`
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________________________
`
`GLOBALFOUNDRIES U.S., INC., GLOBALFOUNDRIES DRESDEN
`MODULE ONE LLC & CO. KG, GLOBALFOUNDRIES DRESDEN
`MODULE TWO LLC & CO. KG, and
`THE GILLETTE COMPANY,
`Petitioners,
`
`
`
`v.
`
`Zond, LLC.
`U.S. Patent No. 6,853,142
`IPR Case No. IPR2014-010981
`
`
`
`PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION FOR
`OBSERVATION ON CROSS-EXAMINATION OF
`PETITIONER’S REPLY WITNESS
`
`
`1 Case No. IPR2014-01016 has been joined with this proceeding.
`
`
`
`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`
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`TABLE OF CONTENTS
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`INTRODUCTION ........................................................................................... 1
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`RESPONSES TO OBSERVATIONS ON DR. OVERZET’S
`TESTIMONY .................................................................................................. 1
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`A.
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`B.
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`C.
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`D.
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`E.
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`F.
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`G.
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`H.
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`Response to Observation 1 .................................................................... 1
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`Response to Observation 2 .................................................................... 3
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`Response to Observation 3 .................................................................... 5
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`Response to Observation 4 .................................................................... 6
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`Response to Observation 5 .................................................................... 7
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`Response to Observation 6 .................................................................. 10
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`Response to Observation 7 .................................................................. 11
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`Response to Observation 8 .................................................................. 13
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`
`
`i
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`
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`I.
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`II.
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`INTRODUCTION
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`I.
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`Petitioner submits this response to Patent Owner Zond’s Observations on
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`Cross-Examination of Dr. Overzet, Paper No. 30 (“Observation”). Patent Owner
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`presents eight observations on Dr. Overzet’s testimony. While Petitioner believes
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`that the testimony will be appropriately viewed and weighed by the Board, the
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`specific observations presented by Patent Owner are irrelevant and mischaracterize
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`the testimony of Dr. Overzet, as specified below, and therefore are not probative of
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`any material issue before the Board.
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`II. RESPONSES TO OBSERVATIONS ON DR. OVERZET’S
`TESTIMONY
`A. Response to Observation 1
`Patent Owner contends that Dr. Overzet’s testimony indicates that his field
`
`of expertise is inadequate to support Petitioner’s positions with respect to “gas
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`laser references” such as Kudryavtsev. Observation at 2. As a threshold matter,
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`Patent Owner’s observation is based on deposition testimony of Dr. Overzet taken
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`by Patent Owner regarding U.S. Patent No. 7,147,759 in different IPR
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`proceedings. Patent Owner is permitted to submit its motion for observations in
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`those proceedings, not the instant ones.
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`Notwithstanding its threshold irrelevance, the cited testimony merely
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`indicates that Dr. Overzet is not an expert in all aspects of “gas laser design.”
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`Deposition of Dr. Overzet re U.S. Patent No. 7,147,759 (“’759 Depo. Tr.”) at
`1
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`107:6-8 (IPR2014-00781 Ex. 2012). On the other hand, Dr. Overzet testified that
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`“I am an expert in the generation of plasma; furthermore all of the articles that
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`we've gone through with respect to the '759 patent involve the generation of
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`plasma.” Id. at 109:14-18 (IPR2014-00781 Ex. 2012). In other words, Dr. Overzet
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`is an expert in the relevant field for the patent at issue and he applies his expert
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`opinion when concluding that it would be obvious to combine references that
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`pertain to plasma generation such as Kudryavtsev. See IPR2014-00781 Overzet
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`Dec. at ¶¶ 55-59 (Ex. 1240).
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`Finally, Patent Owner’s characterization of Kudryavtsev as a reference
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`“directed to gas lasers” is an incorrect conclusion contrived only to attack Dr.
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`Overzet’s qualification as an expert purporting to testify about “gas laser design.”
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`Observation at 2; ’759 Depo. Tr. at 107:6-8 (IPR2014-00781 Ex. 2012).
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`Kudryavtsev explicitly states that its model emerges from “the study of ionization
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`relaxation in a plasma when the external electric field suddenly increases” and that
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`the model is applicable “whenever a field is suddenly applied to a weakly ionized
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`gas.”2 Kudryavtsev at p. 30, left col., ¶ 1; p. 34, right col. final ¶ (IPR2014-00819
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`Ex. 1204). Thus, Kudryavtsev is directed to ionization relaxation mechanics which
`
`
`2 The general applicability of Kudryavtsev includes gas lasers, but is not limited to
`them. Kudryavtsev at p. 34, right col., last ¶ (“[The modeled effects] must be
`allowed for when studying emission mechanisms in pulsed gas lasers, gas
`breakdown, laser sparks, etc.”) (IPR2014-00819 Ex. 1204).
`2
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`falls within Dr. Overzet’s plasma generation expertise. As a result, Zond’s limiting
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`Kudryavtsev to application to gas lasers is an unsupported conclusion which is
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`irrelevant to this proceeding.
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`B. Response to Observation 2
`Patent Owner contends that Dr. Overzet’s testimony indicates that “the flow
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`of gas [in Wang] is far from the strongly-ionized plasma at the upper end of the
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`chamber” which supports Patent Owner’s argument that the gas does not diffuse
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`the strongly-ionized plasma to the extent that it allows additional power to be
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`absorbed. Observation at 3. Patent Owner’s observation draws a self-serving
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`conclusion that has no support from the cited testimony.
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`The excerpt cited by Patent Owner merely shows that Dr. Overzet agrees
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`with counsel for Patent Owner that: (1) gas enters Wang’ system at the lower right,
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`(2) Wang’s system includes a vacuum system and a pumping port, and (3) the
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`vacuum system pumps gas out of Wang’s chamber at the pumping port location.
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`Deposition Transcript of Dr. Overzet re U.S. Patent No. 6,853,142 (“’142 Depo.
`
`Tr.”) at 6:5-7:5 (Ex. 2012).
`
`Nowhere in the cited testimony does Dr. Overzet opine on what the feed gas
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`does after it is introduced in Wang’s system and before it is pumped out by the
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`vacuum system. Despite this, Patent Owner concludes that the testimony indicates
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`that the feed gas flow is far from the strongly-ionized plasma. Observation at 3. In
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`3
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`fact, immediately following the excerpt cited by Patent Owner, Dr. Overzet
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`discussed the nature of the feed gas flow in Wang’s chamber, indicating that the
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`feed gas flows from the inlet in the lower right portion of Wang’s chamber, then
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`flows between the pedestal and the grounded shield into the main volume of
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`Wang’s chamber, and then eventually reaches the pumping port in the lower left:
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`Q. All right. So in the three-dimensional device that is
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`represented in this two-dimensional figure, is there a path around the -
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`- the bottom portion of the pedestal for the gas to flow?
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`A. There a gap is shown between the pedestal 18 and the item
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`24 and 36, in which I expect gas can flow and fill.
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`Q. Does the gas that enters the chamber in Figure 1 of Wang
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`move toward the pumping part -- pumping port identified by item
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`number 40?
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`A. I'm sorry, I was looking at something else and I missed the
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`detail of your question. Would you please repeat it for me?
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`Q. Sure, no problem. Does the gas that enters the chamber of
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`Figure 1 of Wang move toward the pumping port identified by item
`
`number 40?
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`MR. TENNANT: Objection, form.
`
`A. Eventually.
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`4
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`’142 Depo. Tr. at 7:24-8:20 (Ex. 2012) (emphasis added). Patent Owner
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`conveniently omits this testimony which addresses the flow path of the feed gas.
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`As a result, Patent Owner’s observation is nothing more than a baseless conclusion
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`which provides no insight on patentability and is irrelevant to the proceeding.
`
`C. Response to Observation 3
`Patent Owner contends that Dr. Overzet’s testimony shows that “the ’142
`
`patent disclosed a pre-ionizing filament electrode that is separate and distinct from
`
`the cathode and anode.” Observation at 4. Patent Owner concludes that Dr.
`
`Overzet’s testimony supports Patent Owner’s contention that “the electrode recited
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`in certain dependent claims of the ’142 patent (e.g., claim 29) is separate and
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`distinct from the cathode and anode recited in the claims from which they depend
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`(e.g., claim 21).” Id. Again, Patent Owner draws a self-serving conclusion that
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`has no support from the cited testimony.
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`In the cited testimony, Patent Owner questioned Dr. Overzet regarding
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`Figure 6A and whether the ’142 Patent identifies a pre-ionizing filament electrode
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`separate from the cathode and anode. ’142 Depo. Tr. at 28:20-29:9 (Ex. 2012).
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`Based on this, and nothing more, Patent Owner concludes that Dr. Overzet’s mere
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`confirmation that the elements are present in Figure 6A supports its position that
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`dependent claims reciting electrodes claim an electrode that is separate from the
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`5
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`claimed cathode and anode. 3 Observation at 4. Patent Owner never questioned
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`Dr. Overzet in the context of the claim language. As a result, Zond’s conclusion is
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`incorrect and irrelevant to this proceeding.
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`D. Response to Observation 4
`Patent Owner contends that Dr. Overzet’s testimony shows that “Wang’s
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`device includes a floating shield and dielectric between its anode and cathode”
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`which supports its position that Wang differs from the claims of the ’142 patent
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`which recite a structure in which a cathode is positioned adjacent to the anode with
`
`a gap there between. Observation at 6. Yet again, Patent Owner’s observation
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`draws a self-serving conclusion that has no support from the cited testimony.
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`The excerpt cited by Patent Owner merely shows that Dr. Overzet agrees
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`with Patent Owner that Wang discloses: (1) a grounded shield that protects the
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`chamber walls and acts as a grounded anode, (2) a cathode at the top of the
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`chamber that also acts as a sputtering target, and (3) a floating shield supported by
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`a dielectric isolator that becomes negatively-charged in the presence of a high-
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`density plasma and focuses sputtered ions toward the wafer. ’142 Depo. Tr. at
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`24:17-27:4 (Ex. 2012). Patent Owner never asked Dr. Overzet about the
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`orientation of the cathode, anode, and floating shield relative to one another.
`
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`3 Patent Owner’s conclusion is an example of importing a claim limitation from an
`embodiment disclosed in the specification which is manifestly inappropriate.
`6
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`Rather, Patent Owner cites to Dr. Overzet’s mere confirmation that these
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`components are disclosed by Wang and baselessly concludes that Wang’s floating
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`shield and dielectric are disposed between the anode and cathode in contravention
`
`of the claims of the ’142 patent. Observation at 6. Dr. Overzet’s testimony is
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`consistent with his expressed conclusion that Wang discloses the claimed anode
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`and cathode positioned adjacent to the anode forming a gap there between.
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`Overzet Declaration at ¶¶ 121-122 (Ex. 1422). As a result, Zond’s unilateral
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`conclusion in the absence of support from the cited testimony is unhelpful in
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`deciding patentability and irrelevant to this proceeding.
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`E. Response to Observation 5
`Observation 5 cites a small portion of Dr. Overzet’s testimony relating to the
`
`power supply utilized in Lantsman and concludes that “Lantsman’s device applies
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`a very different type of power than the pulses applied by Wang and Mozgrin.”
`
`Observation at 9. More specifically, Patent Owner claims that the difference
`
`between Lantsman’s device and the devices of Wang and Mozgrin preclude
`
`combination without any objective evidence showing how one of ordinary skill in
`
`the art what have achieved the claimed invention by combining them. Id. Patent
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`Owner’s argument mischaracterizes Dr. Overzet’s testimony about combining
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`references and is irrelevant to the grounds instituted in this proceeding.
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`First, the testimony cited by Patent Owner refers only to isolated questions
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`7
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`regarding the physical apparatus disclosed in Lantsman and ignores the fact that
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`Dr. Overzet’s answers were not given in the context of combining Lantsman with
`
`any other reference. Immediately following the excerpt cited by Patent Owner, Dr.
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`Overzet states that Lantsman discloses a single power supply unit that comprises
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`two power supply sections – a primary and secondary DC power supply – which
`
`corresponds to Wang’s two-stage plasma system:
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`Q. Okay. Does Lantsman disclose a value for the ion density of
`
`its plasma?
`
`A. Interesting. So in -- as part of my reading for answering this
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`question, I note that in column 2, line 42 relating to a prior question,
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`Lantsman writes: "In brief summary, this technique is implemented
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`by a power supply circuit comprising two power supply sections: an
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`essentially conventional primary power supply which provides the
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`primary power to electrically drive the cathode during the plasma
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`process, and a secondary power supply which supplies an initial
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`plasma ignition voltage sufficiently in excess of the oscillation
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`threshold voltage," and by using the word "two power supply
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`sections," he implies that it could be part of one power supply
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`system. Let me just -- got it. Got it. Lantsman describes -- this is, in
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`fact, discussed in my declaration in paragraph 69 -- actually starting
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`8
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`earlier in paragraph 66 and following. Looking in the middle of that
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`paragraph 69, both Lantsman and Wang teach two-stage plasma
`
`systems. Lantsman teaches a limited or a first plasma stage that he
`
`also calls preionizing, and a second stage that he calls substantial in
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`that the sputtering current has become substantial with the primary
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`power supply.
`
`’142 Depo. Tr. at 32:14-33:19 (Ex. 2012). Patent Owner’s observation attempts to
`
`twist Dr. Overzet’s testimony regarding the physical apparatus of Lantsman by
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`groundlessly concluding that a person of ordinary skill in the art would not
`
`combine the references despite the fact that Dr. Overzet never testified as such.
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`Secondly, Patent Owner’s reliance on the physical differences between
`
`Lantsman and either Wang or Mozgrin is irrelevant as the Board considered this
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`argument when Patent Owner initially made it in its Preliminary Response and
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`instituted inter partes review because “a determination of obviousness based on
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`teachings from multiple references does not require an actual, physical substitution
`
`of elements.” See, e.g., IPR2014-00818 Institution Decision at 14 (Paper No. 9);
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`see also IPR2014-00818 Patent Owner Preliminary Response at 32-34, 36 (Paper
`
`No. 8). Because of this, the instant proceeding is instituted on the ground that a
`
`person of ordinary skill in the art would combine the teaching of Lantsman to
`
`either Wang or Mozgrin such that Patent Owner’s observation regarding physical
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`9
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`differences between the apparatuses of Lantsman, Wang, or Mozgrin is irrelevant.
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`F. Response to Observation 6
`Patent Owner contends that Dr. Overzet’s testimony indicates that Figure 5
`
`of Kudryavtsev is “applicable only to devices that have a radius” such that it could
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`not predictably be combined with Wang or Mozgrin which do not have a radius.
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`Observation at 9-10. Similar to Observation 1, Patent Owner’s observation is
`
`based on deposition testimony of Dr. Overzet taken by Patent Owner regarding
`
`U.S. Patent No. 7,147,759 in different IPR proceedings.
`
`Notwithstanding the threshold irrelevance of the excerpt, Patent Owner’s
`
`argument is misplaced because it mischaracterizes Dr. Overzet’s testimony about
`
`combining Kudryavtsev with Wang or Mozgrin. Immediately following the cited
`
`testimony, Dr. Overzet testified that that Kudryavtsev’s model has wide
`
`applicability to systems other than Kudryavtsev’s particular cylindrical apparatus,
`
`including those that do not have a radius:
`
`A. Since Kudryavtsev has a model that is widely applicable, he
`
`could, and one of ordinary skill in the art -- let me rephrase that. He
`
`could choose to apply his model in various volumes. His model
`
`would not simply be limited to things having a simple radius,
`
`cylindrical or spherical.
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`Q. But my question was with respect to Figure 5.
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`10
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`A. Figure 5 discloses one kind of an environment that has a
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`radius.
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`Q. So Figure 5 would be limited to only those types of shapes
`
`that have a radius; is that correct?
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`MR. TENNANT: Objection, form. Asked and answered.
`
`A. My understanding is that Figure 5 would be most readily
`
`applied to that kind of a system, but still could have application
`
`outside.
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`’759 Depo. Tr. at 29:19 – 30:15 (IPR2014-00781 Ex. 2012) (emphasis
`
`added).
`
`When Dr. Overzet’s testimony is considered in its full context, Patent
`
`Owner’s observation is incorrect and ultimately irrelevant to Dr. Overzet’s opinion
`
`– both expressed in his declaration and confirmed in his deposition – that a person
`
`of ordinary skill in the art would be motivated to combine Kudryavtsev’s teaching
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`with the systems disclosed in Wang or Mozgrin.
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`G. Response to Observation 7
`Observation 7 cites to selected portions of Dr. Overzet’s testimony relating
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`to differences between Wang and Kudryavtsev and concludes that “there is no
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`objective evidence tending to establish that the teachings of the very different
`
`devices of Wang and Kudryavtsev would have led to predictable results.”
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`11
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`Petitioner’s Response to Patent Owner’s Motion for Observation
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`Observation at 11. Similar to previous observations, Patent Owner’s observation is
`
`based on deposition testimony of Dr. Overzet taken by Patent Owner regarding
`
`U.S. Patent No. 7,147,759 in different IPR proceedings.
`
`Notwithstanding the threshold irrelevance of the excerpt, Patent Owner’s
`
`argument is misplaced because it mischaracterizes Dr. Overzet’s testimony about
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`combining Wang and Kudryavtsev and is irrelevant to the instituted grounds .
`
`First, the testimony cited by Patent Owner refers only to isolated questions
`
`regarding the physical apparatus used by Kudryavtsev and Wang and ignores the
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`fact that Dr. Overzet’s answers were not in the context of combining the two
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`references. In fact, during his deposition, Dr. Overzet explained in detail how his
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`declaration shows that a person of ordinary skill in the art would be motivated to
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`apply the teachings of Kudryavtsev to the system of Wang:
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`In short, Kudryavtsev is useful for describing how a voltage
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`pulse such as Wang's voltage pulse operates and how to adjust
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`voltage amplitude and duration in order to increase the ionization rate
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`so that a rapid increase in electron density and the formation of a
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`strongly-ionized plasma occurs for the benefit of improved sputtering
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`and manufacturing processing capabilities.
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`Beginning, again, in paragraph 57, bottom of page 29:
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`"Moreover, a person of ordinary skill in the art would understand that
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`12
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`Kudryavtsev intended that its derived model can be applied over a
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`range of pressures as evidenced by Figure 3 of Kudryavtsev, which
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`accurately models the duration of the slow growth stage tau sub s for
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`argon discharges."
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`’759 Depo. Tr. at 39:4-21 (IPR2014-00781Ex. 2012) (emphasis added). Patent
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`Owner’s observation attempts to twist Dr. Overzet’s testimony regarding the
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`physical apparatuses of Wang and Kudryavtsev by unilaterally concluding that a
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`person of ordinary skill in the art would not combine the references despite the fact
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`that Dr. Overzet never testified as such.
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`
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`Secondly, similar to Observation 5, Patent Owner’s reliance on the physical
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`differences between Wang and Kudryavtsev is irrelevant as the Board has already
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`denied Patent Owner’s physical substitution argument when instituting inter partes
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`review. See, e.g., IPR2014-00819 Institution Decision at 15 (Paper No. 9); see
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`also IPR2014-00819 Patent Owner Preliminary Response at 30-35 (Paper No. 8).
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`Thus, the instant proceeding is instituted on the ground that a person of ordinary
`
`skill in the art would combine the teaching of Kudryavtsev to Wang irrespective of
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`any physical differences between the references such that Patent Owner’s
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`observation is irrelevant.
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`H. Response to Observation 8
`Patent Owner contends that Dr. Overzet’s testimony demonstrates that the
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`13
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`“density of the plasma is shown in Kudryavtsev to decrease away from the axis of
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`the cylinder” which differs from the claims of the ’142 Patent which require a
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`plasma density to be “substantially uniform proximate to the sputtering target.”
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`Observation at 14. Similar to previous observations, Patent Owner’s observation is
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`based on deposition testimony of Dr. Overzet taken by Patent Owner regarding
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`U.S. Patent No. 7,147,759 in different IPR proceedings.
`
`Notwithstanding the threshold irrelevance of the excerpt, Patent Owner
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`incorrectly reads the claims of the ’142 Patent and distorts Dr. Overzet’s testimony
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`to support its erroneous construction. First, nowhere in its claims does the ’142
`
`Patent require the strongly-ionized plasma to be “substantially uniform proximate
`
`to the sputtering target” as Patent Owner states in its observation. Observation at
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`14. The only similar language in the ’142 Patent is in claims 15, 27, and 38 which
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`requires that the strongly-ionized plasma be substantially uniform proximate to, if
`
`anything, the cathode. ’142 Patent at 15:41-44, 22:21-24, 23:2-3 (Ex. 1401).
`
`Secondly, the testimony cited by Patent Owner merely indicates that the
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`plasma density in Figure 5 of Kudryavtsev is larger in the center than at some
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`value away from the center. Observation at 14-15. Patent Owner fails to consider
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`the claim language calling for the plasma to be “substantially uniform.” ’142
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`Patent at 15:41-44, 22:21-24, 23:2-3 (Ex. 1401) (emphasis added). Indeed, right
`
`after the testimony cited by Patent Owner, Dr. Overzet testified that Kudryavtsev
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`14
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`meets the “substantially uniform” limitation:
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`Q. Figure 5 shows that the plasma density is not uniform;
`
`correct?
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`MR. TENNANT: Objection, form, relevance.
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`A. One of ordinary skill in the art would always understand that
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`plasmas, when incoming close to any kind of a surface, will decrease
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`in plasma density. So the uniformity would never be considered from
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`0 to 1 in that fashion, as the question has examined it. Therefore, one
`
`of ordinary skill in the art would understand this plasma to be
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`relatively uniform.
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`’142 Depo. Tr. at 35:23 – 36:7 (IPR2014-00781 Ex. 2012). When Dr. Overzet’s
`
`testimony is considered in its full context, Patent Owner’s observation is incorrect
`
`and ultimately irrelevant to Dr. Overzet’s opinion – both expressed in his
`
`declaration and confirmed in his deposition – that a person of ordinary skill in the
`
`art would understand that Kudryavtsev discloses a substantially uniform plasma.
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`Dated: May 29, 2015
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`15
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`Respectfully Submitted,
`
`
`
`/s/ David M. Tennant
`David M. Tennant
`Lead Counsel for Petitioner
`GlobalFoundries
`Registration No. 48,362
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`Trial No. IPR2014-01098
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`CERTIFICATE OF SERVICE
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`
`
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`Pursuant to 37 C.F.R. § 42.6(e), this is to certify that I caused to be served a
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`true and correct copy of the foregoing “PETITIONER’S RESPONSE TO
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`PATENT OWNER’S MOTION FOR OBSERVATION ON CROSS-
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`EXAMINATION OF PETITIONER’S REPLY WITNESS” as detailed below:
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`
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`Date of service May 29, 2015
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`Manner of service Email: bbarker@chsblaw.com;
`gonsalves@gonsalveslawfirm.com; kurt@rauschenbach.com
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`Documents served PETITIONER’S RESPONSE TO PATENT OWNER’S
`MOTION FOR OBSERVATION ON CROSS-
`EXAMINATION OF PETITIONER’S REPLY WITNESS
`
`Persons Served Bruce Barker
`Chao Hadidi Stark & Barker LLP
`176 East Mail Street, Suite 6
`Westborough, MA 01581
`
`Dr. Gregory J. Gonsalves
`2216 Beacon Lane
`Falls Church, Virginia 22043
`
`
`
`/s/ Anna Goodall
`Anna Goodall
`White & Case LLP
`3000 El Camino Real
`Five Palo Alto Square, 9th Floor
`Palo Alto, CA 94306
`Tel: (650) 213-0367
`Email: agoodall@whitecase.com
`
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