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`Inter Partes Review of US. 5,652,084
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.
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`(TSMC),
`Petitioner
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`V.
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`DSS TECHNOLOGY MANAGEMENT, INC.
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`Patent Owner
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`Patent 5,652,084
`IPR2014-01030
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`Title: METHOD FOR REDUCED PITCH LITHOGRAPHY
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`AFFIDAVIT OF ERICK HASEGAWA
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`_1_
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`TSMC-1012
`TSMc-1012
`TSMC v. DSS, IPR2014-01030
`TSMC v. DSS, IPR2014-01030
`1 of 2
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`I, Erick Hasegawa, do hereby declare:
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`1.
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`I am an attorney with the law firm of Haynes and Boone, LLP. 1 am
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`proficient in both Japanese and English. 1 have reviewed the documents submitted
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`as Exhibits TSMC—1004 and TSMC—l 011 in IPR2014—01030. Exhibit TSMC— l 011
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`refers to the original, Japanese language version of JP04071222A (“Jinbo”);
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`Exhibit TSMC~1004 refers to an English translation of Jinbo.
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`2.
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`It is my belief that Exhibit TSMC-1004 is, to the best of my
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`knowledge, a true and accurate translation of the original, Japanese language
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`version of Jinbo provided in TSMC-lOl l.
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`3.
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`I declare that all statements made herein on my own knowledge are
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`true and that all statements made oninformatiOn and belief are believed to be true,
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`and further, that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 or Title 18 of the United States Code.
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`FP/bt‘mhq 2: 20“).
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`4g;‘1
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`Date
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`Erick Hasegawa
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`*2_
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`TSMC-1012
`TSMc-1 012
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`2 of 2
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