UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.
`(TSMC) and SAMSUNG ELECTRONICS., LTD
`Petitioner
`
`V.
`
`DSS TECHNOLOGY MANAGEMENT,
`Patent Owner
`
`INC.
`
`Patent 5,652,084
`IPR2014—0103O
`
`Title: METHOD FOR REDUCED PITCH LITHOGRAPHY
`
`ORAL DEPOSITION OF
`
`DR. CHRIS A. MACK
`
`MAY 14, 2015
`
`ORAL DEPOSITION OF DR. CHRIS A. MACK, produced as a
`
`witness at the instance of the Petitioner, and duly
`
`sworn, was taken in the above—styled and numbered cause
`
`on May 14, 2015,
`
`from 9:03 a.m.
`
`to 1:08 p.m., before
`
`Larissa L. McPhearson, CSR in and for the State of
`
`Texas, reported by machine shorthand, at the offices of
`
`Nix, Patterson & Roach, LLP, 5215 North O'Connor
`
`Boulevard, Suite 1900, Irving, Texas 75039, pursuant to
`
`the Federal Rules of Civil Procedure.
`
`TSMC v. DSS
`IPR2014-01030 /TSMC-1017
`
`Page'1of117
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.
`(TSMC) and SAMSUNG ELECTRONICS., LTD
`Petitioner
`
`V.
`
`DSS TECHNOLOGY MANAGEMENT,
`Patent Owner
`
`INC.
`
`Patent 5,652,084
`IPR2014—0103O
`
`Title: METHOD FOR REDUCED PITCH LITHOGRAPHY
`
`ORAL DEPOSITION OF
`
`DR. CHRIS A. MACK
`
`MAY 14, 2015
`
`ORAL DEPOSITION OF DR. CHRIS A. MACK, produced as a
`
`witness at the instance of the Petitioner, and duly
`
`sworn, was taken in the above—styled and numbered cause
`
`on May 14, 2015,
`
`from 9:03 a.m.
`
`to 1:08 p.m., before
`
`Larissa L. McPhearson, CSR in and for the State of
`
`Texas, reported by machine shorthand, at the offices of
`
`Nix, Patterson & Roach, LLP, 5215 North O'Connor
`
`Boulevard, Suite 1900, Irving, Texas 75039, pursuant to
`
`the Federal Rules of Civil Procedure.
`
`TSMC v. DSS
`IPR2014-01030 /TSMC-1017
`
`Page'1of117
`
`
`
`DR. CHRIS A. MACK - May 14, 2015
`
`A P P E A R A N C E S
`
`Page 2
`
`FOR THE PETITIONER, TAIWAN SEMICONDUCTOR MANUFACTURING
`COMPANY, LTD.:
`
`Mr. Scott Cunning
`HAYNES AND BOONE, LLP
`800 17th Street, NW
`Suite 500
`
`20006
`Washington, D.C.
`Phone:
`(202)306-4135
`Fax:
`(202)654-4267
`E-mail:
`scott.cunning@haynesboone.com
`
`—and-
`
`Mr. David M. O'Dell
`
`HAYNES AND BOONE, LLP
`2505 North Plano Road
`Suite 4000
`
`75082
`Richardson, Texas
`Phone:
`(972)739-8635
`Fax:
`(972)692-9118
`E-mail:
`david.odell@haynesboone.com
`
`FOR THE PETITIONER, SAMSUNG ELECTRONICS, LTD.:
`
`Mr. Christopher Marando
`WEIL, GOTSHAL & MANGES LLP
`1300 Eye Street, NW
`Suite 900
`
`20005
`Washington, D.C.
`Phone:
`(202)682-7000
`Fax:
`(202)857-0940
`E—mail:
`christopher.marando@weil.com
`
`FOR THE PATENT OWNER:
`
`Anton J. Hopen
`Andriy Lytvyn
`. Nicholas Pfeifer
`SMITH & HOPEN
`180 Pine Avenue North
`
`34677
`Oldsmar, Florida
`Phone:
`(800)807-3531
`Fax:
`(813)925-8525
`E-mail:
`anton.hopen@smithhopen.com
`andriy.lytvyn@smithhopen.com
`np@smithhopen.com
`
`INC.
`HANNA & HANNA,
`713.840.8484
`
`IPRZO14-01030 / TSMC-1017
`
`Page 2 of 117
`
`
`
`DR. CHRIS A. MACK - May 14, 2015
`
`A P P E A R A N C E S
`
`Page 3
`
`—and—
`
`Mr. Kirk Voss
`
`NIX, PATTERSON & ROACH, LLP
`5215 North O'Connor Boulevard
`Suite 1900
`
`75039
`Irving, Texas
`Phone:
`(972)831-1188
`Fax:
`(972)444-0716
`E—mail:
`kirkvoss@nix1awfirm.com
`
`INC.
`HANNA & HANNA,
`713.840.8484
`
`IPRZO14-01030 / TSMC-1017
`
`Page 3 of 117
`
`
`
`DR. CHRIS A. MACK — May 14, 2015
`
`Page 4
`
`PAGE
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`Appearances .
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`. ..2—3
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`DR. CHRIS A. MACK
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`Examination by Mr. Scott Cunning .
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`Examination by Mr. Andriy Lytvyn .
`Further examination by Mr. Scott Cunning .
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`Signature and Changes .
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`Reporter's Certificate .
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`EXHIBITS
`
`NO.
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`DESCRIPTION
`
`PAGE IDENTIFIED
`
`TSMC—lOl4
`
`United States Patent 5,652,084 .
`
`.
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`. ..23
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`TSMC—lO15
`
`TSMC—lO16
`
`Patent Owner DSS Technology,
`Inc.'s Response to Petition .
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`Claim Construction Memorandum and
`Order .
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`MARKED IN PREVIOUS DEPOSITION,
`
`JUST REFERRED TO:
`
`DSS—2007
`
`Declaration of Dr. Chris A. Mack, Ph.D.l9
`
`TSMC-1004
`
`Patent Application .
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`INC.
`HANNA & HANNA,
`713.840.8484
`
`IPRZO14-01030 I TSMC—1017
`
`Page 4 of 117
`
`
`
`DR. CHRIS A. MACK - May 14, 2015
`
`(On the record at 9:03 a.m.)
`
`DR. CHRIS A. MACK,
`
`Page 5
`
`having been first affirmed,
`
`testified as follows:
`
`BY MR. CUNNING:
`
`EXAMINATION
`
`Q. Good morning, Dr. Mack. Could you state your
`
`full name, please?
`
`A. Chris Allen Mack.
`
`And what is your residence address?
`
`1605 Watchhill Road, Austin, Texas.
`
`And are you currently employed?
`
`I work as a consultant.
`
`Okay. And do you ——
`
`And part—time at the University of Texas at
`
`as adjunct faculty.
`
`Q. Does your consulting business have a name?
`
`A
`
`NO.
`
`Q.
`
`So you just --
`
`A
`
`I sometimes ~~ I apologize for speaking over
`
`your -— any of your question.
`
`I sometimes use the name
`
`lithoguru.com, which is my website address, as my
`
`business name. That's an unofficial name, not an
`
`official name, for my consulting business.
`
`Q. Have you given a deposition before?
`
`A.
`
`I have.
`
`INC.
`HANNA & HANNA,
`713.840.8484
`
`|PR2014—0103O /TSMC—1017
`
`Page 5 of 117'
`
`
`
`DR. CHRIS A. MACK — May 14, 2015
`
`Page 6
`
`Q. Okay. Well, you gave a deposition in a
`
`litigation related to this proceeding, correct?
`
`A. Yes.
`
`Q. Okay. Other than that deposition, have you
`
`been deposed before?
`
`A. Yes.
`
`Q A
`
`Q
`
`How many times?
`
`. Approximately 10 or l2.
`
`Okay.
`
`So you're somewhat familiar with the way
`
`these things work, but I like to kind of go over the
`
`procedures at the beginning to make sure everybody has
`
`that fresh in their mind. Everything that we say is
`
`being taken down by the court reporter,
`
`so for that
`
`reason, it's important to give verbal answers rather
`
`than nods or shakes of the head.
`
`Do you understand
`
`that?
`
`A.
`
`I do.
`
`Q. Okay. And because the court reporter is trying
`
`to take down both my questions and your answers,
`
`I will
`
`try not to begin a question in the middle of your
`
`answer.
`
`If you could try to wait until I finish my
`
`questions before beginning your answers, that'll make it
`
`easier for the court reporter.
`
`Is that fair?
`
`A. Yes.
`
`Q. Okay.
`
`If I ask you a question that you don't
`
`INC.
`HANNA & HANNA,
`713.840.8484
`
`IPRZO14-01030 / TSMC-1017
`
`Page 6 of 117
`
`
`
`DR. CHRIS A. MACK — May 14, 2015
`
`Page 7
`
`understand,
`
`I want to make sure that we understand each
`
`other today,
`
`so if you can let me know,
`
`I will attempt
`
`to clarify the question.
`
`Can you let me know if you
`
`don't understand one of my questions?
`
`A. Yes.
`
`Q. And we'll probably take a break about every
`
`hour, but there's nothing magic to that,
`
`so if you need
`
`a break for any reason, you know, you can just let me
`
`know and I'll accommodate that.
`
`A.
`
`I will.
`
`Q. And the only thing I would ask,
`
`though, if I
`
`have a question that's pending, if you could answer that
`
`question before we take a break.
`
`Can you agree to that?
`
`A. Yes.
`
`Q. Your attorneys may interpose objections to some
`
`of my questions today.
`
`For the most part, that's just
`
`for the record.
`
`If you understand the question,
`
`you're —— you can go ahead and answer the question.
`
`Do
`
`you understand that?
`
`A. Yes.
`
`Q.
`
`Is there any reason that you can't give full
`
`and truthful testimony today, or are you under the
`
`influence of any medications, for instance?
`
`A. No.
`
`Q. And I apologize about that question, but you
`
`INC.
`HANNA & HANNA,
`7l3.840.8484
`
`lPR2014—O103O /TSMC—1017
`
`Page 7 of 117
`
`
`
`DR. CHRIS A. MACK — May 14, 2015
`
`Page 8
`
`never know if someone was in a car accident yesterday.
`
`All right.
`
`Can you briefly describe your
`
`educational background after high school?
`
`A.
`
`I attended Rose—Hulman Institute of Technology
`
`where I received four bachelor's degrees in chemistry,
`
`chemical engineering, physics, and electrical
`
`engineering.
`
`I attended the University of Maryland at
`
`College Park where I received a master's degree in
`
`electrical engineering, and I attended the University of
`
`Texas at Austin where I received a Ph.D.
`
`in chemical
`
`engineering.
`
`Q.
`
`I grew up in Terre Haute,
`
`so I know
`
`Rose—Hulman.
`
`A.
`
`It is a fabulous school.
`
`Q. All right. When did you begin working with
`
`photolithography?
`
`A.
`
`I began in photolithography in 1983.
`
`Q. And what was the circumstances in which you
`
`began working with photolithography?
`
`A.
`
`I was working for the National Security Agency
`
`in Fort Meade, Maryland and NSA has a fab for
`
`manufacturing semiconductor devices and a research
`
`organization to develop next generation processes for
`
`that fab.
`
`I worked in the research organization.
`
`Q. What type of photolithography equipment were
`
`INC.
`HANNA & HANNA,
`7l3.840.8484
`
`|PR2014—O103O / TSMC-1017
`
`Page 8 of 117
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`
`
`DR. CHRIS A. MACK - May 14, 2015
`
`Page 9
`
`you using at the time?
`
`A.
`
`I began using what's called contact printers,
`
`then moved on to the use of step-and—repeat lithography
`
`tools.
`
`Q. And for the transfer of the desired pattern to
`
`the substrate for the contact printer, how does that
`
`work?
`
`A. With the contact printer,
`
`the mask is put in
`
`direct contact with the photoresist covered wafer, or in
`
`a slight variation called proximity printing, a small
`
`gap in the order of tens of microns is maintained
`
`between the mask and the photoresist coated wafer.
`
`Light is shown through the mask to create a shadow of
`
`the mask pattern that then exposes the photoresist.
`
`Q. And for —— is the —~ I'm sorry,
`
`the proximity
`
`printing,
`
`is that a type of contact printing, or is that
`
`a separate type of printing?
`
`A.
`
`They are sometimes considered together because
`
`they use the same -— often use the same tools, but they
`
`are sometimes considered as separate types of pattern --
`
`patterning.
`
`Q. And the step—and—repeat equipment that you
`
`mentioned, how does that work for transferring the
`
`pattern to the imaging layer?
`
`A.
`
`A step-and-repeat system is a type of
`
`INC.
`HANNA & HANNA,
`713.840.8484
`
`|PR2014—01030 / TSMC—1017
`
`Page 9 of 117
`
`
`
`DR. CHRIS A. MACK — May 14, 2015
`
`Page 10
`
`projection optical lithography where a lens is used to
`
`project the image of a mask onto the photoresist coated
`
`wafer.
`
`Q. Are there other types of projection optical
`
`lithography?
`
`A. Yes.
`
`Q. What other types of projection optical
`
`lithography are you familiar with?
`
`A. Well, another style of projection optical
`
`lithography besides the step—and—repeat is the scanner
`
`where —— well, if I could back up and explain what a
`
`step—and—repeat is. That —— all of the projection
`
`optical systems require a method of covering the entire
`
`wafer which cannot be exposed all at one time.
`
`In a
`
`stepper, a small portion of the resist coated wafer is
`
`exposed at one time,
`
`then the wafer is stepped or moved
`
`to a new location and then a repeat of that exposure
`
`happens,
`
`step—and—repeat until the entire wafer is
`
`exposed with multiple copies of the mask.
`
`Another style of projection optical
`
`lithography is the scanner.
`
`In a full wafer scanner,
`
`the mask has an entire wafer's worth of patterns on it,
`
`and then the entire mask and wafer are scanned past the
`
`exposure region so that the entire wafer is exposed by
`
`the entire mask.
`
`INC.
`HANNA & HANNA,
`713.840.8484
`
`IPRZO14-01030 I TSMC-1017
`
`Page 10 of 117
`
`
`
`DR. CHRIS A. MACK — May 14, 2015
`
`The next style of projection optical
`
`Page ll
`
`lithography,
`
`the one that is most commonly used today,
`
`is a hybrid of those two styles called the
`
`step-and—scan. Within one exposure field,
`
`the mask and
`
`the wafer are scanned past a slit which then exposes all
`
`of the mask to that portion of the wafer.
`
`The wafer is
`
`then stepped to a new location and the scanning
`
`operation is repeated.
`
`O. Other than step—and—repeat,
`
`the last one that
`
`you described, would that be called step—and—scan?
`
`A.
`
`Step—and-scan is the common name for the last
`
`one I described.
`
`Q.
`
`Step—and—scan, and then just scanning
`
`projection system. Any other types of projection
`
`optical lithography that you're familiar with?
`
`A. There are a number of what I would call minor
`
`variations or alternate approaches that are not commonly
`
`used. One,
`
`for example,
`
`is called maskless lithography
`
`where we have a pattern that is created in some way
`
`besides the use of a mask. Usually, it's a very small
`
`region which is then scanned in some way on the wafer.
`
`One example would be a very simple approach
`
`of simply having a laser focused down to a small spot.
`
`That spot is scanned in a raster scan approach across an
`
`area, and the beam is turned on and off. This would be
`
`INC.
`HANNA & HANNA,
`713.840.8484
`
`lPR2014—01030 I TSMC-1017
`
`Page 11 of 117
`
`
`
`Page 12
`
`DR. CHRIS A. MACK — May 14, 2015
`
`called a direct write lithography system.
`
`Q. Are there other —— other than direct write, are
`
`there other types of maskless lithography systems?
`
`A. There are —— there is a style which uses
`
`something called a digital multimirror. This is similar
`
`to the digital multimirrors used in the digital light
`
`projectors in movie theaters or home TVs where the
`
`mirrors are basically turned on and off by tilting them
`
`and that creates the pattern.
`
`The mirrors —— the
`
`digital multimirror is illuminated, and an image of that
`
`is then projected onto the wafer.
`
`Q. Are you familiar with other types of maskless
`
`lithography systems?
`
`A. There is —— there are systems that use electron
`
`beam lithography, beams of electrons rather than photons
`
`to ex —— excuse me,
`
`to expose the resist coated wafer.
`
`Besides direct write with the scanning spot,
`
`there is
`
`something called a cell projection.
`
`A small cell, maybe
`
`a —— it is a rectangle or some other primitive pattern
`
`is projected onto the wafer and then more complex
`
`patterns are built up through the use of combinations of
`
`those primitive cells.
`
`Q.
`
`Can you elaborate on that? When you say a
`
`primitive pattern is projected onto the wafer,
`
`is the --
`
`are you projecting, you know, a limited set of features
`
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`713.840.8484
`
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`
`Page12of117
`
`
`
`DR. CHRIS A. MACK - May 14, 2015
`
`Page 13
`
`at a time?
`
`A. Yes.
`
`Q. Okay.
`
`So you would expose to do one portion of
`
`the die and then do a second exposure for a different
`
`portion of the die?
`
`A. Typically, these primitive patterns are very
`
`small and maybe with a fairly simple shape,
`
`for example,
`
`a T pattern or an L pattern or simply a rectangle.
`
`Then
`
`more complicated patterns are decomposed into the small
`
`set of primitive patterns, and then one exposure at a
`
`time,
`
`the more complicated pattern is built up.
`
`Q. Okay. What is the light source, i: it is a
`
`light source, that's used with —— well,
`
`is it a photon?
`
`Is it a light source,
`
`like a traditional optical light
`
`source that's used with cell projection?
`
`A. Typically, it is electron beams.
`
`Q. Any other maskless systems that you're aware
`
`of, maskless lithography systems?
`
`A. There's actually quite a large variety of what
`
`I would call research or —— well, let's just call them
`
`research lithography approaches. One,
`
`for example,
`
`is
`
`called dip—pen lithography.
`
`It is maskless.
`
`It uses
`
`something like an atomic force microscope tip with a
`
`chemically altered tip to chemically alter a substrate.
`
`Q.
`
`Is that used in production?
`
`INC.
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`713.840.8484
`
`IPRZO14-01030 /TSMC-1017
`
`Page 13 of 117
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`
`
`DR. CHRIS A. MACK — May 14, 2015
`
`A. No.
`
`Page l4
`
`Q. Was it used in a research context that the ——
`
`well,
`
`in the 1994 time frame?
`
`A.
`
`I don't believe so, but I'm not familiar with
`
`when dip—pen lithography first began.
`
`Q. What about cell projection,
`
`is that used in
`
`commercial production today?
`
`A.
`
`I believe that it is used in mask manufacturing
`
`which also involves a lithography process, but not
`
`in
`
`commercial wafer production.
`
`Q. Cell projection was available in the 1994 time
`
`frame?
`
`A.
`
`I believe so.
`
`Q. Or how about E—beam lithography,
`
`is —— well,
`
`the E—beam lithography,
`
`the imaging,
`
`is that a version
`
`of direct write?
`
`A. Most of the E—beam lithography approaches are
`
`direct write.
`
`Q.
`
`So rather than using a laser to scan the
`
`pattern into the resist,
`
`the projection equipment is an
`
`E—beam?
`
`A. That's correct.
`
`Q. And how does the —— well, could you refer to
`
`the —— would it be appropriate to call it a projection
`
`apparatus,
`
`the —— that exposes the resist to the E—beam?
`
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`DR. CHRIS A. MACK — May 14, 2015
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`Page l5
`
`A.
`
`In a scanning spot direct write lithography
`
`system, we generally wouldn't refer to the system that
`
`focuses the beam onto the resist coated wafer as a
`
`projection system.
`
`Q. Okay. Well, what would be the term that you
`
`would use to refer to that tool,
`
`the E—beam tool?
`
`A. We would generally call it a direct write
`
`E-beam tool.
`
`Q. Okay.
`
`So how do you program the pattern into
`
`the direct write E—beam tool, if you don't use a mask?
`
`A.
`
`You have what's called a beam blanker that
`
`turns the beam on and off.
`
`The beam blanker is driven
`
`by a database which contains the pattern information.
`
`Q.
`
`So you program the series of instructions to
`
`the database telling the direct write E—beam tool when
`
`to expose and when to turn off the E-beam?
`
`A. That's correct.
`
`Q. And does the direct write E-beam tool, does it
`
`move across the substrate?
`
`A. There are two motions involved. While the
`
`wafer is stationary,
`
`the beam is scanned over a very
`
`small region to expose that small region.
`
`Then the
`
`wafer is stepped to a new location and adjacent to the
`
`previous location, and again,
`
`the beam is scanned over
`
`the small area.
`
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`DR. CHRIS A. MACK — May 14, 2015
`
`Page 16
`
`Q.
`
`So the instructions that you program into the
`
`database that tell the E—beam tool when to turn on and
`
`off also program the E-beam tool how to scan across the
`
`section that's being exposed?
`
`A. Yes.
`
`Q. And how does the —— how do you relay the
`
`patterning information to a digital multimirror
`
`apparatus?
`
`A. Like with a direct write E—beam tool, it begins
`
`with a description of the pattern that's desired to be
`
`printed. Often for both tools,
`
`that database will be in
`
`a file format called a GDS file. That serves as the
`
`information that serves to control or program the
`
`mirrors in the digital multimirror device, but it does
`
`involve some translation of format.
`
`Q. Does the digital multimirror device scan across
`
`a portion of the wafer?
`
`A.
`
`The systems I'm familiar with would not
`
`involve
`
`any scanning.
`
`Q. And what's the radiation source that's used
`
`with the digital multimirror systems?
`
`A.
`
`It would be a light source of some sort.
`
`Q. And do you have direct experience working with
`
`E-beam lithography?
`
`A.
`
`I have limited experience with E—beam
`
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`DR. CHRIS A. MACK — May 14, 2015
`
`Page 17
`
`lithography.
`
`Q. What's your experience working with E-beam
`
`lithography?
`
`A.
`
`I have been involved in contracting to have
`
`masks made by a mask maker who would use an E-beam
`
`lithography tool for that purpose.
`
`I have been involved
`
`in studying the physics of electron beam lithography and
`
`in the development of a lithography simulator to
`
`simulate electron beam lithography.
`
`Q.
`
`I'm sorry, can I —— if we can go back, you say
`
`that you've been involved with consulting to have masks
`
`made that would be used with E-beam?
`
`A.
`
`I didn't say consulting, but in some of my
`
`various jobs, I've required the purchase of photomasks,
`
`and that involved contracting with mask makers and
`
`specifying the types of lithography that would be used
`
`in the manufacture of those masks and understanding
`
`their capabilities and sources of errors.
`
`Q.
`
`So I just want to make sure I understand
`
`because I
`
`thought, based on the earlier conversation,
`
`E-beam was a maskless system,
`
`so is a mask created and
`
`then the programming instructions for that mask are fed
`
`into the machine?
`
`MR. HOPEN: Objection to form.
`
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`Page 17 of 117
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`
`
`DR. CHRIS A. MACK - May 14, 2015
`
`Page l8
`
`Q.
`
`I'll ask it this way, why would you contract
`
`with a mask maker for a photomask when dealing with
`
`E—beam lithography?
`
`A. Let me try to be a little bit more clear.
`
`The
`
`photomask was being used for photolithography, optical
`
`lithography.
`
`The making of the photomask involved the
`
`use of E—beam lithography.
`
`So my experience with E-beam
`
`lithography is mostly involved in the use of E—beam
`
`lithography in the manufacture of masks.
`
`Q.
`
`Do you have any experience with E—beam
`
`lithography in the translation of patterns into
`
`photoresist?
`
`A.
`
`As
`
`I was saying,
`
`the manufacture of a photomask
`
`is a lithography process that involves the use of
`
`E—beams in exposing photoresist.
`
`Q.
`
`Do you have experience using an E—beam
`
`lithography system to pattern a semiconductor device?
`
`A.
`
`I'm very familiar with that technology, but I
`
`don't have direct experience in doing that.
`
`Q. What about the cell projection technology, have
`
`you used cell projection technology to manufacture
`
`semiconductor devices?
`
`A. No.
`
`Q.
`
`The digital multimirror technology, have you
`
`used the digital multimirror technology to manufacture
`
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`
`
`DR. CHRIS A. MACK — May 14, 2015
`
`Page 19
`
`semiconductor devices?
`
`A. No.
`
`Q. And the direct write lithography that you
`
`mentioned,
`
`that would use a laser as a light source,
`
`so
`
`it'd be an optical direct write lithography.
`
`Is that
`
`correct terminology?
`
`A. Yes.
`
`Q. Okay. Have you used optical direct write
`
`lithography to manufacture semiconductor devices?
`
`A.
`
`NO.
`
`Q. Are you familiar with optical direct write
`
`lithography?
`
`A.
`
`I am.
`
`Q.
`
`I'm going to hand you what's previously been
`
`marked as DSS Exhibit 2007. And whenever I hand you a
`
`document today, please feel free to flip through it to
`
`the extent you need to do so to familiarize yourself
`
`with a document.
`
`I may ask a question about a specific
`
`portion, but you should read as much as you need to get
`
`the context for the question.
`
`A. Okay.
`
`Q. Okay. My first question is whether or not you
`
`recognize this?
`
`A. Yes.
`
`Q. And what is DSS 2007?
`
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`Page19of117
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`
`
`DR. CHRIS A. MACK — May 14, 2015
`
`Page 20
`
`'
`
`A.
`
`It's my declaration in this IPR case.
`
`Q.
`
`On the last page of the document, page 11,
`
`there's a signature.
`
`Is that your signature?
`
`Yes.
`
`Did you sign the declaration on March 13th,
`
`Yes.
`
`Did you read the declaration before you signed
`
`Yes.
`
`Did you draft this declaration?
`
`It was drafted in collaboration with the
`
`attorneys I was working with.
`
`Q. Okay. Who were the attorneys that you were
`
`working with?
`
`A. Mostly Andriy and Anton, sitting here.
`
`Q. Did you —~
`
`A. Mostly Andriy.
`
`Q. Did you work with anyone else in preparing this
`
`declaration?
`
`A.
`
`I don't recall.
`
`Q. Other than attorneys, did you work with anyone
`
`else in preparing the declaration?
`
`A. No.
`
`Q.
`
`So you don't have like a research assistant or
`
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`DR. CHRIS A. MACK — May 14, 2015
`
`Page 21
`
`anything --
`
`No.
`
`NO.
`
`that would have had input into this?
`
`If you look at paragraph 16 of your
`
`declaration --
`
`A.
`
`I promise you I've read this, but I've just now
`
`noticed that a couple of paragraphs are out of order in
`
`their numbering, but I --
`
`Q. Ah.
`
`A.
`
`—— I have found paragraph 16.
`
`Q. Yeah.
`
`Do you think paragraph 17 and 18 are
`
`important?
`
`A. And --
`
`Q.
`
`I'm just --
`
`A. Well, all of the paragraphs,
`
`I believe, are
`
`their proper order, but the numbering --
`
`Okay.
`
`—— has been misapplied.
`
`Okay. Well,
`
`the paragraph 16 on page 4.
`
`I see it.
`
`Q. At
`
`the end of the paragraph, you say,
`
`I believe
`
`that a person of ordinary skill in the art would have a
`
`BS degree in engineering or similar field and several
`
`years of experience using photolithography methods for
`
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`
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`Page 22
`
`DR. CHRIS A. MACK — May 14, 2015
`
`semiconductor fabrication.
`
`Do you see that?
`
`A. Yes.
`
`Q. What different methods of semiconductor
`
`fabrication would a person of ordinary skill in the art
`
`have had experience with?
`
`A.
`
`Semiconductor fabrication is by and large
`
`performed using step—and—repeat projection lithography
`
`and step—and—scan projection lithography.
`
`So those are
`
`the methods.
`
`One or both of those methods would be the
`
`methods I'm referring to here.
`
`Q. Would a person of ordinary skill in the art
`
`have experience with E—beam lithography?
`
`A.
`
`A person of ordinary skill in the art would be
`
`familiar with E—beam lithography.
`
`Q. And what about optical direct write
`
`lithography, would a person of ordinary skill in the art
`
`have had experience with optical direct write
`
`lithography?
`
`A. Optical direct write lithography is not
`
`generally used in semiconductor fabrication, so I
`
`believe a person of ordinary skill in the art would be
`
`familiar with that technology, but not necessarily have
`
`direct experience in its use.
`
`Q.
`
`You reviewed the U.S. Patent 5,652,084 in
`
`preparing your declaration?
`
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`
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`DR. CHRIS A. MACK — May 14, 2015
`
`A. Yes.
`
`Page 23
`
`Q.
`
`In your view, does the 084 patent claim methods
`
`of semiconductor fabrication that would include the use
`
`of E—beam direct write lithography?
`
`A.
`
`I don't recall all the specifics —— methods
`
`mentioned in the 084 patent.
`
`Perhaps if I had a copy of
`
`that patent,
`
`I could refresh my memory.
`
`Q.
`
`Just so happens I have copies.
`
`MR. CUNNING: Let's mark this because this
`
`appears to be a copy other than one that was used
`
`previously,
`
`so can we mark this as TSMC—10l4.
`
`(Exhibit TSMC—lOl4 marked.)
`
`Q.
`
`Do you recognize TSMC—lOl4?
`
`A. Yes.
`
`Q. And that is the 084 patent that you considered
`
`in preparing your declaration?
`
`A. Yes.
`
`Q.
`
`So my prior question was whether,
`
`in your view,
`
`the 084 patent claimed methods of semiconductor
`
`fabrication that included the use of E—beam direct write
`
`lithography?
`
`A. Well,
`
`I note that in column 3 in line 45, it
`
`says,
`
`the term "radiation" may include ultraviolet
`
`light, x—ray radiation, electron beam or E—beam
`
`radiation, vacuum radiation, or ion beam radiation,
`
`for
`
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`DR. CHRIS A. MACK — May 14, 2015
`
`Page 24
`
`example.
`
`So it's clear that electron beam is
`
`contemplated, and it does say imaging layer may be
`
`exposed to the first mask using any suitable form of
`
`radiation. That is not direct write,
`
`though,
`
`that
`
`includes a mask. Let me see if I find a reference to
`
`direct write.
`
`Q. Maybe I can help with that.
`
`If you look in
`
`column 12 --
`
`Yes.
`
`—— it would be paragraph —— starting at around
`
`Yes.
`
`Does that mean to you that the 084 patent would
`
`include lithography techniques that are maskless such as
`
`direct write exposure?
`
`MR. HOPEN: Objection to form.
`
`A. Yes.
`
`Q. When —— I want to back up to a sort of
`
`traditional optical lithography technique that exposes a
`
`pattern in the photoresist through a mask.
`
`Can you kind
`
`of describe how that would work from start to finish?
`
`A. Let me describe that in a basic projection
`
`optical lithography --
`
`Q. Okay.
`
`A.
`
`—— system.
`
`Now, when you say describe it from
`
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`DR. CHRIS A. MACK — May 14, 2015
`
`Page 25
`
`start to finish,
`
`there are lots and lots of details.
`
`Q. Okay.
`
`A.
`
`So I don't know to what level of detail you
`
`wish me to explain.
`
`Q. Why don't you give me an overview, and then
`
`I'll ask follow—up questions, as necessary.
`
`A. Okay. We begin with a projection optical tool
`
`that can project an image of a photomask onto a portion
`
`of a resist coated wafer.
`
`The photomask is put or
`
`mounted in the tool, and that photomask has alignment
`
`marks or registration marks that allow the photomask to
`
`be aligned to the optical system.
`
`A wafer that has been previously coated
`
`with a photoresist is also loaded onto a wafer table and
`
`put into the system. That wafer is then aligned either
`
`directly or indirectly to the photomask.
`
`A shutter is
`
`opened which allows light to illuminate the photomask.
`
`Light is transmitted through the clear portions of the
`
`photomask blocked by the opaque portions of the
`
`photomask. And as the light profligates away from the
`
`photomask, it diffracts.
`
`A projection lens, usually a very
`
`complicated and large lens system, collects a portion of
`
`the diffracted light and focuses it down to a plane that
`
`is meant to coincide with the surface of the resist
`
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`
`DR. CHRIS A. MACK — May 14, 2015
`
`Page 26
`
`coated wafer.
`
`On that plane,
`
`that surface, an image of
`
`the photomask is produced. That
`
`image then exposes the
`
`photoresist, causes chemical change in response to the
`
`amount of light that is exposing. At the end of the
`
`exposure,
`
`the allotted exposure time,
`
`the shutter is
`
`closed, and the wafer is removed.
`
`It then undergoes
`
`further processing, for example, development to develop
`
`and form patterns in the photoresist layer.
`
`Q.
`
`In claim 1 of the 084 patent which is
`
`TSMC—lO14 —— do you have that?
`
`Yes.
`
`Column 13.
`
`Yes.
`
`The limitation l(b) when it —— where it states,
`
`patterning the first imaging layer in accordance with
`
`the first pattern to form a first pattern layer having a
`
`first feature -— you see that?
`
`A. Yes.
`
`Q.
`
`Is the process that you just described that
`
`patterning step?
`
`A.
`
`The process I described would fall under that
`
`claim element.
`
`Q. Okay.
`
`It says that the photomask has alignment
`
`marks that allows you to align it with the optical
`
`system. What do you mean by that?
`
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`
`
`DR. CHRIS A. MACK - May 14, 2015
`
`A. There are two major goals in accurate
`
`Page 27
`
`patterning or forming a first pattern, a first pattern
`
`layer,
`
`for example, using the terminology of claim 1.
`
`One is to produce the correct size of the feature or
`
`shape of the pattern, and the second is to position that
`
`pattern in the proper spot on the wafer.
`
`One of
`
`ordinary skill in the art at the time frame of the 084
`
`patent would be well aware that these are the two
`
`criterion that lithographers worry about when assessing
`
`the quality of a lithographic process.
`
`A necessary step in achieving the proper
`
`placement of the pattern on the wafer is the proper
`
`placement 0:
`
`the photomask in the optical projection
`
`tool. That is accomplished by measuring alignment marks
`
`on the reticle after the reticle has been mounted in the
`
`projection optical tool so that a measurement of the
`
`exact position of that reticle in multiple degrees of
`
`freedom can be made.
`
`Q. What is a reticle?
`
`A.
`
`I'm sorry, a reticle is a —— simply another
`
`name for a photomask.
`
`Q.
`
`So other than aligning the mask with the
`
`optical system, are there other types of alignment that
`
`are necessary for a projection photolithography system
`
`to accurately transfer the pattern to the wafer?
`
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`
`
`DR. CHRIS A. MACK - May 14, 2015
`
`Page 28
`
`A. Well,
`
`there are actually quite a large number,
`
`but the most important one that is done every single
`
`time that lithography tool is used is the alignment of
`
`the wafer. This can be done indirectly where the wafer
`
`is aligned to the projection optical system or a
`
`coordinate system associated with the projection optical
`
`system.
`
`In that case, because the reticle has been
`
`properly aligned to the projection optical system and
`
`the wafer is properly aligned to the projection optical
`
`system,
`
`the result is a proper alignment of the wafer to
`
`the reticle. Ultimately,
`
`the wafer can be aligned
`
`directly to the reticle without going through the
`
`intermediate step of the coordinate system of the
`
`projection optical system.
`
`Q.
`
`If you misalign the mask to the optical system,
`
`will you transfer the same pattern to the wafer?
`
`A.
`
`I'm not sure what pattern you're referring to.
`
`Q.
`
`The pattern in the mask.
`
`A.
`
`The pattern on the mask, when you say the same
`
`pattern, you can think of that independent of everything
`
`else and —— all right.
`
`I have to back up.
`
`I apologize.
`
`I think the correct answer is that very much depends on
`
`the situation.
`
`Q. Okay.
`
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`Page 28 of 117
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`
`DR. CHRIS A. MACK — May 14, 2015
`
`Page 29
`
`A.
`
`In a simplest thought experiment, simplest
`
`scenario, you have resist coated wafer that is not at
`
`all influenced by any of the existing patterns on the
`
`wafer projecting an image of that mask into that resist
`
`coated wafer, would then be -— produce patterns in the
`
`resist that were independent of the patterns underneath
`
`it.
`
`This will not always be the case,
`
`though.
`
`Q. Why will it not always be the case?
`
`A. Existing patterns on the wafer often involve
`
`topography,
`
`that is,
`
`the wafer is not perfectly flat
`
`after it has been previously patterned. When coating
`
`photoresist onto this topography wafer,
`
`the coating of
`
`the photoresist will have variations in the thickness of
`
`the photoresist that depend upon the topography on the
`
`wafer.
`
`In some cases,
`
`the variation and the thickness
`
`of the photoresist can be quite extreme with very thin
`
`regions of photoresist on the high parts of the
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