Exhibit 2010
`Exhibit 2010
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`Exhibit 2010
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`Page 1
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` 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
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`Page 2
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`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
`
` ///
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`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
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`INDEX:
`EXAMINATION BY: PAGE
`Mr. Lahav....................................9
`EXHIBITS MARKED FOR IDENTIFICATION:
`Exhibit 2004................................95
`U.S. Patent No. 6,398,929 B1
`No Bates
`PREVIOUSLY MARKED EXHIBITS:
`Exhibit TSMC 1001
`U.S. Patent No. 6,853,142 B2
`No Bates
`Exhibit INTEL 1002
`Kortshagen Declaration - '759 Patent
`No Bates
`Exhibit TSMC 1003
`High-Current Low-Pressure Quasi-Stationary
`Discharge in a Magnetic Field
`Experimental Research
`No Bates
`Exhibit TSMC 1004
`U.S. Patent No. 6,190,512 B1
`No Bates
`Exhibit TSMC 1201
`U.S. Patent No. 7,147,759 B2
`No Bates
`Exhibit TSMC 1202
`Kortshagen Declaration - '142 Patent
`No Bates
`Exhibit TSMC 1204
`Ionization Relaxation in a plasma produced
`by a pulsed inert-gas discharge
`No Bates
`Exhibit TSMC 1205
`U.S. Patent 6,413,382 B1
`No Bates
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`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
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`THE VIDEOTAPED DEPOSITION OF DR. UWE KORTSHAGEN,
`VOLUME I, taken on this 3rd day of December, 2014,
`at The Commons Hotel, 615 Washington Avenue, S.E.,
`Minneapolis, Minnesota, commencing at
`approximately 7:37 a.m.
`
` 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
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` DR. UWE KORTSHAGEN
`Avenue, New York, New York. The court
`reporter is Amy Larson in association
`with TSG Reporting.
` Will counsel please introduce yourselves.
` MR. LAHAV: Etai Lahav of
`Radulescu, LLP, representing the patent owner
`Zond.
` MS. GRANOVSKY: Maria Granovsky,
`Radulescu, LLP, representing Zond.
` MR. GONSALVES: Greg Gonsalves
`representing Zond.
` MR. FITZPATRICK: Anthony
`Fitzpatrick from Duane Morris, LLP,
`representing Taiwan Semiconductor
`Manufacturing Company Limited and TSMC
`North America.
` MR. TENNANT: David Tennant with
`White & Case representing Global Foundries.
` MR. MCCOMBS: David McCombs with
`Haynes & Boone representing TSMC
`North America and Taiwan Semiconductor
`Limited and Fujitsu.
` MR. HUH: Gregory Huh with
`Haynes & Boone representing TSMC and Fujitsu.
`
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` DR. UWE KORTSHAGEN
` MR. RISMILLER: Brett Rismiller
`with White & Case representing Global
`Foundries.
` THE VIDEOGRAPHER: And those on
`the phone, please.
` MR. ZHOU: Yes, this is Xin-Yi
`Zhou. It's spelled X-I-N dash Y-I, and the
`last name is Z-H-O-U, and I represent
` Advanced Micro Devices, Inc.
` MR. HOUSTON: This is
`Michael Houston of Foley & Lardner
`representing Renesas Electronics Corporation
`and Renesas Electronics America, Inc.,
`Renesas being spelled R-E-N-E-S-A-S, for the
`court reporter.
` MR. SILLIMAN: Michael Silliman
`here, last name is S-I-L-L-I-M-A-N, from
`Baker, Botts, LLP, representing Toshiba.
` THE VIDEOGRAPHER: And would the
`court reporter please swear in the witness.
` DR. UWE KORTSHAGEN,
` a witness in the above-entitled action,
` after having been first duly sworn, was
` deposed and says as follows:
`
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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
`
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` DR. UWE KORTSHAGEN
` is K-O-R-T-S-H-A-G-E-N.
`Q. Have you ever given a deposition before?
`A. No.
`Q. Okay. So I'm going to go over some of the
` rules of depositions, okay?
`A. Thank you.
`Q. Do you understand that you've just taken an
` oath to testify truthfully?
`A. Yes.
`Q. And you will testify truthfully today?
`A. Yes.
`Q. You understand that I'm going to be asking
` you questions?
`A. Yes.
`Q. And that you have an obligation to answer my
` questions?
`A. Yes.
`Q. And that even if your counsel objects to my
` questions, you still have to answer them; do
` you understand that?
`A. Yes.
`Q. The one exception to that is if you get
` instructed on attorney work product or
` attorney/client privilege; do you understand?
`
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` DR. UWE KORTSHAGEN
`A. Yes.
`Q. Please allow me to finish my question before
` you answer, okay?
`A. Yes.
`Q. Thank you. If you don't understand a
` question or you would like me to rephrase,
` please ask me to do so, okay?
`A. Yes.
`Q. If I ask a question and you answer it, I'm
` going to assume you understood it. Is that
` fair?
`A. Yes.
`Q. Okay. Please also be careful to give
` audible, verbal answers to my questions, all
` right?
`A. Yes.
`Q. So uh-huhs or nuh-uhs, the court reporter has
` trouble taking those, so it's important to
` give the verbal answers, all right?
`A. Yes.
`Q. Are you taking any medications that might
` impair your ability to testify truthfully
` today?
`A. No.
`
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` DR. UWE KORTSHAGEN
`Q. Is there any other reason why you can't
` testify truthfully today?
`A. No.
`Q. Okay. Where are you currently employed?
`A. At the University of Minnesota.
`Q. And what is your title?
`A. I'm a professor of mechanical engineering.
`Q. In your CV you reference a diploma degree in
` physics in June of 1988, and it's -- how do
` you pronounce the name of the university?
`A. The University of Bochum.
`Q. Bochum?
`A. Bochum.
`Q. Bochum. And is a diploma degree like a
` bachelor's degree in the United States?
`A. It is probably between a bachelor's and a
` master's degree. It is a five-year degree.
`Q. Okay. Did you -- okay. And then you
` obtained a Ph.D. in January of 1991 from the
` same university?
`A. That is correct, yes.
`Q. Did you prepare a dissertation in connection
` with your Ph.D.?
`A. Yes, I did.
`
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` DR. UWE KORTSHAGEN
`Q. What was the topic of that dissertation?
`A. The topic was on electron energy distribution
` functions in radio frequency produced
` plasmas.
`Q. Did you study any particular applications?
`A. I studied a particular method of generating
` plasmas based on so-called propagating
` surface waves.
`Q. And did you -- did you study any particular
` commercial application or application of any
` particular endeavor other than the
` generalized -- generation of plasmas?
`A. No.
`Q. Okay. Did that dissertation entail research
` relating to generation of plasmas inside a
` magnetron?
`A. No.
`Q. Did you study in your dissertation generating
` plasmas for purposes of sputtering?
`A. No.
`Q. After your Ph.D., under education your CV
` lists a, quote, habilitation in experimental
` physics?
`A. That is correct.
`
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` DR. UWE KORTSHAGEN
`Q. What is a habilitation in experimental
` physics?
`A. Habilitation is a specific degree in the
` German academic system which at that time in
` the 1990s was required to become a.
` university professor.
`Q. Does it correlate with post-doc research?
`A. Yeah, you may correlate it with -- with an
` advanced post doc. It also includes writing
` yet another thesis, habilitation, but one is
` already in the position to advise Ph.D.
` students at that point.
`Q. Was there any coursework required --
`A. No, there is no --
`Q. Go ahead.
`A. No, there is no coursework required.
`Q. What was the topic of your thesis for your
` habilitation?
`A. The topic of the thesis was on kinetic theory
` and experiments studying electron
` distribution functions in a wide range of
` plasmas.
`Q. In that, quote, "wide range of plasmas," end
` quote, did that include plasmas used for
`
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` DR. UWE KORTSHAGEN
` sputtering?
`A. Yes.
`Q. Did it include plasmas used for magnetron
` sputtering?
`A. No.
`Q. Can you explain the work you did in
` connection with your habilitation related to
` plasmas used for sputtering?
`A. Among other -- among the different systems
` that I studied at that time was a particular
` plasma system called capacitively coupled
` plasma, and such kinds of plasmas can be used
` for the chemical vapor deposition of films,
` but they can also be used for sputtering.
`Q. And sputtering is not chemical vapor
` deposition, correct?
`A. I would call it more physical vapor
` deposition.
`Q. So sputtering is physical vapor deposition
` and chemical vapor deposition is some other
` process, right?
`A. Could you repeat that question, please?
`Q. Sure. I'm not going to repeat it, I'm going
` to change it.
`
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` DR. UWE KORTSHAGEN
` When -- when people in the art talk about
` chemical vapor deposition, that's something
` different than sputtering, correct?
`A. Generally, I would say this is correct, yes.
`Q. So you said you studied this capacitively?
` coupled plasmas that could be used for
` sputtering. Did you study them in connection
` with their use for sputtering?
`A. I studied them with respect to their -- how
` should I express it -- with respect to the
` properties of electrons within these plasmas,
` in particular, the energy distribution
` function of electrons.
`Q. But you didn't study how to make use of that
` energy distribution function with respect to
` sputtering, correct?
` MR. FITZPATRICK: Objection to the
` form of the question.
` THE WITNESS: I think the correct
` way to answer this is to say that the
` fundamental studies of electron distribution
` functions that I performed also applied to
` situations of sputtering.
`BY MR. LAHAV:
`
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` 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?
`
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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?
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`A. They perform their research under my
` guidance, yes.
`Q. Did they use the magnetron sputtering tools
` under your guidance?
`A. No.
`Q. Under whose guidance did they perform the
` magnetron sputtering?
`A. So because magnetron sputtering as an
` application is a routine technique, my
` students usually get trained by a
` professional staff member at the university,
` and after this training are free to use this
` tool after scheduling its use.
`Q. So the magnetron sputtering that your Ph.D.
` students use is a routine technique, correct?
` MR. FITZPATRICK: Objection to the
` form of the question.
` THE WITNESS: The magnetron
` sputtering that my students use is used for
` routine deposition of films, yes.
`BY MR. LAHAV:
`Q. But even today there is cutting edge --
` cutting-edge research being performed with
` respect to magnetron sputtering, right?
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` MR. FITZPATRICK: Objection to the
` form of the question.
` THE WITNESS: Yes, I believe that
` there is research being performed on
` sputtering, yes.
`BY MR. LAHAV:
`Q. Just not in your group, correct?
`A. That is correct.
`Q. In the several declarations that you've
` submitted in these cases, you've mentioned
` that most of your Ph.D. students go on to
` work on plasmas either in academia or the
` semiconductor industry; is that true?
`A. Yes, that is correct.
`Q. And the Ph.D. students who go on to work in
` the semiconductor industry, do you know if
` their chosen line of work is in magnetron
` sputtering?
`A. I'm sorry, I can't really tell you that
` for -- for all of my students, because once
` students leave my group and enter a company,
` quite often I lose track of what specifically
` they're working on.
`Q. Do you have any recollection of a student
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` 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,
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` DR. UWE KORTSHAGEN
` please.
`Q. Hynix or SK Hynix?
`A. No.
`Q. Global Foundries?
`A. No.
`Q. Fujitsu?
`A. No.
`Q. TSMC?
`A. No.
`Q. Renesas?
`A. No.
`Q. Or Toshiba?
`A. No.
`Q. Do you referee papers for any journals?
`A. I do.
`Q. For which journals?
`A. I'm afraid there are too many journals to
` give you a complete list now.
`Q. Okay. Do you have a selection of the
` journals that you referee papers for most
` often?
`A. I could -- let's -- let's start with some
` plasma-related journals. I'm on the
` editorial advisory board of a journal called
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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.
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` DR. UWE KORTSHAGEN
`BY MR. LAHAV:
`Q. But not for any particular application,
` correct?
`A. No, not typically directed to any particular
` application.
`Q. As is common in academia, there -- is it the
` case that there are publications with your
` name on them that -- where -- where a
` substantial -- where a substantial amount of
` the work was performed by your students?
`A. That is very common, yes.
`Q. And that is true for you as well?
`A. Very much so, yes.
`Q. Okay. When your name goes on a paper do you
` review and edit it?
`A. Yes.
`Q. I've handed you Paper 13 in the 00781
` proceeding. Paper 13 is the Board's decision
` instituting Proceeding 781; do you agree?
`A. I must admit I didn't listen to the case
` number when you just stated it. Do you want
` to restate it so that I can say yes or no?
`Q. Sure. I've handed you Paper 13 in the 781
` proceeding.
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` DR. UWE KORTSHAGEN
`A. Yes.
`Q. Paper 13 is the Board's decision instituting
` Proceeding 781; do you agree?
`A. I agree. Thank you.
`Q. Have you reviewed Paper 13 before?
`A. Yes, I have reviewed this paper.
` MR. FITZPATRICK: Counsel, is this
` going to be an exhibit? Are you going to
` mark this as an exhibit?
` MR. LAHAV: As I did in the last
` depositions if it already has a -- I'm happy
` to mark it. It already has a control number,
` Paper 13, in that proceeding.
` MR. FITZPATRICK: It's your
` deposition.
` MR. LAHAV: Yeah. Okay.
`BY MR. LAHAV:
`Q. Please turn to page 9 of Paper 13.
`A. (Complies.)
`Q. And page 9 begins a section on claim
` construction of weakly ionized plasma and
` strongly ionized plasma, correct?
`A. Yes, that is correct.
`Q. If you turn to page 11, the Board adopted a
`
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` DR. UWE KORTSHAGEN
` construction of weakly ionized plasma as, "A
` plasma with a relatively low peak density of
` ions," correct?
`A. That is correct.
`Q. Do you agree with that construction?
`A. I agree with that construction.
`Q. And the Board adopted a construction of
` strongly ionized plasma as, quote, "A plasma
` with a relatively high peak density of ions,"
` end quote, right?
`A. That is correct.
`Q. And do you agree with that construction?
`A. Yes.
`Q. Is it your understanding that the Board's
` construction of the terms weakly ionized
` plasma and strongly ionized plasma are
` relative terms?
`A. I believe that is what it is, yes.
`Q. And in your analysis and opinions you've
` applied those terms as relative terms,
` correct?
`A. That is correct.
`Q. Does there have to be -- I'll withdraw that.
` Is a plasma with a relatively --
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` DR. UWE KORTSHAGEN
` withdraw. I'll start that again.
` Is a plasma with a peak density of ions
` of 5 times 10 to the sixth a strongly ionized
` plasma if there is a lower -- or if there is
` a weakly ionized plasma of four times ten to
` the sixth? Let me withdraw that. I'm going
` to ask it slightly differently.
` In your opinion, can a plasma with a peak
` density of ions of 5 times 10 to the sixth be
` strong -- a strongly ionized plasma?
`A. Could you be so kind to specify the units
` that you're using?
`Q. I can, if I can remember the correct units.
` I think it's ions per volume, but I can look
` at a -- what is the normal density units
` that's used in the context of plasma
` densities?
`A. Well, it depends.
`Q. Ions per cubic centimeter.
`A. Uh-huh.
`Q. Okay. So let's do this again. In your
` opinion, can a plasma having a relatively
` high peak density -- I'm going to do this for
` 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
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` DR. UWE KORTSHAGEN
` correct.
`Q. How about in a magnetron sputtering chamber?
`A. In a magnetron sputtering chamber I think it
` would be unusual to call a plasma of such a
` density strongly ionized, even though you
` could, if you wanted to, create conditions in
` the magnetron sputtering chamber where a
` plasma of that density could be called
` strongly ionized.
`Q. What is that situation?
`A. It's likely a situation which would not be
` used in any practical application, but you
` could decide to create a plasma in your
` magnetron chamber at extremely low pressure.
`Q. What do you mean by extremely low pressure?
`A. So that the density of your neutral atoms is
` very low.
`Q. What would that density be?
`A. I can't tell you off the top of my head.
` Yeah, I don't know if it would actually
` correspond to any kind of realistic pressure.
`Q. So you're saying that 5 times 10 to the sixth
` ions per cubic centimeter would not be a
` strongly ionized plasma in a magnetron
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` DR. UWE KORTSHAGEN
` sputtering chamber under any conditions?
` MR. FITZPATRICK: Objection to the
` form.
` THE WITNESS: No, I'm not saying
` that. I think -- can you repeat your
` question, please?
` MR. LAHAV: Yes.
`BY MR. LAHAV:
`Q. Is it your opinion that 5 times 10 to the
` sixth ions per cubic centimeter can never be
` considered a strongly ionized plasma in a
` magnetron sputtering chamber under any
` conditions?
` MR. FITZPATRICK: Same objection.
` THE WITNESS: I can't -- I cannot
` agree to -- to the term can never be
` considered, because as I said, if you go to
` very low pressure, unreasonably low pressure,
` and you were to be able to create a plasma of
` such density, then at this very low pressure
` it may be reasonable to call a plasma a
` strongly ionized plasma.
`BY MR. LAHAV:
`Q. Well, pressure, what magnitude of pressure
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` are you thinking of?
`A. Significantly lower than 1 millitorr.
`Q. Can a plasma with a peak ion density of
` 5 times 10 to the sixth ions per cubic?
` centimeter ever be considered a strongly
` ionized plasma under reasonable pressures
` for magnetron sputtering?
` MR. FITZPATRICK: Objection to the
` form.
` THE WITNESS: I think it would be
` unusual to do that.
`BY MR. LAHAV:
`Q. Can a plasma with a peak ion density of
` 5 times 10 to the sixth ions per cubic
` centimeter ever be considered a strongly
` ionized plasma under reasonable pressures for
` magnetron sputtering?
` MR. FITZPATRICK: Objection to the
` form.
` THE WITNESS: I think it would be
` highly unusual to do that, but because we are
` defining strongly and weakly ionized plasma
` in relative terms here, it would also depend
` on what we -- what we are comparing it with.
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`BY MR. LAHAV:
`Q. So if there were a; plasma existing in a?
` magnetron sputtering chamber a microsecond
` earlier which had a peak density of ions of
` 4 times 10 to the sixth ions per cubic
` centimeter, then the plasma which has a
` peak ion density of 5 times 10 to the sixth
` ions per cubic centimeter would be considered
` a strongly ionized plasma, correct?
` MR. FITZPATRICK: Objection to the
` form.
` THE WITNESS: I think it would be
` highly unusual to define it as such.
`BY MR. LAHAV:
`Q. Would you?
`A. I would not.
`Q. Okay. So does that mean you disagree with
` the Board's construction of strongly ionized
` plasma?
` MR. FITZPATRICK: Objection to the
` form, asked and answered.
` THE WITNESS: No, I do not
` disagree with the Board's construction.
`BY MR. LAHAV:
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