`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.
`(TSMC) and SAMSUNG ELECTRONICS, CO. LTD.
`Petitioner
`
`v.
`
`DSS TECHNOLOGY MANAGEMENT, INC.
`Patent Owner
`
`___________________
`
`Patent 5,652,084
`IPR2014-010301
`
`Title: METHOD FOR REDUCED PITCH LITHOGRAPHY
`
`_________________________________________________________
`
`PETITIONERS’ OBJECTIONS TO PATENT OWNER’S
`DEMONSTRATIVES
`
`1 Case IPR2014-01493 has been joined with this proceeding.
`
`
`
`Petitioners’ Objections to Demonstratives
`IPR2014-01030
`
`Pursuant to the Order for Oral Hearing (Paper 25, p. 3), Petitioners
`
`respectfully object to slides 35-40, 45-46, and 48 of the Patent Owner’s
`
`demonstratives proposed for the upcoming oral hearing on August 12, 2015 (Paper
`
`8, Scheduling Order). In the Order for Oral Hearing, the Board has directed the
`
`parties to St. Jude Medical, Cardiology Division, Inc. v. The Board of Regents of
`
`the University of Michigan, IPR2013-00041 (PTAB January 27, 2014) (Paper 65),
`
`for guidance regarding the appropriate content of demonstratives. The present
`
`objections are provided in accordance with the Board’s Order for Oral Hearing and
`
`the guidance from St. Jude.
`
`Slides 35-40, 45-46, and 48 are objected to because they present new
`
`arguments and argumentative characterizations, including previously un-cited
`
`deposition testimony and/or new figures, that have never been previously presented
`
`or discussed in any Paper of record, specifically:
`
`Slides 35 and 40. Petitioners object to slides 35 and 40 because they present
`
`new arguments based on previously un-cited deposition testimony of Patent
`
`Owner’s expert Dr. Mack, regarding alleged differences between shifting a wafer
`
`versus shifting a mask.
`
`Slides 36-39. Petitioners object to slides 36-39 because they present new
`
`arguments based on newly drafted figures (and for slides 37 and 39, previously un-
`
`cited deposition testimony from Dr. Mack’s deposition), regarding alleged
`
`1
`
`
`
`Petitioners’ Objections to Demonstratives
`IPR2014-01030
`
`differences between shifting a wafer versus shifting a mask.
`
`Slide 45. Petitioners object to slide 45 because it presents new
`
`argumentative characterizations based on previously un-cited deposition testimony
`
`from Dr. Mack’s deposition, regarding the teachings of Jinbo.
`
`Slide 46. Petitioners object to slide 46 because it presents new
`
`argumentative characterizations based on previously un-cited deposition testimony
`
`from Dr. Mack’s deposition, regarding the description of the ‘084 patent abstract
`
`and other embodiments described in the specification.
`
`Slides 48 and 50. Petitioners object to slides 48 and 50 because they present
`
`new arguments based on the file history of a patent related to the 084 Patent that
`
`was not previously discussed or argued in any Paper of record.
`
`The Petitioners request that the Board not consider or rely on any arguments
`
`based on slides 35-40, 45-46, and 48, and further that the Board prohibit the Patent
`
`Owner from using these slides, as well as verbally arguing the content thereof, at
`
`the oral hearing on August 12, 2015.
`
`Dated: August 10, 2015
`
`Respectfully submitted,
`
`/David M. O’Dell/
`David M. O’Dell
`Lead Counsel for Petitioner TSMC
`Registration No. 42,044
`
`2
`
`
`
`Petitioners’ Objections to Demonstratives
`IPR2014-01030
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), this is to certify that I caused to be served a true
`
`and correct copy of the foregoing “PETITIONERS’ OBJECTIONS TO PATENT
`
`OWNER’S DEMONSTRATIVES”, as detailed below:
`
`Date of service August 10, 2015
`
`Manner of service Email: andriy.lytvyn@smithhopen.com
`
`anton.hopen@smithhopen.com; IPR@smithhopen.com
`
`christopher.marando@weil.com; brian.ferguson@weil.com;
`
`jason.lang@weil.com
`
`Persons Served Andriy Lytvyn and Anton Hopen
`
`Christopher Marando, Jason Lang, and Brian Ferguson
`
`/David M. O’Dell/
`David M. O’Dell
`Registration No. 42,044
`
`3
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