG. 2A from ‘609 Patent)
`
`Petition, at p. 5 (annotated FIG. 2B from ‘609 Patent)
`
`3
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`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`Forming the fourth conductive layer out of poly
`would have been obvious
`
`
`2. The capacitor of claim 1 wherein the third conductive layer is a metal layer of the IC and 2. The capacitor of claim 1 wherein the third conductive layer is a metal layer of the IC and
`
`the fourth conductive layer is a poly layer of the IC, the shield capacitor portion including a the fourth conductive layer is a poly layer of the IC, the shield capacitor portion including a
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`first node shield plate formed in the metal layer from a plurality of metal stripes and a first node shield plate formed in the metal layer from a plurality of metal stripes and a
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`second node shield plate formed in the poly layer.second node shield plate formed in the poly layer.
`
`2nd node
`shield plate
`
`4th layer
`
`Paul, FIG. 8 (annotated)
`
`4
`
`Pet. Reply at 2
`
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`Forming the fourth conductive layer out of poly
`would have been obvious
`
`“As an alternative to the use of a metal
`layer as shown in FIG. 3B (which may be
`needed for interconnect purposes) the
`bottom shield plate 36 can be
`implemented with a poly-silicon or
`diffusion layer.”
`Anthony, 4:49-52
`
`Pet. Reply at 2-3 & 4-5
`
`5
`
`Anthony, FIG. 3B
`
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`Forming the fourth conductive layer out of poly
`would have been obvious
`Petitioner’s Expert, Morgan Johnson:
`
`Pet. Reply at 5 citing IVM 1013 (Second Declaration of Mr. Morgan Johnson), ¶ 19.
`
`6
`
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`Forming the Fourth Layer out of Poly Would
`have been Obvious
`
`Patent Owner’s Expert:
`
`Pet. Reply at 5 citing IVM1014
`(Blanchard Deposition), 51:21-24
`
`7
`
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`A person of ordinary skill in the art would have
`combined Paul and Anthony
`
`Petitioner’s Expert
`Morgan Johnson:
`
`8
`
`Pet. Reply at 5 citing IVM1013 (Second Declaration
`of Mr. Morgan Johnson), ¶ 20.
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`A person of ordinary skill in the art would have
`combined Paul and Anthony
`
`Patent Owner’s Expert
`
`9
`
`Pet. Reply at 6 citing IVM1014 (Blanchard Deposition), 52:14-25
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`Claim 8 of the ‘609 Patent
`
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`7. The capacitor of claim 1 wherein the first plurality of conductive elements comprises a first 7. The capacitor of claim 1 wherein the first plurality of conductive elements comprises a first
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`plurality of conductive strips extending along a first direction, the second plurality of conductive plurality of conductive strips extending along a first direction, the second plurality of conductive
`
`elements comprises a second plurality of conductive strips extending along the first direction, elements comprises a second plurality of conductive strips extending along the first direction,
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`and the third plurality of conductive elements comprises a third plurality of conductive strips and the third plurality of conductive elements comprises a third plurality of conductive strips
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`extending along a second direction orthogonal to the first direction. extending along a second direction orthogonal to the first direction.
`
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`8. The capacitor of claim 7 wherein each of the conductive elements in the third plurality of 8. The capacitor of claim 7 wherein each of the conductive elements in the third plurality of
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`conductive elements is adjacent to a conductive element electrically connected to and forming a conductive elements is adjacent to a conductive element electrically connected to and forming a
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`third part of the first node. third part of the first node.
`
`FIG. G of the First Johnson Declaration, IVM1002, ¶ 77, editing FIG. 13 of Paul
`Pet. Reply at 7-8
`
`10
`
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`Claim 18 of the ‘609 Patent
`
`
`
`18. 18.
`A capacitor in an integrated circuit ("IC") comprising: A capacitor in an integrated circuit ("IC") comprising:
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`a first plate formed in a first conductive layer of the IC; a second plate formed in a substrate of a first plate formed in a first conductive layer of the IC; a second plate formed in a substrate of
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`the IC; a gate dielectric layer disposed between the first plate and the second plate; the IC; a gate dielectric layer disposed between the first plate and the second plate;
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`a shield plate formed in a second conductive layer of the IC having a perimeter electrically a shield plate formed in a second conductive layer of the IC having a perimeter electrically
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`connected the second plate so as to form an electrical shield around the first plate; and connected the second plate so as to form an electrical shield around the first plate; and
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`a plurality of contacts formed between the shield plate and the second plate; wherein the shield a plurality of contacts formed between the shield plate and the second plate; wherein the shield
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`plate has a gap through which an electrical contact to the first plate extends, and the shield plate, plate has a gap through which an electrical contact to the first plate extends, and the shield plate,
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`the plurality of contacts, and the second plate provide electrical shielding for the first plate. the plurality of contacts, and the second plate provide electrical shielding for the first plate.
`
`11
`
`(Annotated FIG. 4 of Paul)
`
`Petition at 46
`
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`Claim 18 of the ‘609 Patent
`
`Decision to Institute:
`
`12
`
`Pet. Reply at 12-13 citing Decision to Institute, paper no. 11, pp. 11-12
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`Claim 19 of the ‘609 Patent
`
`Petitioner’s Expert
`Morgan Johnson:
`
`
`19. The capacitor of claim 18 wherein the first 19. The capacitor of claim 18 wherein the first
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`conductive layer is a first poly layer, the substrate conductive layer is a first poly layer, the substrate
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`comprises silicon and second plate is formed in comprises silicon and second plate is formed in
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`an N-well of the substrate and the shield plate is an N-well of the substrate and the shield plate is
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`formed in a second poly layer of the IC.formed in a second poly layer of the IC.
`
`Pet. Reply at 14 citing IVM 1002
`(First Declaration of Mr. Morgan Johnson), ¶ 88.
`
`13
`
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`Claim 19 of the ‘609 Patent
`
`Patent Owner’s Expert:
`
`14
`
`Pet. Reply at 14 citing IVM1014 (Blanchard Deposition), 60:4-12
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`Proposed Substitute Claim 20
`
`
`20. (New, substitute for original claims 1 and 8) A capacitor in an integrated circuit ("IC") comprising: 20. (New, substitute for original claims 1 and 8) A capacitor in an integrated circuit ("IC") comprising:
`
`a core capacitor portion having a first plurality of conductive elements electrically connected to a core capacitor portion having a first plurality of conductive elements electrically connected to
`
`and forming a first part of a first node of the capacitor formed in a first conductive layer of the IC and and forming a first part of a first node of the capacitor formed in a first conductive layer of the IC and
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`a second plurality of conductive elements electrically connected to and forming a first part of a a second plurality of conductive elements electrically connected to and forming a first part of a
`
`second node of the capacitor formed in the first conductive layer, the first plurality of conductive second node of the capacitor formed in the first conductive layer, the first plurality of conductive
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`elements alternating with the second plurality of conductive elements in the first conductive layer, and elements alternating with the second plurality of conductive elements in the first conductive layer, and
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`a third plurality of conductive elements electrically connected to and forming a second part of the first a third plurality of conductive elements electrically connected to and forming a second part of the first
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`node formed in a second conductive layer adjacent to the first conductive layer, each of the node formed in a second conductive layer adjacent to the first conductive layer, each of the
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`conductive elements in the third plurality of conductive elements is adjacent to a conductive element conductive elements in the third plurality of conductive elements is adjacent to a conductive element
`
`electrically connected to and forming a third part of the first node, and at least portions of some of the electrically connected to and forming a third part of the first node, and at least portions of some of the
`
`second plurality of conductive elements overlying and vertically coupling to at least portions of some second plurality of conductive elements overlying and vertically coupling to at least portions of some
`
`of the third plurality of conductive elements; of the third plurality of conductive elements;
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`a shield capacitor portion having a fourth plurality of conductive elements formed in at least the a shield capacitor portion having a fourth plurality of conductive elements formed in at least the
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`first conductive layer of the IC, the second conductive layer of the IC, a third conductive layer of the first conductive layer of the IC, the second conductive layer of the IC, a third conductive layer of the
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`IC, and a fourth conductive layer of the IC, the first conductive layer and the second conductive layer IC, and a fourth conductive layer of the IC, the first conductive layer and the second conductive layer
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`each being between the third conductive layer and the fourth conductive layer, the shield capacitor each being between the third conductive layer and the fourth conductive layer, the shield capacitor
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`portion being electrically connected to and forming a second part of the second node of the capacitor portion being electrically connected to and forming a second part of the second node of the capacitor
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`and surrounding the first plurality of conductive elements and the third plurality of conductive and surrounding the first plurality of conductive elements and the third plurality of conductive
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`elements; and elements; and
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`a reference shield electrically connected to a reference node of the IC other than the second node a reference shield electrically connected to a reference node of the IC other than the second node
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`of the capacitor, the shield capacitor portion being disposed between the reference shield and the of the capacitor, the shield capacitor portion being disposed between the reference shield and the
`
`core capacitor portion.core capacitor portion.
`
`15
`
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`Proposed Substitute Claim 20
`
`FIG. G of the First Johnson Declaration, IVM1002, ¶ 77 editing FIG. 13 of Paul
`Opposition to Motion to Amend at p. 4
`
`16
`
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`Proposed Substitute Claim 30
`
`
`30. (New, substitute for claim 13) A capacitor in an integrated circuit ("IC") comprising:30. (New, substitute for claim 13) A capacitor in an integrated circuit ("IC") comprising:
`
`a core capacitor portion having a first plurality of conductive elements electrically connected to a core capacitor portion having a first plurality of conductive elements electrically connected to
`
`and forming a first part of a first node of the capacitor formed in a first conductive layer of the IC and and forming a first part of a first node of the capacitor formed in a first conductive layer of the IC and
`
`a second plurality of conductive elements electrically connected to and forming a first part of a a second plurality of conductive elements electrically connected to and forming a first part of a
`
`second node of the capacitor formed in the first conductive layer, the first plurality of conductive second node of the capacitor formed in the first conductive layer, the first plurality of conductive
`
`elements alternating with the second plurality of conductive elements in the first conductive layer, and elements alternating with the second plurality of conductive elements in the first conductive layer, and
`
`a third plurality of conductive elements electrically connected to and forming a second part of the first a third plurality of conductive elements electrically connected to and forming a second part of the first
`
`node formed in a second conductive layer adjacent to the first conductive layer, at least portions of node formed in a second conductive layer adjacent to the first conductive layer, at least portions of
`
`some of the second plurality of conductive elements overlying and vertically coupling to at least some of the second plurality of conductive elements overlying and vertically coupling to at least
`
`portions of some of the third plurality of conductive elements;portions of some of the third plurality of conductive elements;
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`a shield capacitor portion having a fourth plurality of conductive elements formed in at least the a shield capacitor portion having a fourth plurality of conductive elements formed in at least the
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`first conductive layer of the IC, the second conductive layer of the IC, a third conductive layer of the first conductive layer of the IC, the second conductive layer of the IC, a third conductive layer of the
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`IC, and a fourth conductive poly layer of the IC, the first conductive layer and the second conductive IC, and a fourth conductive poly layer of the IC, the first conductive layer and the second conductive
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`layer each being between the third conductive layer and the fourth poly conductive layer, the shield layer each being between the third conductive layer and the fourth poly conductive layer, the shield
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`capacitor portion being electrically connected to and forming a second part of the second node of the capacitor portion being electrically connected to and forming a second part of the second node of the
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`capacitor and surrounding the first plurality of conductive elements and the third plurality of capacitor and surrounding the first plurality of conductive elements and the third plurality of
`
`conductive elements, andconductive elements, and
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`a reference shield electrically connected to a reference node of the IC other than the second node a reference shield electrically connected to a reference node of the IC other than the second node
`
`of the capacitor, the shield capacitor portion being disposed between the reference shield and the of the capacitor, the shield capacitor portion being disposed between the reference shield and the
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`core capacitor portion, wherein the reference shield includes a substrate portion of a substrate of the core capacitor portion, wherein the reference shield includes a substrate portion of a substrate of the
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`IC, a first conductive curtain extending from the substrate portion, and a second conductive curtain IC, a first conductive curtain extending from the substrate portion, and a second conductive curtain
`
`extending from the substrate portion.extending from the substrate portion.
`
`17
`
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.
`
`

`
`Proposed Substitute Claim 30
`
`Figure D.2
`
`FIG. D.2 of the First Johnson Declaration,IVM1002, ¶ 56
`(Depicting FIG. 3B of Anthony modified to incorporate
`Paul’s Structure)
`
`Opposition to Motion to amend at 7
`
`Petition, paper no. 3, p. 57
`(Annotated version of FIG. 2B of Anthony)
`
`Opposition to Motion to amend at 8
`
`18
`
`© 2013 Sterne, Kessler, Goldstein, & Fox P.L.L.C. All Rights Reserved.