Case IPR2016-01246
`U.S. Patent No. 7,126,174
`
`
`Filed on behalf of Godo Kaisha IP Bridge 1
`
`By: Neil F. Greenblum (ngreenblum@gbpatent.com)
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: (703) 716-1191
`Fax: (703) 716-1180
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.
`and GLOBALFOUNDRIES U.S. INC.,
`Petitioners,
`
`v.
`
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`____________
`
`Case IPR2016-012461
`U.S. Patent No. 7,126,174
`____________
`
`
`PATENT OWNER’S REQUEST FOR REHEARING
`
`
`
`
`
`
`1 Case IPR2016-01247 has been consolidated with this proceeding.
`
`GlobalFoundries U.S. Inc.’s motions for joinder in Cases IPR2017-00925 and
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`IPR2017-00926 were granted.
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`
`
`
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`

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`Case IPR2016-01246
`U.S. Patent No. 7,126,174
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`TABLE OF CONTENTS
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`
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`I.
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`II.
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`Page
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`Introduction ................................................................................................. 1
`
`The Board Misapprehended the Petition To Be Saying that the
`“Petition” Explained How Lee and Noble Are Combined ............................ 2
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`III. The Board Was Mistaken to Overlook the Obvious Complexity of
`Semiconductor Technology ......................................................................... 2
`
`IV. The Board Overlooked And Misapprehended the Law of Obviousness
`by Failing to Take Technological Complexity into Account ........................ 4
`
`V.
`
`The Board Was Mistaken to Overlook Dr. Banerjee’s Lack of
`Credibility .................................................................................................... 6
`
`VI. By Mistakenly Relying Extensively on Dr. Banerjee The Board
`Misapprehended and Was Misled as to the Complexity of Integrating
`the Proposed Combinations of References ................................................... 8
`
`VII. The Board Was Mistaken to Entirely Overlook The Explanation in the
`Sur-Reply of Why Lee and Lowrey Could Not be Modified as Dr.
`Banerjee Proposed ....................................................................................... 9
`
`VIII. The Board Overlooked and Misapprehended that to Establish
`Obviousness It Is Necessary to Establish What the Final Structure
`Would Look Like ......................................................................................... 9
`
`IX. The Board Was Mistaken to Ignore the Sur-Reply and Rely Heavily
`on Dr. Banerjee’s Unreliable Testimony .....................................................10
`
`X.
`
`The Board Was Mistaken to Ignore the Inadvisability of Forming a
`Raised Trench in Lowrey ............................................................................13
`
`XI. The Board Was Mistaken to Find That It Needs Only Evaluate the
`Portion of the Reply on Which it Chooses to Rely ......................................14
`
`XII. The Board Was Mistaken to Rule that Patent Owner Could Not
`Submit a Declaration with Its Sur-Reply .....................................................14
`
`XIII. Conclusion ..................................................................................................15
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`i
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`

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`I.
`
`Introduction
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`Case IPR2016-01246
`U.S. Patent No. 7,126,174
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`The Board misapplied the law of obviousness in the field of semiconductor
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`fabrication and relied extensively upon the unreliable testimony of Dr. Banerjee to
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`justify the unpatentability of claims 1-12 and 14-18 of U.S. Patent No. 7,126,174
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`(the “‘174 patent”), and for these reasons Patent Owner respectfully requests
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`rehearing.
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`Petitioner had the initial burden of asserting “how” an STI would be
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`substituted for the LOCOS of Lee and Lowrey. The Board credited the Declaration
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`testimony of Dr. Banerjee who said the substitution could be performed by a
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`POSITA without saying “how”, and granted the Petition. Petitioner’s Reply and
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`Declaration then proceeded for the first time to explain “how” the substitution
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`would be performed. Patent Owner objected and was granted limited permission
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`to file a Sur-Reply, but without a supporting Declaration. The Deposition of Dr.
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`Banerjee was then taken, and Patent Owner was authorized to include the
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`Deposition transcript in the Sur-Reply.
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`The Board was mistaken to: 1) initiate the IPR based upon a Petition which
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`did not explain “how” the substitution was to be performed; 2) not strike the Reply
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`for explaining “how” for the first time; 3) to credit the testimony of Dr. Banerjee
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`who contradicted himself and his Declaration; 4) not permit Patent Owner to file a
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`Declaration with the Sur-Reply; 5) selectively ignore portions of the Banerjee
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`1
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`U.S. Patent No. 7,126,174
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`testimony and the Sur-Reply relating directly to the credibility of Banerjee and the
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`unworkability of substituting STI into Lee and Lowrey.
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`II. The Board Misapprehended the Petition To Be Saying that the
`“Petition” Explained How Lee and Noble Are Combined
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`
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`The Board asserts that Petitioner explains in detail how Lee and Noble are
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`being combined referring back to Section II.D.3.b. of the Petition. FWD, p. 37.
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`This section relies in part upon Dr. Banerjee’s testimony which the Board found
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`persuasive. FWD, p. 16.
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`The Board mistakenly overlooks that neither the Petition nor Dr. Banerjee
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`ever said “how” the reference processes were to be combined to arrive at a
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`workable claimed invention. Petitioner itself acknowledged that its Petition had
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`not set forth “how” the references were to be combined. Reply, p. 18, FN 9.
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`III. The Board Was Mistaken to Overlook the Obvious Complexity of
`Semiconductor Technology
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`
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`Semiconductor fabrication technology is one of the most complex
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`technologies there is. As was noted throughout this proceeding, every single
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`applied reference, as well as virtually all of the remaining references devote
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`numerous columns describing exactly how their devices, including their isolation,
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`are formed. Dr. Schubert cited numerous supporting references in the literature
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`explaining the intricate complexity of semiconductor fabrication, and how changes
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`in one aspect impact the entire fabrication process. PO Response, Paper 14, p. 2;
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`2
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`U.S. Patent No. 7,126,174
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`Ex. 2012, ¶61; Ex. 2013-2019. The Board was mistaken to ignore the complexity
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`of the fabrication process when analyzing the obviousness of forming trench
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`isolation on the Lee and Lowrey devices.
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`Significantly, the Board overlooked Petitioner’s Ex. 1060 (slide 108) which
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`specifically shows that the substitution of STI for LOCOS to reduce the size of
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`semiconductor devices resulted in a 50% increase in the number of fabrication
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`steps. It actually says that process complexity for STI is “high”. See Ex. 1060, p.
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`108; and Oral Hearing Transcript (“Trial Transcript”), Paper 46, p. 33.
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`The Board’s attention was directed to Samsung Electronics Co., Ltd.,
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`Micron Technology, Inc., and SK Hynix, Inc. v. ELM 3DS Innovations, LLC,
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`IRP2016-00394, Paper 64 (PTAB June 23, 2017) (“the ‘394 decision”) which
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`specifically addressed the complexity of semiconductor technology:
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`In the particular circumstances of this case, with its complex
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`technology of integrated circuit fabrication and robust written
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`description articulating general advantages of its membrane dielectric
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`isolation process, we are not persuaded that Petitioner has met its
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`burden to provide sufficient articulated reasoning with rational
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`underpinning to support Petitioner’s conclusion of obviousness.”
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`Samsung, IPR2016-00394, Paper 64, p. 39.2
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`
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`2 The Board specifically asked whether Patent Owner was aware of any case
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`law in the field of semiconductor manufacture establishing that given the complex
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`3
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`Case IPR2016-01246
`U.S. Patent No. 7,126,174
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`The Board was mistaken to overlook the complexity of fabrication
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`associated with the transition from LOCOS to STI and reached a mistaken
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`conclusion as a result.
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`IV. The Board Overlooked And Misapprehended the Law of
`Obviousness by Failing to Take Technological Complexity into
`Account
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`From the outset, the Board has steadfastly maintained that regardless of
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`complexity there is no legal requirement that Petitioner explain how the device
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`being claimed could be fabricated based upon the asserted prior art.
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`Yet, paradoxically, while dismissing complexity as an issue, the Board
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`framed the issue as to which expert to believe on whether a POSITA would have
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`been “able to fabricate the semiconductor device of Lee, replacing its LOCOS with
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`nature of semiconductor manufacture it is necessary to show how references would
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`be combined. Trial Transcript, p. 49:3-8. Subsequently, Patent Owner was
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`authorized to submit a copy of the ‘394 decision without comment. Ex. 2080. The
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`decision is one of a family of decisions all standing for the proposition that
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`semiconductor fabrication technology is highly complex. See Final Written
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`Decisions in IPR2016-00393; IPR2016-00395; IPR2016-00390; IPR2016-00391;
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`IPR2016-00389; IPR2016-00786, and Combined Final Written Decision in
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`IPR2016-00386, -387, -388.
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`4
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`trench isolation as taught by Noble.” Institution Decision, pp. 17-18; Emphasis
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`added. The complexity issue was addressed in the same way for the remaining
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`rejections. Thus, while maintaining that there is no legal requirement for Petitioner
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`to explain how the references would be modified to arrive at the claimed invention,
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`the Board nevertheless, pointed to conflicting testimony of Patent Owner’s Dr.
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`Schubert as creating an issue of fact on this issue.
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`Despite the numerous exhibits attesting to the complexities of semiconductor
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`manufacture (PO Response, p. 2; Ex. 2012, ¶61; Ex. 2013-2019) and the IBM
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`exhibit (Pet. Ex. 1060) as well as the case law which was requested and supplied,
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`the Board erroneously took no account of all that had been presented and notes that
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`“Patent Owner does not cite any direct authority for this proposition, in semi-
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`conductor cases or otherwise, and we are aware of none.” FWD, p. 27.
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`The Board did “not see how the complexity of semiconductor manufacturing
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`in general requires a more detailed explanation …, particularly when Petitioner has
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`presented ample evidence … that a person of ordinary skill in the art would have
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`known how to fabricate a device with either type.” FWD, p. 28. Fabricating
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`“either type” is not the issue – substituting one for the other to arrive at a workable
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`device is the question. The Board was wrong to first acknowledge an issue of
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`expert credibility on being able to substitute STI for LOCOS, but then to find that
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`an explanation of how each of LOCOS and STI could be separately fabricated was
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`sufficient to explain how the LOCOS/STI substitution could be fabricated given
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`the structures of Lee and Lowrey. Innogenetics, N.V. v. Abbott Labs., 512 F.3d
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`1363, 1374 n.3 (“We must still be careful not to allow hindsight reconstruction of
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`the references to reach the claimed invention without any explanation as to how or
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`why the references would be combined to produce the claimed invention.”)
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`(Emphasis added).
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`V. The Board Was Mistaken to Overlook Dr. Banerjee’s Lack of
`Credibility
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`
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`The Board was wrong to rely on Dr. Banerjee for the complexity or
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`workability of the substitution, or anything else, because he is not a credible
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`witness.
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`In his initial entirely conclusory First Declaration (Ex. 1004), Dr. Banerjee
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`made no effort to explain the process for combining the references or how this
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`would be accomplished. When pressed by the PO Preliminary Response on this
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`issue, Dr. Banerjee’s Second Declaration explains for the first time “how” the
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`substitution would be made. Ex. 1057, ¶83. He declared that the process of Lee,
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`as described in Lee, would be “followed by deposition of the polysilicon gate
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`conductor layer 117, followed by silicon nitride or silicon oxynitride layer 118.
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`(Lee at 6:46–61.).” Ex. 1057, ¶83. Dr. Banerjee further said that the remainder of
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`the process would have proceeded as in Lee. Ex. 1057, ¶84. The “remainder of
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`the process” required first performing deep/heavy doping followed by shallow
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`doping.
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`Then during his deposition when explaining how the substitution would be
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`performed, he denied that anyone would perform deep/heavy doping followed by
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`shallow doping – it is just not done that way. Ex. 2078, pp. 87:14-88:3. This was
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`more than a mere misstatement, because when repeatedly questioned, Dr. Banerjee
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`(unwittingly) insisted repeatedly that one would not perform the process as it is
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`performed in Lee, which was however the very way he proposed that the
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`substitution be performed in his Declaration. Ex. 2078, pp. 88:4-90:1.
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`Dr. Banerjee did not realize that Lee uses the very sequence that he could not
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`imagine would be performed, i.e., deep/heavy doping first, followed by
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`shallow/light doping:
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`Q. It’s always done in this order. I’m talking not only about Lee, but
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`in general, is the shallow always done before the deep?
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`A. To the best of my knowledge, yes. Everything that I’ve seen, it has
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`been in that sequence.
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`Ex.2078, pp. 87:14-88:3.
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`Q. And can you think, as you sit - as you prepared your declaration
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`and as you sit here today, can you see a way to modify Lee so that it -
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`this doping sequence would be opposite to the one we’ve been talking
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`about? In other words, deep first and shallow second?
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`Mr. Yoches: Objection.
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`A. I mean, everything that I am aware of, you do the LDD first and
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`then the deeper implant second.
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`Id., at pp. 89:14-90:1.
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`After a break requested by Petitioner’s counsel, Dr. Banerjee blurted that he
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`“misspoke earlier.” Ex.2078, pp.124:12-131:19. He even denied that he had
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`offered an opinion on how the Lee process could be performed (deep first followed
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`by shallow) (“I have not given any opinion on that.”) Ex.2078; pp. 89-90. Yet,
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`that is precisely how Lee operates, and that is what Dr. Banerjee said and it was
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`exactly what he opined on in his Declaration.
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`To summarize:
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`1) During his deposition he said the Lee process (initial deep/heavy doping)
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`would not be followed when substituting trench isolation (Ex. 2078, pp. 87:14-
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`90:1);
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`2) He said exactly the opposite in his Declaration (Ex. 1057, ¶¶ 83-84); and
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`3) Then he denied he ever opined at all on doing initial deep/heavy doping
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`first (the process of Lee) (Ex. 2078, pp. 89-90).
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`VI. By Mistakenly Relying Extensively on Dr. Banerjee The Board
`Misapprehended and Was Misled as to the Complexity of
`Integrating the Proposed Combinations of References
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`The Board asserted that even if certain aspects of semiconductor device
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`manufacture “might” be complex, it does not appear that the substitution of trench
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`isolation for LOCOS would have been considered unduly complex, “given all the
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`evidence discussed above.” FWD, p. 28. The Board did not point to any specific
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`8
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`U.S. Patent No. 7,126,174
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`evidence, although repeated prior reference was made throughout to the testimony
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`of Dr. Banerjee, see, e.g., p. 23 where Dr. Banerjee is cited for the proposition that
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`“‘LOCOS and STI are both methods for forming insulating materials in the same
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`locations of the substrate to perform the same function,’ and ‘[t]hey are both
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`performed near the very beginning in device processing.’ Ex. 1004, ¶ 82.”
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`The Board was wrong to dismiss the complexity of “how” based upon the
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`testimony of Dr. Banerjee.
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`VII. The Board Was Mistaken to Entirely Overlook The Explanation
`in the Sur-Reply of Why Lee and Lowrey Could Not be Modified
`as Dr. Banerjee Proposed
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`
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`Patent Owner’s Sur-Reply to Petitioner’s Reply (Paper 37, “Sur-Reply”)
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`specifically addressed the incoherent/inconsistent explanation provided by Dr.
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`Banerjee as to “how” the references would be modified.
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`The Board was mistaken to overlook the portion of the Sur-Reply which
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`could only address for the first time why the process of combining the references
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`would not make a workable device.
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`VIII. The Board Overlooked and Misapprehended that to Establish
`Obviousness It Is Necessary to Establish What the Final Structure
`Would Look Like
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`
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`The Board maintains that Petitioner is not required to explain how a person
`
`of ordinary skill in the art would incorporate an STI into Lee’s device, while
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`preserving the gate stack and interconnection of Noble’s preferred embodiment.
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`FWD, p. 33.
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`It is indeed necessary to explain what the final combined structure would
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`look like, taking existing structure into account, in order to determine whether that
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`final structure satisfies the claim elements to produce a workable device.
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`Combining references cannot be an abstract exercise, relying only upon hindsight
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`to arrive at the claimed invention. See, e.g., Kinetic Concepts, Inc. v. Smith &
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`Nephew, Inc., 688 F.3d 1342, 1368 (Fed. Cir. 2012) (quoting Innogenetics, N.V. v.
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`Abbott Labs., 512 F.3d 1363, 1374 n.3.
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`IX. The Board Was Mistaken to Ignore the Sur-Reply and Rely
`Heavily on Dr. Banerjee’s Unreliable Testimony
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`
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`The Board decision references Dr. Banerjee 24 different times, and
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`substantially relied upon his expertise and credibility. The Board was mistaken to
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`rely on his testimony and ignore the Sur-Reply analysis of his testimony.
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`The Sur-Reply specifically cited to Dr. Banerjee’s contradictory testimony,
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`wherein Dr. Banerjee testified:
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`“I cannot think of a straightforward process flow where you do it in
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`reverse order [i.e., deep/heavy doping first followed by shallow/light
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`doping]. These implants are done using what are called self-
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`alignment techniques and very straightforward ways to do the
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`sequence of LDD first, followed by the heavier, deeper source drain.”
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`Ex.2078, p. 88:10-15.
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`Yet, the “unthinkable” is exactly what Petitioner/Banerjee proposed in his
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`Case IPR2016-01246
`U.S. Patent No. 7,126,174
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`Declaration (“The remainder of the process would have proceeded as Lee
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`teaches…).” Ex. 1057, ¶¶ 83, 84; Reply, p. 20. Ultimately during his deposition
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`Dr. Banerjee gave up said he gave no such opinion at all. Ex. 2078, pp. 89:14-
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`90:5.
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`
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`It is only in a footnote, that the Board addressed the Sur-Reply on this issue
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`and summarily discounted these “misstatements” (FWD, fn. 13, pp. 35-36) for the
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`following reasons:
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`1.
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`The Board first dismisses Dr. Banerjee’s misstatements because this
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`argument was not directly responsive to any of the new exhibits filed by Petitioner
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`with the Reply, noting that Patent Owner argued that a lengthy Sur-Reply was
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`necessary to respond to the lengthy arguments made by Petitioner in its Reply and
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`numerous exhibits submitted with the Reply, referring to Papers 27, 28.
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`The Board is clearly mistaken: Neither the Petition nor Dr. Banerjee’s first
`
`declaration ever said how the LOCOS of Lee would be replaced by trench
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`isolation. Then, for the first time in their Reply (Paper 21), as well as the Second
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`Banerjee Declaration (Ex. 1057) explained that the doping procedure of Lee was to
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`be followed after the formation of the trench. Reply, Paper 21, pp. 19-20; Ex.
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`1057, ¶¶83-84. Patent Owner was perfectly justified in questioning Dr. Banerjee
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`on his new assertion (Paper 21,dated June 14, 2017) during his deposition (June
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`27, 2017), and calling Dr. Banerjee’s contradictions to the Board’s attention.
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`U.S. Patent No. 7,126,174
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`Issues going to credibility are always relevant and appropriate.
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`As a matter of law, the Board was wrong and mistaken to overlook Dr.
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`Banerjee’s clearly contradictory testimony. As the Court of Appeals for the
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`Federal Circuit noted in a very analogous situation, Ultratec, Inc. v. CaptionCall,
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`LLC, 872 F.3d 1267, 1272 (Fed. Cir. 2017):
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`The Board offers no reasoned basis why it would not be in the interest
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`of justice to consider sworn inconsistent testimony on the identical
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`issue. Ultratec sought to offer recent sworn testimony of the same
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`expert addressing the same patents, references, and limitations at issue
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`in the IPRs. A reasonable adjudicator would have wanted to review
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`this evidence. If Mr. Occhiogrosso gave conflicting testimony on
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`cross-examination, this would be highly relevant to both the Board’s
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`analysis of the specific issues on which he gave inconsistent testimony
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`and to the Board’s overall view of his credibility. Mr. Occhiogrosso’s
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`testimony was critical to the Board’s fact findings in this case, as the
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`opinions’
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`repeated
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`reliance on
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`it establishes.
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` Under such
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`circumstances, no reasonable fact finder would refuse to consider
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`evidence of inconsistent sworn testimony. Moreover, any such
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`inconsistencies would likely bear on the overall credibility of the
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`expert.
`2.
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`The Board then minimizes the impact of Dr. Banerjee’s
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`“misstatements” by again noting that since the technology is not complex, there is
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`no requirement of a teaching of an actual, physical substitution of Noble’s STI into
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`Lee’s device. But the Board was relying on Dr. Banerjee’s unreliable testimony
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`U.S. Patent No. 7,126,174
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`for this proposition. Dr. Schubert directly challenged the ability to perform such a
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`substitution to arrive at the claimed invention (Ex. 2012, ¶ 186 et seq.) but the
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`Board believed Dr. Banerjee.
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`3.
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`The Board also dismissed the issue because “Patent Owner’s
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`arguments appear to be directed to purported problems or deficiencies with Lee
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`itself, rather than issues arising from the combination that may have discouraged a
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`person of ordinary skill in the art from combining Lee’s teachings with those of
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`Noble.”
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`The Board is clearly mistaken. As noted in the Sur-Reply, the “problem” is
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`not present in Lee or Lowrey, because the problems do not arise in the context of
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`LOCOS; they only arise when the substitution is made. Sur-Reply, pp. 17-18, and
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`27-28.
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`As a matter of law, the Board was wrong and mistaken to overlook Dr.
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`Banerjee’s clearly contradictory testimony as well as to overlook the Sur-Reply.
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`X. The Board Was Mistaken to Ignore the Inadvisability of Forming
`a Raised Trench in Lowrey
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`
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`Once again, the Board relies upon Dr. Banerjee to explain away the
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`significance of the height difference, and finds his explanation persuasive. FWD,
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`p. 58. The drawings in the Reply were the first explanation of how Lowrey would
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`be modified to include an STI. (Reply, pp. 19-20).
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`The Board was mistaken to overlook the unprofessional basis of Dr.
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`U.S. Patent No. 7,126,174
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`Banerjee’s opinion. When questioned on the errors in the drawings in his
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`Declaration where he simply eliminated reference to the height difference, he
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`repeatedly explained his errors were “stylistic” (Ex. 2078, pp. 197-201) and that he
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`did not find it necessary to go into “gory details” (Ex. 2078, pp. 210:8-10, 234:17-
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`19, 270:9-11) in his opinion.
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`Patent Owner was not permitted to submit a Declaration from Dr. Schubert
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`with its Sur-Reply, but in complex semiconductor technology it is simply
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`unthinkable for an expert to ignore the “gory” details and make “stylistic” errors.
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`The Board was mistaken to rely on Dr. Banerjee at all and to credit the testimony
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`of Dr. Banerjee as to the Lowrey substitution.
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`XI. The Board Was Mistaken to Find That It Needs Only Evaluate
`the Portion of the Reply on Which it Chooses to Rely
`
`
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`Given that the Reply for the first time explained how the combination was to
`
`be fabricated, the Board was wrong to ignore how Petitioner proposed combining
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`the teachings of the references in the Reply. FWD, p. 37. Because of the
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`complexity of semiconductor technology, the Board was indeed required to
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`evaluate the workability of the proposed processes. The Board was mistaken to
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`ignore the unworkable processes proposed by Petitioner/Dr. Banerjee.
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`XII. The Board Was Mistaken to Rule that Patent Owner Could Not
`Submit a Declaration with Its Sur-Reply
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`Patent Owner moved for permission to file a Sur-Reply (Orders, Paper 27, p.
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`Case IPR2016-01246
`U.S. Patent No. 7,126,174
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`3, and Paper 28, p. 2). During a conference call held on June 30, 2017, the Board
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`ruled that although it would authorize Patent Owner to file a Sur-Reply, an
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`accompanying Declaration was not authorized. Order, Paper 28, p. 3. The precise
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`permitted content of the Sur-Reply was not addressed. Order, Paper 28, p. 2 (“The
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`requested Sur-reply will be in response to Petitioner’s Reply.”)
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`Given that it was only in its Reply that Petitioner and Dr. Banerjee first
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`explained how they proposed fabricating the claimed invention, denying Patent
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`Owner the right to submit a Declaration on this issue was clear error. Patent
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`Owner was wrongly limited to explaining what an expert “would” say, if such a
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`Declaration would have been permitted.
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`XIII. Conclusion
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`Patent Owner respectfully requests the Board grant rehearing and, find the
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`Challenged Claims patentable.
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`Dated: February 1, 2018
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`Respectfully submitted,
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`/Neil F. Greenblum /
`Neil F. Greenblum
`Registration No. 28,394
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
`Fax: 703-716-1180
`Email: ngreenblum@gbpatent.com
`Attorney for Patent Owner,
`Godo Kaisha IP Bridge 1
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`Case IPR2016-01246
`U.S. Patent No. 7,126,174
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true copy of the foregoing:
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`PATENT OWNER’S REQUEST FOR REHEARING
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`was served by electronic mail on this 1st day of February, 2018, upon Counsel for
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`Petitioners, as follows:
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`Darren M. Jiron (darren.jiron@finnegan.com);
`J.P. Long (jp.long@finnegan.com);
`E. Robert Yoches (bob.yoches@finnegan.com);
`Joshua L. Goldberg (joshua.goldberg@finnegan.com);
`TSMC-IPB-PTAB@finnegan.com;
`Kent J. Cooper (kent.cooper@kjcooperlaw.com); and
`Adam Floyd (floyd.adam@dorsey.com)
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`/Neil F. Greenblum/
`Neil F. Greenblum
`Registration No. 28,394
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
`Fax: 703-716-1180
`Email: ngreenblum@gbpatent.com
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