`
`2
`3
`
`4
`
`5
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`6
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`7
`8
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`9
`10
`11
`12
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`14
`15
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`18
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`20
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`23
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`25
`
`Page 1
` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________________
`TAIWAN SEMICONDUCTOR
`MANUFACTURING COMPANY, LTD.
`AND TSMC NORTH AMERICA CORP., Case Nos.
` IPR2014-00781
` Petitioners, IPR2014-00782
` IPR2014-01083
`-vs- IPR2014-01086
` IPR2014-01087
`ZOND, LLC,
` Patent Owner.
`________________________________
`
` VIDEOTAPED DEPOSITION of DR. UWE KORTSHAGEN
` VOLUME I
` Minneapolis, Minnesota
` December 3rd, 2014
`
`Reported by:
`Amy L. Larson, RPR
`Job No. 87857
`
`TSG Reporting - Worldwide 877-702-9580
`
`TSMC et al v. Zond IPR2014-00799
`Page 1 Zond Ex. 2019
`
`
`
`Page 2
`
`Page 3
`
`Page 5
`
`APPEARANCES: (CONT'D.)
` WHITE & CASE
` 701 Thirteenth Street, N.W.
` Washington, D.C. 20005
` By: David Tennant, Esq.
` By: Brett Rismiller, Esq.
` For: Global Foundries
`
` O'MELVENY & MYERS
` 400 South Hope Street
` Los Angeles, California 90071
` By: Vincent Zhou, Esq. (By telephone)
` For: Advanced Micro Devices
`
` FOLEY & LARDNER
` 321 North Clark Street
` Chicago, Illinois 60654
` By: Michael Houston, Esq. (By telephone)
` For: Renesas Electronics Corporation and
` Renesas Electronics America, Inc.
`
` BAKER BOTTS
` One Shell Plaza
` 910 Louisiana Street
` Houston, Texas 77002
` By: Michael Silliman, Esq.
` For: Toshiba
`
` ALSO PRESENT: Dean Hibben, Videographer
`
`INDEX: (CONT'D.)
`PREVIOUSLY MARKED EXHIBITS:
`Exhibit TSMC 1216
`U.S. Patent 6,306,265 B1
`No Bates
`Exhibit TSMC 1221
`U.S. Patent 5,247,531
`No Bates
`Exhibit TSMC 1222
`European Patent Application
`No Bates
`Exhibit TSMC 1302
`Kortshagen Declaration - '759 Patent
`No Bates
`Exhibit
`Paper 13 - No Bates
`
`1
`2
`3
`4
`
`56789
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`APPEARANCES:
` RADULESCU
` 350 Fifth Avenue
` New York, New York 10118
` By: Etai Lahav, Esq.
` Maria Granovsky, Esq.
` For: Zond, LLC
`
` GONSALVES LAW FIRM
` 2216 Beacon Lane
` Falls Church, Virginia 22043
` By: Gregory Gonsalves, Esq.
` For: Zond, LLC
`
` DUANE MORRIS
` 100 High Street
` Boston, Massachusetts 02110
` By: Anthony Fitzpatrick, Esq.
` For: Taiwan Semiconductor Manufacturing
` Company Limited and
` TSMC North America
`
` HAYNES AND BOONE
` 2323 Victory Avenue
` Dallas, Texas 75219
` By: David McCombs, Esq.
` By: Gregory Huh, Esq.
` For: Taiwan Semiconductor Manufacturing
` Company Limited and
` TSMC North America
`
` ///
`
`Page 4
`
`1
`2
`3
`4
`
`56
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`7
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`13
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`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`INDEX:
`2
`EXAMINATION BY: PAGE
`3 Mr. Lahav....................................9
`4
`EXHIBITS MARKED FOR IDENTIFICATION:
`5
`Exhibit 2004................................95
`U.S. Patent No. 6,398,929 B1
`6
`No Bates
`7
`PREVIOUSLY MARKED EXHIBITS:
`8
`Exhibit TSMC 1001
`U.S. Patent No. 6,853,142 B2
`9
`No Bates
`10
`Exhibit INTEL 1002
`Kortshagen Declaration - '759 Patent
`11
`No Bates
`12
`Exhibit TSMC 1003
`High-Current Low-Pressure Quasi-Stationary
`13
`Discharge in a Magnetic Field
`Experimental Research
`14
`No Bates
`15
`Exhibit TSMC 1004
`U.S. Patent No. 6,190,512 B1
`16
`No Bates
`17
`Exhibit TSMC 1201
`U.S. Patent No. 7,147,759 B2
`18
`No Bates
`19
`Exhibit TSMC 1202
`Kortshagen Declaration - '142 Patent
`20
`No Bates
`21
`Exhibit TSMC 1204
`Ionization Relaxation in a plasma produced
`22
`by a pulsed inert-gas discharge
`No Bates
`23
`24
`25
`
`Exhibit TSMC 1205
`U.S. Patent 6,413,382 B1
`No Bates
`
`TSG Reporting - Worldwide 877-702-9580
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`Page 6
`1
`THE VIDEOTAPED DEPOSITION OF DR. UWE KORTSHAGEN,
`2
`VOLUME I, taken on this 3rd day of December, 2014,
`3
`at The Commons Hotel, 615 Washington Avenue, S.E.,
`4 Minneapolis, Minnesota, commencing at
`5
`approximately 7:37 a.m.
`
`67
`
`89
`
`10
`11
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`Page 7
`
`1
` DR. UWE KORTSHAGEN
`2 Avenue, New York, New York. The court
`3
`reporter is Amy Larson in association
`4 with TSG Reporting.
`5
` Will counsel please introduce yourselves.
`6
` MR. LAHAV: Etai Lahav of
`7
`Radulescu, LLP, representing the patent owner
`8
`Zond.
`9
` MS. GRANOVSKY: Maria Granovsky,
`10
`Radulescu, LLP, representing Zond.
`11
` MR. GONSALVES: Greg Gonsalves
`12
`representing Zond.
`13
` MR. FITZPATRICK: Anthony
`14
`Fitzpatrick from Duane Morris, LLP,
`15
`representing Taiwan Semiconductor
`16 Manufacturing Company Limited and TSMC
`17
`North America.
`18
` MR. TENNANT: David Tennant with
`19 White & Case representing Global Foundries.
`20
` MR. MCCOMBS: David McCombs with
`21
`Haynes & Boone representing TSMC
`22
`North America and Taiwan Semiconductor
`23
`Limited and Fujitsu.
`24
` MR. HUH: Gregory Huh with
`25
`Haynes & Boone representing TSMC and Fujitsu.
`Page 9
`
` P R O C E E D I N G S
`
` THE VIDEOGRAPHER: This is the
` start of tape number 1 in the videotaped
` deposition of Dr. Uwe Kortshagen in the
` matter of Taiwan Semiconductor Manufacturing
` Company, LL -- LTD, et al. Versus Zond, LLC,
` in the United States Patent and Trademark
` Office before the Patent Trial and Appeal
` Board, case numbers IPR 2014-00781,
` IPR 2014-00782, IPR 2014-01083,
` IPR 2014-01086, and IPR 2014-01087.
` This deposition is being held at the
` Commons Hotel in Minneapolis, Minnesota, on
` December 3rd, 2014, at approximately
` 7:41 a.m.
` My name is Dean Hibben, I'm the legal
` video specialist from TSG Reporting,
` Incorporated, headquartered at 747 Third
`
`Page 8
`
`1
` DR. UWE KORTSHAGEN
`2
` MR. RISMILLER: Brett Rismiller
`3 with White & Case representing Global
`4
`Foundries.
`5
` THE VIDEOGRAPHER: And those on
`6
`the phone, please.
`7
` MR. ZHOU: Yes, this is Xin-Yi
`8
`Zhou. It's spelled X-I-N dash Y-I, and the
`9
`last name is Z-H-O-U, and I represent
`10
` Advanced Micro Devices, Inc.
`11
` MR. HOUSTON: This is
`12 Michael Houston of Foley & Lardner
`13
`representing Renesas Electronics Corporation
`14
`and Renesas Electronics America, Inc.,
`15
`Renesas being spelled R-E-N-E-S-A-S, for the
`16
`court reporter.
`17
` MR. SILLIMAN: Michael Silliman
`18
`here, last name is S-I-L-L-I-M-A-N, from
`19
`Baker, Botts, LLP, representing Toshiba.
`20
` THE VIDEOGRAPHER: And would the
`21
`court reporter please swear in the witness.
`22
` DR. UWE KORTSHAGEN,
`23
` a witness in the above-entitled action,
`24
` after having been first duly sworn, was
`25
` deposed and says as follows:
`
`1
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` DR. UWE KORTSHAGEN
` MR. FITZPATRICK: Before we begin
` the questioning this morning, I did want to
` state on the record that objections that I
` make or that Mr. Tennant makes will apply to
` all petitioners, to avoid having -- us
` having to make duplicate objections.
` MR. LAHAV: And we agree with
` that. And if we could actually limit it to
` statements from Mr. Fitzpatrick that would be
` best, but --
` MR. FITZPATRICK: Our intention is
` to try to do that to the extent possible.
` MR. LAHAV: Okay. Thank you.
`
` EXAMINATION
`BY MR. LAHAV:
`Q. Good morning.
`A. Good morning.
`Q. Can you please state your full name for the
` record.
`A. My full name is Uwe Richard Kortshagen.
`Q. And can you spell all of that.
`A. The first name is spelled U-W-E. The middle
` name R-I-C-H-R -- A-R-D, and the last name
`3 (Pages 6 to 9)
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`Page 10
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`Page 11
`
`1
` DR. UWE KORTSHAGEN
`2
` is K-O-R-T-S-H-A-G-E-N.
`3 Q. Have you ever given a deposition before?
`4 A. No.
`5 Q. Okay. So I'm going to go over some of the
`6
` rules of depositions, okay?
`7 A. Thank you.
`8 Q. Do you understand that you've just taken an
`9
` oath to testify truthfully?
`10
`A. Yes.
`11
`Q. And you will testify truthfully today?
`12
`A. Yes.
`13
`Q. You understand that I'm going to be asking
`14
` you questions?
`15
`A. Yes.
`16
`Q. And that you have an obligation to answer my
`17
` questions?
`18
`A. Yes.
`19
`Q. And that even if your counsel objects to my
`20
` questions, you still have to answer them; do
`21
` you understand that?
`22
`A. Yes.
`23
`Q. The one exception to that is if you get
`24
` instructed on attorney work product or
`25
` attorney/client privilege; do you understand?
`Page 12
`
`1
` DR. UWE KORTSHAGEN
`2 Q. Is there any other reason why you can't
`3
` testify truthfully today?
`4 A. No.
`5 Q. Okay. Where are you currently employed?
`6 A. At the University of Minnesota.
`7 Q. And what is your title?
`8 A. I'm a professor of mechanical engineering.
`9 Q. In your CV you reference a diploma degree in
`10
` physics in June of 1988, and it's -- how do
`11
` you pronounce the name of the university?
`12
`A. The University of Bochum.
`13
`Q. Bochum?
`14
`A. Bochum.
`15
`Q. Bochum. And is a diploma degree like a
`16
` bachelor's degree in the United States?
`17
`A. It is probably between a bachelor's and a
`18
` master's degree. It is a five-year degree.
`19
`Q. Okay. Did you -- okay. And then you
`20
` obtained a Ph.D. in January of 1991 from the
`21
` same university?
`22
`A. That is correct, yes.
`23
`Q. Did you prepare a dissertation in connection
`24
` with your Ph.D.?
`25
`A. Yes, I did.
`
`1
` DR. UWE KORTSHAGEN
`2 A. Yes.
`3 Q. Please allow me to finish my question before
`4
` you answer, okay?
`5 A. Yes.
`6 Q. Thank you. If you don't understand a
`7
` question or you would like me to rephrase,
`8
` please ask me to do so, okay?
`9 A. Yes.
`10 Q. If I ask a question and you answer it, I'm
`11
` going to assume you understood it. Is that
`12
` fair?
`13 A. Yes.
`14 Q. Okay. Please also be careful to give
`15
` audible, verbal answers to my questions, all
`16
` right?
`17 A. Yes.
`18 Q. So uh-huhs or nuh-uhs, the court reporter has
`19
` trouble taking those, so it's important to
`20
` give the verbal answers, all right?
`21 A. Yes.
`22 Q. Are you taking any medications that might
`23
` impair your ability to testify truthfully
`24
` today?
`25 A. No.
`
`Page 13
`
`1
` DR. UWE KORTSHAGEN
`2 Q. What was the topic of that dissertation?
`3 A. The topic was on electron energy distribution
`4
` functions in radio frequency produced
`5
` plasmas.
`6 Q. Did you study any particular applications?
`7 A. I studied a particular method of generating
`8
` plasmas based on so-called propagating
`9
` surface waves.
`10 Q. And did you -- did you study any particular
`11
` commercial application or application of any
`12
` particular endeavor other than the
`13
` generalized -- generation of plasmas?
`14 A. No.
`15 Q. Okay. Did that dissertation entail research
`16
` relating to generation of plasmas inside a
`17
` magnetron?
`18 A. No.
`19 Q. Did you study in your dissertation generating
`20
` plasmas for purposes of sputtering?
`21 A. No.
`22 Q. After your Ph.D., under education your CV
`23
` lists a, quote, habilitation in experimental
`24
` physics?
`25 A. That is correct.
`
`4 (Pages 10 to 13)
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`Page 14
`
`Page 15
`
`1
` DR. UWE KORTSHAGEN
`2 Q. What is a habilitation in experimental
`3
` physics?
`4 A. Habilitation is a specific degree in the
`5
` German academic system which at that time in
`6
` the 1990s was required to become a.
`7
` university professor.
`8 Q. Does it correlate with post-doc research?
`9 A. Yeah, you may correlate it with -- with an
`10
` advanced post doc. It also includes writing
`11
` yet another thesis, habilitation, but one is
`12
` already in the position to advise Ph.D.
`13
` students at that point.
`14 Q. Was there any coursework required --
`15 A. No, there is no --
`16 Q. Go ahead.
`17 A. No, there is no coursework required.
`18 Q. What was the topic of your thesis for your
`19
` habilitation?
`20 A. The topic of the thesis was on kinetic theory
`21
` and experiments studying electron
`22
` distribution functions in a wide range of
`23
` plasmas.
`24 Q. In that, quote, "wide range of plasmas," end
`25
` quote, did that include plasmas used for
`Page 16
`
`1
` DR. UWE KORTSHAGEN
`2
` sputtering?
`3 A. Yes.
`4 Q. Did it include plasmas used for magnetron
`5
` sputtering?
`6 A. No.
`7 Q. Can you explain the work you did in
`8
` connection with your habilitation related to
`9
` plasmas used for sputtering?
`10
`A. Among other -- among the different systems
`11
` that I studied at that time was a particular
`12
` plasma system called capacitively coupled
`13
` plasma, and such kinds of plasmas can be used
`14
` for the chemical vapor deposition of films,
`15
` but they can also be used for sputtering.
`16
`Q. And sputtering is not chemical vapor
`17
` deposition, correct?
`18
`A. I would call it more physical vapor
`19
` deposition.
`20
`Q. So sputtering is physical vapor deposition
`21
` and chemical vapor deposition is some other
`22
` process, right?
`23
`A. Could you repeat that question, please?
`24
`Q. Sure. I'm not going to repeat it, I'm going
`25
` to change it.
`
`Page 17
`
`1
` DR. UWE KORTSHAGEN
`2
` When -- when people in the art talk about
`3
` chemical vapor deposition, that's something
`4
` different than sputtering, correct?
`5 A. Generally, I would say this is correct, yes.
`6 Q. So you said you studied this capacitively?
`7
` coupled plasmas that could be used for
`8
` sputtering. Did you study them in connection
`9
` with their use for sputtering?
`10 A. I studied them with respect to their -- how
`11
` should I express it -- with respect to the
`12
` properties of electrons within these plasmas,
`13
` in particular, the energy distribution
`14
` function of electrons.
`15 Q. But you didn't study how to make use of that
`16
` energy distribution function with respect to
`17
` sputtering, correct?
`18
` MR. FITZPATRICK: Objection to the
`19
` form of the question.
`20
` THE WITNESS: I think the correct
`21
` way to answer this is to say that the
`22
` fundamental studies of electron distribution
`23
` functions that I performed also applied to
`24
` situations of sputtering.
`25
`BY MR. LAHAV:
`
` DR. UWE KORTSHAGEN
`Q. Did you apply them?
` MR. FITZPATRICK: Objection to the
` form of the question.
` THE WITNESS: If you're asking me
` whether I applied what I learned at the time.
` to sputtering, the answer is no.
`BY MR. LAHAV:
`Q. Did you study how those plasmas might be used
` for sputtering?
`A. No.
`Q. Do you have any industry experience? Have
` you ever worked in industry?
`A. No.
`Q. Have you ever operated a PVD apparatus?
`A. No.
`Q. So you've never operated a magnetron
` sputtering chamber, for example, right?
`A. No.
`Q. Have you ever designed a magnetron sputtering
` chamber?
`A. No.
`Q. The focus of your research with respect to
` plasmas relates to nanoparticles and
` nanocrystals, correct?
`5 (Pages 14 to 17)
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` DR. UWE KORTSHAGEN
`A. That is one part of my research, yes.
`Q. Is that the main focus of your research?
` MR. FITZPATRICK: Objection to the
` form of the question.
` THE WITNESS: I would say in
` terms of my effort, in terms of the number of
` graduate students within my group working on.
` that topic is probably two-thirds of my
` effort.
`BY MR. LAHAV:
`Q. Do -- have you ever had any graduate students
` working for you that have worked on magnetron
` sputtering applications?
`A. I think the answer is yes.
`Q. How many?
`A. I really had to take a guess here. I guess
` five, maybe -- maybe more. And if I may
` explain this, magnetron sputtering is a
` standard technique to deposit metal films or
` other films, and my students routinely use
` this tool, this technique to deposit metal
` films or other films for their research.
`Q. Okay. And do they do that under your
` guidance?
`
`Page 20
`
`1
` DR. UWE KORTSHAGEN
`2 A. They perform their research under my
`3
` guidance, yes.
`4 Q. Did they use the magnetron sputtering tools
`5
` under your guidance?
`6 A. No.
`7 Q. Under whose guidance did they perform the
`8
` magnetron sputtering?
`9 A. So because magnetron sputtering as an
`10
` application is a routine technique, my
`11
` students usually get trained by a
`12
` professional staff member at the university,
`13
` and after this training are free to use this
`14
` tool after scheduling its use.
`15 Q. So the magnetron sputtering that your Ph.D.
`16
` students use is a routine technique, correct?
`17
` MR. FITZPATRICK: Objection to the
`18
` form of the question.
`19
` THE WITNESS: The magnetron
`20
` sputtering that my students use is used for
`21
` routine deposition of films, yes.
`22
`BY MR. LAHAV:
`23 Q. But even today there is cutting edge --
`24
` cutting-edge research being performed with
`25
` respect to magnetron sputtering, right?
`Page 21
`
`1
` DR. UWE KORTSHAGEN
`2
` MR. FITZPATRICK: Objection to the
`3
` form of the question.
`4
` THE WITNESS: Yes, I believe that
`5
` there is research being performed on
`6
` sputtering, yes.
`7
`BY MR. LAHAV:
`8 Q. Just not in your group, correct?
`9 A. That is correct.
`10 Q. In the several declarations that you've
`11
` submitted in these cases, you've mentioned
`12
` that most of your Ph.D. students go on to
`13
` work on plasmas either in academia or the
`14
` semiconductor industry; is that true?
`15 A. Yes, that is correct.
`16 Q. And the Ph.D. students who go on to work in
`17
` the semiconductor industry, do you know if
`18
` their chosen line of work is in magnetron
`19
` sputtering?
`20 A. I'm sorry, I can't really tell you that
`21
` for -- for all of my students, because once
`22
` students leave my group and enter a company,
`23
` quite often I lose track of what specifically
`24
` they're working on.
`25 Q. Do you have any recollection of a student
`
` DR. UWE KORTSHAGEN
` who went to work for a semiconductor company
` who told you, "Hey, I'm going to go work in
` magnetron sputtering"?
`A. No, I don't have any recollection of that.
`Q. Which semiconductor companies do your?
` students work for, that you know of?
`A. Yes, I have at least one student who is
` working at Intel, two former students who are
` working at Micron Technologies, and probably
` five or six students who work at
` Lam Research, or previously Novelis before it
` was bought by Lam Research. There are one or
` two other students who work at companies
` whose name escapes me now.
`Q. Okay. Apart from your involvement in these
` IPR proceedings, do you have any professional
` connection to Intel?
`A. No.
`Q. Gillette?
`A. No.
`Q. AMD?
`A. No.
`Q. Hynix?
`A. Could you -- could you repeat the last name,
`6 (Pages 18 to 21)
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`1
` DR. UWE KORTSHAGEN
`2
` please.
`3 Q. Hynix or SK Hynix?
`4 A. No.
`5 Q. Global Foundries?
`6 A. No.
`7 Q. Fujitsu?
`8 A. No.
`9 Q. TSMC?
`10 A. No.
`11 Q. Renesas?
`12 A. No.
`13 Q. Or Toshiba?
`14 A. No.
`15 Q. Do you referee papers for any journals?
`16 A. I do.
`17 Q. For which journals?
`18 A. I'm afraid there are too many journals to
`19
` give you a complete list now.
`20 Q. Okay. Do you have a selection of the
`21
` journals that you referee papers for most
`22
` often?
`23 A. I could -- let's -- let's start with some
`24
` plasma-related journals. I'm on the
`25
` editorial advisory board of a journal called
`Page 24
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`
` DR. UWE KORTSHAGEN
` Plasma Sources Science and Technology, and so
` I review papers for that journal. I review
` papers for the Journal of Vacuum Science.
` There are actually two journals, Journal of
` Vacuum Science A and Journal of Vacuum
` Science B. Journal of Applied Physics; the
` IEEE Transactions of Plasma Science; the
` Physics of Plasmas; Journal of Physics D
` Applied Physics; Physical Review E;
` Physical Review Letters. Yeah, I can't come
` up with any other journal at the moment.
` And then there is a whole range of
` journals which sends me papers concerning my
` nanomaterials work, which is maybe not that
` relevant for -- for plasma work.
`Q. Is there a particular subgenre of plasma
` papers that are routed to you for -- for
` review?
` MR. FITZPATRICK: Objection to the
` form of the question.
` THE WITNESS: I think that the
` papers which are often referred to me are
` referred to me for my expertise in kinetic
` theory of plasmas.
`
`Page 25
`
`1
` DR. UWE KORTSHAGEN
`2
`BY MR. LAHAV:
`3 Q. But not for any particular application,
`4
` correct?
`5 A. No, not typically directed to any particular
`6
` application.
`7 Q. As is common in academia, there -- is it the
`8
` case that there are publications with your
`9
` name on them that -- where -- where a
`10
` substantial -- where a substantial amount of
`11
` the work was performed by your students?
`12
`A. That is very common, yes.
`13
`Q. And that is true for you as well?
`14
`A. Very much so, yes.
`15
`Q. Okay. When your name goes on a paper do you
`16
` review and edit it?
`17
`A. Yes.
`18
`Q. I've handed you Paper 13 in the 00781
`19
` proceeding. Paper 13 is the Board's decision
`20
` instituting Proceeding 781; do you agree?
`21
`A. I must admit I didn't listen to the case
`22
` number when you just stated it. Do you want
`23
` to restate it so that I can say yes or no?
`24
`Q. Sure. I've handed you Paper 13 in the 781
`25
` proceeding.
`
`1
` DR. UWE KORTSHAGEN
`2 A. Yes.
`3 Q. Paper 13 is the Board's decision instituting
`4
` Proceeding 781; do you agree?
`5 A. I agree. Thank you.
`6 Q. Have you reviewed Paper 13 before?
`7 A. Yes, I have reviewed this paper.
`8
` MR. FITZPATRICK: Counsel, is this
`9
` going to be an exhibit? Are you going to
`10
` mark this as an exhibit?
`11
` MR. LAHAV: As I did in the last
`12
` depositions if it already has a -- I'm happy
`13
` to mark it. It already has a control number,
`14
` Paper 13, in that proceeding.
`15
` MR. FITZPATRICK: It's your
`16
` deposition.
`17
` MR. LAHAV: Yeah. Okay.
`18
`BY MR. LAHAV:
`19 Q. Please turn to page 9 of Paper 13.
`20 A. (Complies.)
`21 Q. And page 9 begins a section on claim
`22
` construction of weakly ionized plasma and
`23
` strongly ionized plasma, correct?
`24 A. Yes, that is correct.
`25 Q. If you turn to page 11, the Board adopted a
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`1
` DR. UWE KORTSHAGEN
`2
` construction of weakly ionized plasma as, "A
`3
` plasma with a relatively low peak density of
`4
` ions," correct?
`5 A. That is correct.
`6 Q. Do you agree with that construction?
`7 A. I agree with that construction.
`8 Q. And the Board adopted a construction of
`9
` strongly ionized plasma as, quote, "A plasma
`10
` with a relatively high peak density of ions,"
`11
` end quote, right?
`12 A. That is correct.
`13 Q. And do you agree with that construction?
`14 A. Yes.
`15 Q. Is it your understanding that the Board's
`16
` construction of the terms weakly ionized
`17
` plasma and strongly ionized plasma are
`18
` relative terms?
`19 A. I believe that is what it is, yes.
`20 Q. And in your analysis and opinions you've
`21
` applied those terms as relative terms,
`22
` correct?
`23 A. That is correct.
`24 Q. Does there have to be -- I'll withdraw that.
`25
` Is a plasma with a relatively --
`
`Page 28
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`1
` DR. UWE KORTSHAGEN
`2
` withdraw. I'll start that again.
`3
` Is a plasma with a peak density of ions
`4
` of 5 times 10 to the sixth a strongly ionized
`5
` plasma if there is a lower -- or if there is
`6
` a weakly ionized plasma of four times ten to
`7
` the sixth? Let me withdraw that. I'm going
`8
` to ask it slightly differently.
`9
` In your opinion, can a plasma with a peak
`10
` density of ions of 5 times 10 to the sixth be
`11
` strong -- a strongly ionized plasma?
`12 A. Could you be so kind to specify the units
`13
` that you're using?
`14 Q. I can, if I can remember the correct units.
`15
` I think it's ions per volume, but I can look
`16
` at a -- what is the normal density units
`17
` that's used in the context of plasma
`18
` densities?
`19 A. Well, it depends.
`20 Q. Ions per cubic centimeter.
`21 A. Uh-huh.
`22 Q. Okay. So let's do this again. In your
`23
` opinion, can a plasma having a relatively
`24
` high peak density -- I'm going to do this for
`25
` the fifth time.
`
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` DR. UWE KORTSHAGEN
` In your opinion, can a plasma with a peak
` density of ions of 5 times 10 to the sixth
` ions per cubic centimeter be considered a
` strongly ionized plasma?
` MR. FITZPATRICK: Objection to the
` form.
` THE WITNESS: Yeah, unfortunately
` I can't answer that question without more
` specific knowledge about what kind of plasma
` we're talking about.
`BY MR. LAHAV:
`Q. What more information do you need to know in
` order to answer that question?
`A. Well, you are asking the question whether a
` plasma with a density of, I believe it was,
` 5 times 10 to the sixth per cubic centimeter
` can be a strongly ionized plasma. I think
` the correct answer is that you will be able
` to find plasmas with a density of ions of 5
` times 10 to sixth per cubic centimeter that
` can be considered strongly ionized.
`Q. In what situation?
`A. I have to guess, but I guess, for instance,
` in the ionosphere of the earth that would be
`
`1
` DR. UWE KORTSHAGEN
`2
` correct.
`3 Q. How about in a magnetron sputtering chamber?
`4 A. In a magnetron sputtering chamber I think it
`5
` would be unusual to call a plasma of such a
`6
` density strongly ionized, even though you
`7
` could, if you wanted to, create conditions in
`8
` the magnetron sputtering chamber where a
`9
` plasma of that density could be called
`10
` strongly ionized.
`11
`Q. What is that situation?
`12
`A. It's likely a situation which would not be
`13
` used in any practical application, but you
`14
` could decide to create a plasma in your
`15
` magnetron chamber at extremely low pressure.
`16
`Q. What do you mean by extremely low pressure?
`17
`A. So that the density of your neutral atoms is
`18
` very low.
`19
`Q. What would that density be?
`20
`A. I can't tell you off the top of my head.
`21
` Yeah, I don't know if it would actually
`22
` correspond to any kind of realistic pressure.
`23
`Q. So you're saying that 5 times 10 to the sixth
`24
` ions per cubic centimeter would not be a
`25
` strongly ionized plasma in a magnetron
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`1
` DR. UWE KORTSHAGEN
`2
` sputtering chamber under any conditions?
`3
` MR. FITZPATRICK: Objection to the
`4
` form.
`5
` THE WITNESS: No, I'm not saying
`6
` that. I think -- can you repeat your
`7
` question, please?
`8
` MR. LAHAV: Yes.
`9
`BY MR. LAHAV:
`10 Q. Is it your opinion that 5 times 10 to the
`11
` sixth ions per cubic centimeter can never be
`12
` considered a strongly ionized plasma in a
`13
` magnetron sputtering chamber under any
`14
` conditions?
`15
` MR. FITZPATRICK: Same objection.
`16
` THE WITNESS: I can't -- I cannot
`17
` agree to -- to the term can never be
`18
` considered, because as I said, if you go to
`19
` very low pressure, unreasonably low pressure,
`20
` and you were to be able to create a plasma of
`21
` such density, then at this very low pressure
`22
` it may be reasonable to call a plasma a
`23
` strongly ionized plasma.
`24
`BY MR. LAHAV:
`25 Q. Well, pressure, what magnitude of pressure
`Page 32
`
`1
` DR. UWE KORTSHAGEN
`2
` are you thinking of?
`3 A. Significantly lower than 1 millitorr.
`4 Q. Can a plasma with a peak ion density of
`5
` 5 times 10 to the sixth ions per cubic?
`6
` centimeter ever be considered a strongly
`7
` ionized plasma under reasonable pressures
`8
` for magnetron sputtering?
`9
` MR. FITZPATRICK: Objection to the
`10
` form.
`11
` THE WITNESS: I think it would be
`12
` unusual to do that.
`13
`BY MR. LAHAV:
`14 Q. Can a plasma with a peak ion density of
`15
` 5 times 10 to the sixth ions per cubic
`16
` centimeter ever be considered a strongly
`17
` ionized plasma under reasonable pressures for
`18
` magnetron sputtering?
`19
` MR. FITZPATRICK: Objection to the
`20
` form.
`21
` THE WITNESS: I think it would be
`22
` highly unusual to do that, but because we are
`23
` defining strongly and weakly ionized plasma
`24
` in relative terms here, it would also depend
`25
` on what we -- what we are comparing it with.
`Page 33
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`1
` DR. UWE KORTSHAGEN
`2
`BY MR. LAHAV:
`3 Q. So if there were a; plasma existing in a?
`4
` magnetron sputtering chamber a microsecond
`5
` earlier which had a peak density of ions of
`6
` 4 times 10 to the sixth ions per cubic
`7
` centimeter, then the plasma which has a
`8
` peak ion density of 5 times 10 to the sixth
`9
` ions per cubic centimeter would be considered
`10
` a strongly ionized plasma, correct?
`11
` MR. FITZPATRICK: Objection to the
`12
` form.
`13
` THE WITNESS: I think it would be
`14
` highly unusual to define it as such.
`15
`BY MR. LAHAV:
`16 Q. Would you?
`17 A. I would not.
`18 Q. Okay. So does that mean you disagree with
`19
` the Board's construction of strongly ionized
`20
` plasma?
`21
` MR. FITZPATRICK: Objection to the
`22
` form, asked and answered.
`23
` THE WITNESS: No, I do not
`24
` disagree with the Board's construction.
`25
`BY MR. LAHAV:
`
`1
` DR. UWE KORTSHAGEN
`2 Q. So help me understand this. Your -- it's
`3
` your opinion that the Board's construction of
`4
` strongly ionized plasma is correct, right?
`5 A. Yes.
`6 Q. And it's your opinion that the Board's
`7
` construction of strongly ionized plasma is a
`8
` relative term, right?
`9 A. That is correct.
`10
`Q. Yet, if I have a plasma with a relatively
`11
` high peak -- with a peak density of ions of
`12
` 5 times 10 to the sixth ions per cubic
`13
` centimeter following a plasma with a peak
`14
` density of ions of 4 times 10 to the sixth
`15
` ions per cubic centimeter, then it's your
`16
` opinion that the plasma with a peak density
`17
` of ions of 5 times 10 to the sixth ions per
`18
` cubic centimeter is not strongly ionized,
`19
` right?
`20
` MR. FITZPATRICK: Objection; form.
`21
` THE WITNESS: Yeah, it is my
`22
` opinion that -- that typically a plasma such
`23
` as this would not be considered strongly
`24
` ionized. In most plasma situations we will
`25
` have a range of densities which is typically
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