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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` TAIWAN SEMICONDUCTOR Patent No. 6,805,779
` MANUFACTURING COMPANY, IPR 2014-00828
` LTD., et al., IPR 2014-00829
` IPR 2014-00917
` Petitioners, IPR 2014-01073
` IPR 2014-01076
`
` vs.
`
` ZOND, LLC,
`
` Patent Owner.
`
`-----------------------------------------------------
`
` VIDEOTAPED DEPOSITION OF LARRY D. HARTSOUGH, Ph.D.
` Oakland, California
` Tuesday, April 7, 2015
`
`REPORTED BY:
`TAVIA MANNING, CSR No. 13294, CLR, CCRR, RPR
`JOB NO. 92218
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` TAIWAN SEMICONDUCTOR Patent No. 6,805,779
` MANUFACTURING COMPANY, IPR 2014-00828
` LTD., et al., IPR 2014-00829
` IPR 2014-00917
` Petitioners, IPR 2014-01073
` IPR 2014-01076
`
` vs.
`
` ZOND, LLC,
`
` Patent Owner.
`
`-----------------------------------------------------
`
` VIDEOTAPED DEPOSITION OF LARRY D. HARTSOUGH, Ph.D.
` Oakland, California
` Tuesday, April 7, 2015
`
`REPORTED BY:
`TAVIA MANNING, CSR No. 13294, CLR, CCRR, RPR
`JOB NO. 92218
`
`TSG Reporting - Worldwide 877-702-9580
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` April 7, 2015
` 9:01 A.M.
`
`Page 2
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`Deposition of LARRY D. HARTSOUGH, Ph.D.,
`taken on behalf of Petitioners at 1001
`Broadway, Oakland, California,
`before Tavia Manning, Certified Shorthand
`Reporter No. 13294, Certified LiveNote
`Reporter, California Certified Realtime
`Reporter, Registered Professional Reporter.
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`APPEARANCES:
`
`FOR THE GLOBALFOUNDRIES PETITIONERS:
` WHITE & CASE
` BY: DAVID TENNANT, ESQ.
` BRETT RISMILLER, ESQ.
` NATHAN ZHANG, ESQ.
` 701 Thirteenth Street, NW
` Washington, DC 20005
`
`
`
`
`
`FOR PETITIONER ADVANCED MICRO DEVICES, INC.:
` O'MELVENY & MYERS
` BY: VINCENT ZHOU, ESQ.
` SCOT RIVES, ESQ.
` 400 South Hope Street
` Los Angeles, CA 90071
`
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`APPEARANCES (CONTINUED):
`
`Page 4
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`FOR PETITIONER TOSHIBA (appearing telephonically):
` BAKER BOTTS
` BY: ROBINSON VU, ESQ.
` One Shell Plaza
` 910 Louisiana Street
` Houston, TX 77002
`
`
`FOR THE PATENT OWNER ZOND, LLC:
` ASCENDA LAW GROUP
` BY: TAREK FAHMI, ESQ.
` 333 West San Carlos Street
` San Jose, CA 95110
`
`
`
`Also present: Marza Tozo, Videographer
` ***
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` OAKLAND, CALIFORNIA;
` TUESDAY, APRIL 7, 2015; 9:01 A.M.
`
`Page 5
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` THE VIDEOGRAPHER: Good morning.
` This is the beginning of DVD Number 1 of
`the deposition of Dr. Larry Hartsough in the matter
`of GLOBALFOUNDRIES U.S., Inc., et al., versus Zond,
`LLC, in the United States Patent and Trademark
`Office before the Patent Trial and Appeal Board,
`Cases IPR2014-00828, IPR2014-00829, IPR2014-00917,
`IPR2014-01073, and IPR2014-01076.
` We are located at 1001 Broadway, Oakland,
`California, on Tuesday, April 7th, 2015.
` The time is 9:02 a.m.
` My name is Marza Tozo from TSG Reporting,
`Inc., and I am the legal video specialist.
` The court reporter is Tavia Manning in
`association with TSG Reporting.
` Will counsel please introduce yourself?
` MR. TENNANT: Dave Tennant with White &
`Case. I am counsel for GLOBALFOUNDRIES U.S., Inc.,
`GLOBALFOUNDRIES Dresden Module One LLC & Co. Kg,
`GLOBALFOUNDRIES Dresden Module Two LLC & Co. Kg.
` MR. ZHANG: Nathan Zhang, White & Case LLP,
`also for GLOBALFOUNDRIES.
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` MR. RISMILLER: Brett Rismiller, White &
`Case LLP, also for GLOBALFOUNDRIES.
` MR. ZHOU: Xin-Yu Zhou, from the law firm
`of O'Melveny & Myers, for petitioner Advanced Micro
`Devices, Inc., and I am joined here by my colleague
`Scot Rives from the same firm.
` MR. FAHMI: Tarek Fahmi on behalf of Zond.
` MR. TENNANT: And anybody on the phone,
`please introduce yourself?
` MR. VU: This is Robinson Vu with Baker
`Botts representing Toshiba.
` THE VIDEOGRAPHER: Will the court reporter
`please swear in the witness.
`
` LARRY HARTSOUGH,
` having been first duly sworn in by the reporter,
` testified as follows:
`
` EXAMINATION
`BY MR. TENNANT:
` Q. Good morning.
` A. Good morning.
` Q. State your name for the record, please.
` A. Larry Dowd Hartsough.
` Q. And you understand that I'll be asking you
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`questions today?
` A. Yes.
` Q. And you also understand that you have to
`answer truthfully?
` A. Yes.
` Q. And you will answer my questions fully?
` A. Yes.
` Q. You understand that you have to answer the
`questions I ask of you; correct?
` A. Yes.
` Q. And even if an objection is made, you have
`to answer my questions, unless your counsel objects
`on the basis of privilege and instructs you not to
`answer.
` Do you understand that?
` A. Yes, I do.
` Q. If you don't understand my question, please
`let me know.
` A. I will.
` Q. Okay. If you answer, I will assume you
`have understood my question; is that fair?
` A. Yes.
` Q. Is there anything that could impair your
`ability to answer my questions today?
` A. No.
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` Q. Did you do anything to prepare for today's
`deposition?
` A. Yes.
` Q. And what did you do?
` A. I met with Mr. Fahmi, and I also reviewed
`some of the materials.
` Q. And how long did you meet with Mr. Fahmi?
` A. Probably about five to six hours.
` Q. And you also mentioned you reviewed some
`materials; correct?
` A. Yes.
` Q. What materials did you review?
` A. Mainly the '779 patent, my declaration
`related to that patent, the three main prior art
`documents, and Angelbeck and -- the name starts with
`a P.
` Q. Pinsley?
` A. Yeah.
` Q. Did you review any other materials?
` A. If I did, it was only partially or briefly
`referencing something that I wanted to find out. I
`might have looked at Kortshagen's declaration or
`file history or something like that.
` Q. But that wasn't in the preparation leading
`up to today's deposition?
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` A. Pardon?
` Q. Was that in the --
` A. Just brief reference to look at that --
`look at those.
` Q. And what did you look at in those -- in the
`Kortshagen declaration?
` A. I think it was just a quote.
` Q. Do you recall that quote?
` A. No. Oh, I remember. It was -- somehow the
`quote was referencing a quotation that was
`referencing one of the -- one of the documents that
`wasn't cited as -- necessarily as the grounds for
`these, and so I wondered what was happening there,
`why he quoted that. That's all.
` Q. And what did you conclude?
` A. Pardon?
` Q. Did you conclude anything from your review
`of his declaration?
` A. Did I conclude anything?
` Q. Yes.
` A. Well, yes.
` Q. And what was that conclusion?
` A. That Mr. Kortshagen made some inaccurate
`statements.
` Q. What document was he referring to?
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` A. One of the -- either Angelbeck or -- what's
`that guy's name again?
` Q. Pinsley?
` A. Pinsley. Pinsley. One of those two.
` Q. But you referenced a document that wasn't
`cited necessarily as a ground?
` A. I didn't.
` Q. Kortshagen did?
` A. I was just looking at a quote from
`Kortshagen. That was all.
` Q. And you don't recall the name of that
`document?
` A. It's that Russian paper for flash tube.
` Q. Kudryastev?
` A. That one.
` Q. Okay. Do you recall any other documents
`that you reviewed?
` A. No.
` Q. Did you prepare your -- well -- strike
`that.
` I'm going to hand you what has been
`previously marked as Exhibit 2005. This is the
`patent owner's exhibit.
` Do you recognize this document?
` A. Yes.
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` Q. And refer to the cover page, which is, I
`guess, the second page.
` Do you see on the cover page, it lists
`inter partes review case numbers, and it lists the
`five case numbers that are the subject of today's
`deposition?
` Do you see that?
` A. I guess, yes.
` Q. Did you prepare one declaration for all
`five IPR case numbers?
` A. In my preparation, yes. I wasn't told that
`it was submitted for all five or whatever, but yeah.
` Q. But --
` A. I might have prepared one declaration.
` Q. Okay. And did you write this declaration?
` A. I certainly wrote parts of it, background
`materials and some of the technical issues, yeah.
` Q. What parts did you not write?
` A. I had a hand in reviewing and editing the
`opinions. I obviously have to agree with what my
`opinion is, but the original drafts were not written
`by me.
` Q. Can you identify the sections of this
`declaration that you did not write?
` A. Unfortunately, there's not a table of
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`contents, but...
` Q. Or we could identify, whichever is
`easier -- or can you identify the sections that you
`did write?
` A. For the most part, Sections 1 through -- 1
`through 4.
` Q. And just for confirmation on the record,
`you're testifying that you wrote Sections 1 through
`4; is that correct?
` A. I said for the most part, yeah.
` Q. And so therefore you did not write
`Sections 5 and higher; correct?
` MR. FAHMI: Objection; form.
` THE WITNESS: Well, as I said, I reviewed
`all sections and made edits to them so that they are
`in conformance with my opinions about the claims.
`BY MR. TENNANT:
` Q. And does this declaration constitute your
`entire testimony?
` MR. FAHMI: Objection; form.
` THE WITNESS: It may have -- I may be
`testify -- having testimony that might be a little
`different than the declaration today -- as I sit
`here today, depending on the questions that you ask.
` But when you say "entire testimony," you
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`mean my entire position on this patent?
`BY MR. TENNANT:
` Q. Yes.
` A. Is that what you're asking?
` Q. Yes.
` A. Yeah. Yes.
` Q. And can you refer to paragraph three, which
`is page 2.
` Do you see that?
` A. Yeah.
` Q. It says "the list of materials I
`considered."
` Do you see that?
` A. Yes.
` Q. And it lists various sets of materials, and
`it includes-- I'm just going to read from the
`paragraph:
` "The '779 patent, the file history of the
` '773 patent, the petitions for inter partes
` review and the exhibits, and the PTAB's
` institution decisions, the transcript of
` the deposition of the petitioners' expert
` on the '779 patent, and the prior art
` references discussed below."
` Do you see that?
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` A. Yes.
` Q. You refer to the file history of the '773
`patent.
` Why did you review the '773 patent?
` A. Oh, that is just a typo, isn't it?
` Q. What -- how should that read?
` A. The '779, yeah.
` Q. Okay. And were there any other
`materials -- strike that.
` Did you review any material that is not
`listed here in forming your opinions set forth in
`this declaration?
` A. No.
` Q. And also, all of your opinions in response
`to the material listed here is set forth in this
`declaration; correct?
` A. Could you repeat that question, please?
` Q. So you reviewed the positions by the
`petitioners' expert; correct?
` A. Yes.
` Q. And that includes the transcript of the
`deposition of the petitioners' expert on the '779
`patent; correct?
` A. As I recall, yes.
` Q. And did you form opinions in response to
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`the positions that the petitioners' expert took?
` A. I did.
` Q. And were any of -- did you express all of
`those opinions in this declaration?
` A. I may have formed further opinions based on
`my more recent review, but -- so I'm not -- I'm not
`sure that I explicitly stated them in the
`declaration.
` Q. So what further opinions did you form?
` A. Well, as I said, I may not have stated my
`opinion that I felt that Dr. Kortshagen was making
`an inaccurate statement regarding electron trapping
`for the laser patents. I did state my opinion that
`those patents do not trap electrons, but I did
`not -- may have not stated that I disagreed with
`Dr. Kortshagen's statement.
` Q. Were there any other opinions that you
`formed that are not in this declaration?
` A. I don't recall at this time.
` Q. In forming your opinions, did you conduct
`any type of experiments?
` A. No.
` Q. Did you refer to any background material
`that is not listed in paragraph three of your
`declaration?
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` A. No.
` Q. So would you turn to --
` A. There may be some references in here. I
`mean, some -- I may have referred to some of my own
`knowledge, but I don't recall that I referred to any
`background material for making any statements like
`that.
` Q. And when you say you referred to your own
`knowledge, what do you mean by that statement?
` A. Well, I have been in this -- working in
`this industry for 30 -- over 35 years, so I have a
`fair amount of just knowledge about how things work
`and real devices.
` Q. So based on your impression or thoughts?
` A. On my knowledge.
` Q. Right. Did you refer to any document to
`refresh your recollection?
` A. No.
` Q. Did you refer to any patent to refresh your
`declaration -- refresh -- refresh your recollection?
`Excuse me.
` A. Any patents other than --
` Q. Than are listed here.
` A. -- than are listed here?
` No, not that I recall.
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` Q. Okay. Turn to paragraph 20, please.
` And that is the beginning of section four,
`"Background Topics"?
` A. Right.
` Q. Section -- subsection A is entitled
`"Magnetron Sputtering History and Operation."
` Do you see that?
` A. Correct.
` Q. Earlier you testified that you wrote this
`section; is that correct?
` A. Yes.
` Q. Okay. What is the basis for the
`description in the section?
` And by the way, let me just clarify it for
`the record. The section that I am referring to is
`paragraphs 20 through 31.
` A. I'm sorry. What do you mean by "what is
`the basis"?
` Q. How did you form the opinions that are
`expressed in this section?
` A. Based on my experience.
` Q. And in writing this section, did you refer
`to any materials?
` A. Well, I give references to some materials
`that illustrate some of the developments. But a
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`lot -- a lot of this is based on materials that I
`have previously provided as background materials
`for -- for magnetron sputtering, either a case or a
`tutorial or whatever.
` Q. And you mentioned your experience. I
`believe your experience is listed paragraph four
`through nine; is that correct?
` A. Partially. Of course, my CV is attached,
`but...
` Q. And that's right. And the last paragraph
`says, "a copy of my CV is attached," which also
`references other material; correct?
` A. Correct.
` Q. And so does this accurately capture all of
`your experience in forming the opinions that are
`expressed in paragraphs 20 through 31?
` MR. FAHMI: Objection; form.
` THE WITNESS: It's -- it's just an
`illustration of my experience. It may not capture
`all of the relevant experience. Well, it doesn't
`capture all of the relevant experience.
`BY MR. TENNANT:
` Q. Is there any relevant experience that you
`did not list on your declaration?
` A. In a 30-year career, it would be hard to
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`list all of the --
` Q. Right.
` A. -- all of the experience.
` Q. But based on what you can recall, all of
`your experience is listed in the declaration that's
`relevant?
` A. I doubt it. I mean, I doubt it -- every
`piece of information would be listed here. This
`gives a broad summary of my experience, and it
`really has to do with the breadth of -- the breadth
`of experience, although it's all pretty much related
`to sputtering, although I do have some other areas
`that I mentioned in paragraph seven.
` And, again, a -- you know, a one-sentence
`summary of those other areas is totally inadequate
`to present the depth of the experience in each of
`those areas.
` Q. And what other areas are you referring to?
` A. Pressure control, wafer cooling, wafer
`handling, cryogenic -- this last sentence in
`paragraph seven.
` Q. Can I refer you back to paragraph 20,
`please.
` And beginning in paragraph 20, you say:
` "Since late 1990s, DC magnetron sputtering
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` has become the preferred method for the
` deposition of thin metal films for many
` applications."
` And it goes on. Do you see that?
` MR. FAHMI: Objection; form.
` THE WITNESS: You said "1990s." It's
`1970s.
`BY MR. TENNANT:
` Q. Thank you.
` A. Yes, I see that.
` Q. And what is your experience with DC
`magnetron sputtering?
` A. Well, it does date back to the mid-1970s,
`when I first went to work for Temescal
`Metallurgical, who were holders of one of the
`seminal patents in magnetron sputtering, and I
`worked in their application lab, both on process and
`on developing equipment.
` Q. Did that equipment have magnets?
` A. I'm sorry. Did --
` Q. Did that equipment use magnets?
` A. Oh, yes.
` Q. And what were the magnets used for?
` A. They were used for forming the magnetic
`field that creates the electron trap in a planar
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`magnetron source.
` Q. And so let me refer you to paragraph 22.
` Do you see the second-to-last sentence on
`this page reads:
` "Since most of the voltage drop from anode
` to cathode occurs in this region, the
` electrons arrive from the discharge region
` with more than enough energy to ionize
` neutral gas atoms there."
` Do you see that sentence?
` A. Yes.
` Q. I'm going to focus on the term "discharge
`region."
` Do you see that in the sentence?
` A. Yeah.
` Q. And what does "discharge region" refer to?
` A. In a planar magnetron device, the discharge
`is relatively localized near the dark space, and
`it's confined, to a great degree, to the region
`where the magnetic field is perpendicular to the
`electric field.
` So in this case, in a standard magnetron,
`the discharge region is relatively localized
`compared to a non-magnetron or planar diode
`discharge.
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` Q. And in this discharge region, is this where
`the plasma is formed?
` A. Yes.
` Q. Okay. And in the sentence that I read
`earlier, it references "neutral gas atoms" at the
`end of the sentence.
` Do you see that?
` A. I'm sorry, what sentence were you looking
`at?
` Q. It's a sentence spanning pages 8 and 9.
` A. Oh.
` Yes.
` Q. So is it correct that neutral gas atoms
`will be present in the discharge region as well?
` A. They will be, yes. They can diffuse to
`that region. Because they're not charged, they're
`not affected by electric or magnetic fields.
` Q. And so -- within the discharge region, you
`have the formation of a plasma; you also have
`neutral -- neutral gas atoms there; correct?
` A. That's correct.
` Q. Is there any other species that would be
`present in the discharge region?
` A. Yes.
` Q. What other species would be present?
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` A. There -- there will be some excited gas
`atoms and some -- perhaps some ionized sputtered
`material atoms.
` Q. And would ions be present as well?
` A. I just said "ionized."
` Q. Okay. Sorry if I missed that.
` What is an ion?
` A. An ion is a particle. It can have ionized
`atoms or ionized molecules that -- in which the
`number of electrons doesn't match the number of
`protons. So they can have a deficit of electrons,
`or they can have a surplus of electrons.
` Q. If an ion has a deficit of electrons, what
`happens to the electrons that were ejected from the
`atom?
` MR. FAHMI: Objection; form.
` THE WITNESS: What do you mean what happens
`to them? They're -- they're --
`BY MR. TENNANT:
` Q. Where do they go?
` A. Well, they go where they will be -- they're
`under the same influence as any other electron in
`that region. And so it would be influenced by
`electric and magnetic fields. They may be trapped,
`or they may eventually lose enough energy to reach
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`a -- an electrode or other surface.
` Q. And how are electrons trapped by the
`magnetic electric field -- or magnetic field?
`Excuse me.
` MR. FAHMI: Objection; form.
` THE WITNESS: That's not necessarily an
`easy question to answer because the trapping
`phenomenon depends on examination of all of those
`influences that I mentioned: the proximity to a
`surface, the electric field and the magnetic field
`configuration, and how those interact.
` But in general, the trapping results in a
`motion of the electron that, in essence, impedes it
`as -- impedes it when it has energy; impedes it from
`moving out of that trapped region.
`BY MR. TENNANT:
` Q. So in the presence of a magnetic field,
`isn't it correct that an electron will rotate or
`spiral around the magnetic field lines?
` A. Again, that's one of the motions that an
`electron will have. That may not trap it in the
`sense that I am talking about, but it will have that
`motion.
` Q. And what sense of trap are you talking
`about, then?
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` A. I am talking about -- that if -- when it
`has energy, that its motion keeps it within a region
`that tends to prevent it from going to an electrode
`or other surface.
` Q. And how long would -- strike that.
` Can an electron be trapped forever and
`therefore never contact another surface in the
`presence of a magnetic field?
` A. As I mentioned, the trapping effect depends
`on that electron having some -- some energy and
`response to -- in response to an electric field.
`And as it undergoes collisions, it loses significant
`energy, then that changes.
` But you have to look at the configuration
`that the magnetic and electric fields to determine
`whether the kind of electron trapping that I am
`talking about takes place, and that may --
` Q. If --
` A. -- that may depend on looking at very
`specific -- specific of each situation.
` Q. Assuming that the magnetic field and the
`electric field are perpendicular to one another,
`would that result in trapping an electron?
` MR. FAHMI: Objection; form.
` THE WITNESS: No.
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`BY MR. TENNANT:
` Q. Why not?
` A. Because that alone just imparts a -- exerts
`a force on the electron. And whether that force is
`one that results in a motion that traps the
`electron, again, as I said, depends on the specifics
`of each geometry of the electric and magnetic
`fields.
` Q. Sir, earlier you referred to an electron
`resulting in a collision.
` Do you recall that?
` A. It may, depending on...
` Q. What would an electron collide with?
` A. Other -- other -- an electron would
`typically collide with atoms, whether -- no matter
`what state they're in, or molecules.
` Q. So let's consider a neutral gas atom in a
`collision with an electron.
` What happens to the neutral gas atom after
`the collision with the electron?
` MR. FAHMI: Objection; form.
` THE WITNESS: The answer to that depends a
`lot on the energy of that electron. So it can
`impart -- there can be elastic collisions; there can
`be collisions that cause excitation; there can be
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`collisions that cause ionization. So it just
`depends on what the energy is.
`BY MR. TENNANT:
` Q. And so you referred to excitation.
` So it's possible to excite a gas atom with
`the collision with an electron; correct?
` A. That is correct.
` Q. Have you heard of the term -- strike that.
` Do you understand the term "metastable
`atom"?
` A. To the extent that it's been defined here.
` I am not an atomic physicist, so I can
`understand what it's saying, that the energy level
`is one that is more stable than other states,
`because, in some theory, a -- an event that causes
`it to leave that state is not possible. That's --
`that's my extent of my understanding of it. It has
`a longer lifetime than other states -- other excited
`states.
` Q. When you refer to "longer lifetime," what
`do you mean by that?
` A. Well, I have been given to understand that
`it can be on the order of many seconds.
` Q. And what happens at the end of the life of
`a metastable atom?
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` MR. FAHMI: Objection; form.
` THE WITNESS: Well, it -- it could undergo
`a collision before the end of its life that ionizes
`it, or it could return to a -- to a ground state.
`BY MR. TENNANT:
` Q. A metastable atom is an excited atom;
`correct?
` A. It has a higher energy state, yes.
` Q. And because it has a higher energy state,
`it has a longer lifetime relative to excited atoms
`that are not metastable atoms; correct?
` A. That's my understanding, yes.
` Q. And what is the basis of your
`understanding?
` A. As I said, I'm not an atomic -- not a
`physicist, so the basis of my understanding is
`basically what is presented in the materials that I
`read.
` Q. And what specific materials regarding
`metastable atoms did you read?
` A. Well, the '779 patent talks about it
`briefly.
` Q. Any other materials that you reviewed?
` A. I think I might have, you know, gone to
`Wikipedia just to see, okay, is the '779 description
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`correct? But that's about it.
` Q. And in your review of Wikipedia, did you
`find anything that was inconsistent with what you
`reviewed on the '779 patent?
` A. Not that I recall.
` Q. Did you find any different interpretations
`of a metastable atom when you reviewed Wikipedia?
` A. Again, not that I recall.
` Q. Do you agree with the material that you
`reviewed regarding metastable atoms in particular to
`the '779 patent?
` MR. FAHMI: Objection; form.
` THE WITNESS: I will say that I found no
`reason to disagree with it.
`BY MR. TENNANT:
` Q. And in your experience from designing
`sputtering magnetron systems, did you ever encounter
`or analyze the phenomenon of generating metastable
`atoms?
` A. No. Well, in the sense of not doing it
`purposefully. I mean, did I encounter it? I could
`have, but I wouldn't have recognized -- I wouldn't
`have paid attention to that -- that particular
`phenomenon.
` Q. Is it the case that metastable atoms are
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`always generated when you form a plasma?
` A. That, I couldn't answer for sure.
` Q. Do you have an opinion?
` MR. FAHMI: Objection; form.
` THE WITNESS: I would have to study it.
`BY MR. TENNANT:
` Q. So I just handed you a copy of U.S. Patent
`Number 6,805,779 that has been previously marked as
`Exhibit TSMC 1201.
` Do you recognize this document?
` A. Yes.
` Q. This is the '779 patent that is subject of
`the IPRs in this case; correct?
` A. Yes.
` Q. And just for the record, the '779 patent
`has various exhibit numbers, depending on which IPR
`it was submitted in.
` So for this deposition today, I am just
`going to refer to it as the '779 patent; is that
`fair?
` A. Yes.
` Q. Okay. Can you refer to Figure 1, please?
` A. Okay.
` Q. Now at the bottom of Figure 1, do you see
`the word "prior art"?
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` A. Yes.
` Q. Do you understand Figure 1 to illustrate a
`prior art system?
` A. That's what it says, yes.
` Q. And do you agree with that?
` A. It's -- yes. It's a generalized schematic
`of prior art magnetron -- DC magnetron sputtering.
` Q. Okay. Now refer to Figure 2, please.
` A. Did you say Figure 2?
` Q. Yes.
` Now, this illustrates an embodiment of a
`plasma generator disclosed by the '779 patent;
`correct?
` A. That's correct.
` Q. And if you can just look at the brief
`description of the drawing, column 2, line 3, the
`'779 patent states that:
` "Figure 2 illustrates a cross-sectional
` view of an embodiment of a plasma generator
` that generates a plasma with a multi-step
` ionization process according to the present
` invention."
` Do you see that?
` A. Yes.
` Q. Now, refer back to Figure 1, please.
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` Do you see how the various components of
`the system are labeled with numbers?
` A. Yes.
` Q. And those numbers are 100 and above?
`
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