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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`Petitioner,
`
`v.
`
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`
`
`Case IPR2016-012461
`Patent 7,126,174 B2
`
`
`PETITIONER’S MOTION TO EXCLUDE EVIDENCE
`UNDER 37 C.F.R. § 42.64(c)
`
`
`
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`
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`1 Case IPR2016-01247 has been consolidated with this proceeding.
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`
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`IPR2016-01246, IPR2016-01247
`Patent 7,126,174 B2
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`TABLE OF CONTENTS
`
`
`I.
`II.
`
`Introduction ...................................................................................................... 1
`The Board should exclude paragraphs 33–159 of Patent Owner’s
`Exhibit 2001, paragraphs 33–149 of Patent Owner’s Exhibit 2011, and
`paragraphs 4–10 and 35–458 of Patent Owner’s Exhibit 2012 as
`unreliable expert testimony. ............................................................................ 3
`III. The Board should exclude in their entirety Patent Owner’s Exhibits
`2002–2010, 2013–2019, 2026–2030, 2032, and 2033 as irrelevant and
`non-probative evidence. ................................................................................... 6
`A.
`Exhibits 2002, 2003, 2004, 2032, and 2033 .......................................... 6
`B.
`Exhibits 2005, 2006, 2007, 2008, 2009, and 2010 ................................ 7
`C.
`Exhibits 2013, 2014, 2015, 2016, 2017, 2018, and 2019 ..................... 9
`D.
`Exhibit 2026 ........................................................................................ 10
`E.
`Exhibits 2027, 2028, 2029, and 2030 .................................................. 11
`IV. The Board should exclude in their entirety Patent Owner’s Exhibits
`2003, 2004, and 2026 as hearsay. .................................................................. 12
`A.
`Exhibits 2003 and 2004 ....................................................................... 12
`B.
`Exhibit 2026 ........................................................................................ 12
`
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`
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`IPR2016-01246, IPR2016—01247
`
`Patent 7,126,174 B2
`
`I.
`
`Introduction
`
`For the reasons discussed below, Petitioner TSMC hereby moves to exclude
`
`the following evidence under 37 CPR. § 42.64(c):
`
`Declaration of Dr. E. Fred Schubert, PhD. in support of Patent Owner’s
`5E a?
`'
`'
`onse filed in IPR2016—01246 on October 5, 2016
`
`Schematic illustration of the Chemical Mechanical Polishing process
`from Steigerwald, Murarka, and Gutmann, Chemical Mechanical
`Planarization o Microelectronic Materials 1997 .
`
`Schematic illustration of the Chemical Mechanical Polishing process
`from the Motorola Company. SC Solutions.com. Accessed September
`30, 2016. http://www.scsolutionscom/chemical-
`mechanical lanarization—cm u —controllers—0
`
`Photograph of a Chemical Mechanical Polishing Tool from the Applied
`Materials Company. BusinessWire.com. Accessed October 5, 2016.
`http://www.businesswire.com/news/home/200407 1 1005007/en/Applied—
`Materials-Revolutionizes-Planarization—Technology-Breakthrough—
`Reflexion
`
`2005
`
`Troxel, Boning, McIlrath “Semiconductor Process Representation.”
`Wil' En cloedia 0 Electrical and Electronics, . . 139—147 1999 .
`
`2006 US. Patent No. 6,052,319 to Jacobs
`
`2007 US. Patent No. 6,952,656 to Cordova et al.
`
`2008
`
`Hunt, “Low Budget Undergraduate Microelectronics Laboratory.”
`University Government Industry Microelectronics Symposium, pp. 81-87
`2006
`
`2009 US. Patent No. 7,074,709 to Youn
`2010
`Burckel, “3D—ICs created using oblique processing.” Advances in
`Patternin Materials and Processes MI], o . 1—12 2016 .
`
`2011
`
`Declaratin ofDr. E- Fred Schubert, Ph.D. in support ofPatent Owner’s
`
`2012
`
`E
`'
`
`'
`
`onse filed in IPR2016-01247 on October 7, 2016
`
`Declaration of Dr. E. Fred Schubert, Ph.D. in support of Patent Owner’s
`Res onse filed in IPR2016-01246 on March 24, 2017-
`
`Thompson, L. F- “An Introduction to Lithography.” Introduction to
`2013 Microlithography, ACS Symposium Ser., American Chemical Society,
`. .1—13 1983 .
`
`2014
`
`CA1275846 C to Roland et al.
`
`
`
`IPR2016-01246, IPR2016-01247
`
`Patent 7,126,174 B2
`
`“Structural Analysis Sample Report” downloaded from
`https://www.chipworks.com/TOC/Structural_Analysis_Sample_Report.
`df 2008 .
`
`2027
`
`Subbanna, S.; Ganin, E.; Crabbé, E.; Comfort, J.; Wu, S.; Agnello, P.;
`Martin, B.; McCord, M.; Newman, H. Ng. T.; McFarland, P.; Sun, J.;
`Snare, J.; Acovic, A.; Ray, A.; Gehres, R.; Schulz, R.; Greco, S.; Beyer,
`K.; Liebmann, L.; DellaGuardia, R.; Lamberti, A. “200 mm Process
`Integration for a 0.15 pm Channel-Length CMOS Technology Using
`Mixed X-Ray / Optical Lithography.”
`roceedings of1994 IEEE
`
`
`
`Hu, Chenming. “Deep-Submicrometer MOS Device Fabrication Using a
`Photoresist—Ashing Technique.” IEEE Electron Device Letters, Vol. 9.
`.
`0 .186—188 1988.
`
`Tanaka, Tetsu; Suzuki, Kunihiro; Horie, Hiroshi; Sugii, Toshihiro.
`“Ultrafast Low-Power Operation of p+-n+ Double-Gate SOI
`MOSFETS.” 1994 Symposium on VLSI Technology Digest of
`Technical Paers, . _ 11—12 1994 .
`
`Kaufman, F- B.; Thompson, D. B-; Broadie, R. E.; Jaso, M. A.; Guthrie,
`W. L.; Pearson, D. J.; and Small, M. B. “Chemical—Mechanical
`Polishing for Fabricating Patterned W Metal Features as Chip
`Interconnects.” Journal of The Electrochemical Society, Vol. 138, No-
`11,
`. . 3460—3465 1991 .
`
`Landis, H.; Burke, P.; Cote, W.; Hill, W.; Hoffman, C.; Kaanta, C.;
`Koburger, C.; Lange, W-; Leach, M.; and Luce, S. “Integration of
`chemical-mechanical polishing into CMOS integrated circuit
`manufacturin
`Thin Solid Films, Vol. 220, No. 1—2,
`0 . 1—7 1992 .
`
`
`
`IPR2016-01246, IPR2016-01247
`Patent 7,126,174 B2
`
`
`II. The Board should exclude paragraphs 33–159 of Patent Owner’s
`Exhibit 2001, paragraphs 33–149 of Patent Owner’s Exhibit 2011, and
`paragraphs 4–10 and 35–458 of Patent Owner’s Exhibit 2012 as
`unreliable expert testimony.
`
`The Board should exclude paragraphs 33–159 of Patent Owner’s Exhibit
`
`2001, paragraphs 33–149 of Patent Owner’s Exhibit 2011, and paragraphs 4–10
`
`and 35–458 of Exhibit 2012 because they contain unreliable testimony under Fed.
`
`R. Evid. 702 and Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (1993).
`
`Petitioner objected to Exhibits 2001 and 2011 in objections dated January 19,
`
`2017. Paper 13, at 2–3. Petitioner objected to Exhibit 2012 in objections dated
`
`March 31, 2017. Paper 16, at 3–4. Patent Owner relies extensively on Exhibits
`
`2001 and 2011 throughout its Preliminary Response (Paper 7), and relies
`
`extensively on Exhibit 2012 throughout its Response (Paper 14).
`
`Under Rule 702, an expert must be qualified in the area about which he
`
`testifies. “[T]he expert’s scientific, technical, or other specialized knowledge
`
`[must] help the trier of fact to understand the evidence or to determine a fact in
`
`issue.” Fed. R. Evid. 702(a). Because Dr. Schubert is not qualified to opine on
`
`shallow trench isolation in silicon MOSFET devices, the Board should not
`
`consider the opinions he expressed in paragraphs 33–159 of Patent Owner’s
`
`Exhibit 2001, paragraphs 33–149 of Patent Owner’s Exhibit 2011, or paragraphs
`
`4–10 and 35–458 of Exhibit 2012.
`
` 3
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`IPR2016-01246, IPR2016-01247
`Patent 7,126,174 B2
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`Paragraphs 13–21 of EX2001 and EX2011 and paragraphs 13–23 of
`
`EX2012 (including Dr. Schubert’s CV) fail to establish Dr. Schubert as someone
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`possessing special knowledge, skill, experience, training, or education about device
`
`isolation in Si MOSFETs, the subject of this IPR. Although he has experience
`
`with III-V compound semiconductors2 and light-emitting devices (e.g., LEDs and
`
`laser diodes), those devices are very different from the Si MOSFET structures at
`
`issue in these proceedings, and they do not involve LOCOS isolation or STI.3 His
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`expertise in III-V light-emitting diodes does not qualify him as an expert on
`
`isolation in Si MOSFET devices. See, e.g., Perkins v. Volkswagen of Am., Inc., 596
`
`F.2d 681, 682 (5th Cir. 1979) (affirming a trial court’s decision to permit “a
`
`specialist in mechanical engineering with no experience in designing entire
`
`2 III-V refers to compounds made from Group III (e.g., Al, Ga, In) and
`
`Group V (e.g., N, P, As, Sb) of the periodic table. Silicon is not a compound
`
`semiconductor and comes from Group IV of the periodic table.
`
`3 There is no discussion of III-V semiconductors or light-emitting devices in
`
`the ’174 patent, the primary references, or the declarations because they are
`
`irrelevant to the technology at issue in these proceedings. For example, LEDs and
`
`laser diodes do not have gates, sources, or drains (they are diodes, not transistors),
`
`and LOCOS specifically refers to the “LOCal Oxidation of Silicon,” which is
`
`inapplicable to III-V materials.
`
` 4
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`IPR2016-01246, IPR2016-01247
`Patent 7,126,174 B2
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`automobiles, to express expert opinions on general mechanical engineering
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`principles” but disqualifying him “as an expert in automotive design”).
`
`Even though Dr. Schubert does not have, or even claim to have, any
`
`experience with LOCOS isolation or STI in Si MOSFET devices, he offers many
`
`opinions about what a person of ordinary skill in the art would have known about
`
`Si MOSFET devices, LOCOS isolation, and STI during the relevant period of 1989
`
`to 1996. See, e.g., EX2012 at ¶¶ 8, 90, 199–202, 239–242.
`
`During his deposition, the only work Dr. Schubert testified he did relating to
`
`Si semiconductor devices during the relevant time periods involved niche methods
`
`of doping, called “delta doping,” having nothing to do with the ’174 patent or prior
`
`art. EX1056 at 48:21–50:6, 52:11–53:13. When asked to identify his work most
`
`relevant to these proceedings, Dr. Schubert did not identify anything other than
`
`references about these irrelevant delta doping techniques. EX1056 at 45:21–46:2;
`
`EX2012 at 233–36.
`
`The focus of this IPR is not doping, and certainly not delta doping, but
`
`device isolation—specifically, whether STI could substitute for LOCOS isolation.
`
`Nothing in Dr. Schubert’s declarations, CV, or deposition testimony suggest he is
`
`qualified to opine on LOCOS isolation or STI. He identified no experience
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`designing or fabricating LOCOS isolation or STI, and admitted his only exposure
`
` 5
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`Patent 7,126,174 B2
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`to MOSFET device isolation structures was a general awareness of them. EX1056
`
`at 67:18–71:14.
`
`A general awareness of device isolation structures does not qualify Dr.
`
`Schubert as an expert on LOCOS isolation or STI. Because he has no specialized
`
`knowledge or experience of LOCOS isolation or STI, Dr. Schubert is not qualified
`
`to opine on issues involving what a person of ordinary skill would know about
`
`substituting one for the other. The Board should exclude his opinions.
`
`III. The Board should exclude in their entirety Patent Owner’s Exhibits
`2002–2010, 2013–2019, 2026–2030, 2032, and 2033 as irrelevant and
`non-probative evidence.
`
`The Board should exclude Exhibits 2002–2010, 2013–2019, 2026–2030,
`
`2032, and 2033 in their entirety because they are irrelevant and non-probative
`
`under Fed. R. Evid. 401, 402, and 403.
`
`A. Exhibits 2002, 2003, 2004, 2032, and 2033
`
`Petitioner objected to Exhibits 2002, 2003, and 2004 as irrelevant and non-
`
`probative in objections dated January 19, 2017. Paper 13, at 4–6. Petitioner further
`
`objected to Exhibit 2004 as irrelevant and non-probative in objections dated March
`
`31, 2017. Paper 16, at 4–6. Petitioner objected to Exhibits 2032 and 2033 as
`
`irrelevant and non-probative in objections dated March 31, 2017. Paper 16, at 4–6.
`
`Dr. Schubert cites Exhibits 2002, 2003, and 2004 at ¶ 61 & n.5 of Exhibits
`
`2001 and 2011 and at ¶ 68 & n.7 of Exhibit 2012. He cites Exhibits 2032 and 2033
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` 6
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`IPR2016-01246, IPR2016-01247
`Patent 7,126,174 B2
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`at ¶ 68 & n.6 of Exhibit 2012. Patent Owner cites Exhibits 2004, 2032, and 2033 at
`
`page 102 of its Response (Paper 14). Patent Owner does not cite Exhibit 2002 or
`
`2003.
`
`Exhibits 2002, 2003, 2004, 2031, and 2033 are irrelevant to the claims-at-
`
`issue in these proceedings, none of which involve chemical-mechanical polishing
`
`(CMP), the subject-matter of these exhibits. The claims at issue in these
`
`proceedings are device structure claims, making CMP irrelevant.4 In addition,
`
`Exhibits 2002, 2003, and 2004 were published after the date of alleged invention
`
`and therefore provide only “impermissible . . . later knowledge about later art-
`
`related facts.” In re Hogan, 559 F.2d 595, 605 (CCPA 1977).
`
`B.
`
`Exhibits 2005, 2006, 2007, 2008, 2009, and 2010
`
`Petitioner objected to Exhibits 2005, 2006, 2007, 2008, 2009, and 2010 as
`
`irrelevant and non-probative in objections dated January 19, 2017. Paper 13, at 6–
`
`7. Dr. Schubert cites Exhibits 2005–2010 only at ¶ 53 of Exhibits 2001 and 2011.
`
`Patent Owner does not cite them. Dr. Schubert suggests that Exhibits 2005–2010
`
`show the “complexity” of matters relating to the ’174 patent, but Exhibits 2005–
`
`2010 are directed to irrelevant technologies unrelated to LOCOS isolation or STI.
`
`
`4 The ’174 patent explains how to use planarization methods other than CMP
`
`to make the claimed structures. EX1001, at 12:43–52, 22:34–49, 25:12–25.
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` 7
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`IPR2016-01246, IPR2016-01247
`Patent 7,126,174 B2
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`None of Exhibits 2005–2010 even mentions LOCOS isolation or STI, which
`
`are at issue in these proceedings. Patent Owner instead cherry-picks isolated
`
`statements from irrelevant contexts to suggest substituting STI for LOCOS
`
`isolation would be “complex”:
`
` “structured or formalized representations [of semiconductor fabrication
`
`processes] that can be understood and manipulated by a collection of
`
`computer programs” (EX2005 at 2);
`
` “an apparatus and method for identifying and preventing improper shipment
`
`of integrated circuits” (EX 2006 at 1:8–10);
`
` “Wafer Fabrication Data Acquisition and Management Systems” (EX2007,
`
`Title);
`
` “Low Budget Undergraduate Microelectronics Laboratory” (EX2008, Title);
`
` reducing electromigration in back-end copper interconnects to improve their
`
`mechanical stability (EX2009 at Abstract, 1:18–21, 2:4–20, 4:10–12); and
`
` “new interconnect topologies,” such as non-planar circuit topologies, created
`
`by “[e]liminating the constraint of 2D planar device architecture” like the 2D
`
`architectures exclusively at issue in these proceedings (EX2010 at 1, 4–5).
`
`Additionally, these exhibits were published after the date of alleged invention and
`
`provide only “impermissible . . . later knowledge about later art-related facts.”
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` 8
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`IPR2016-01246, IPR2016-01247
`Patent 7,126,174 B2
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`Hogan, 559 F.2d at 605. The exhibits are irrelevant to the substitutability of
`
`LOCOS isolation and STI and more likely to confuse this issue than to clarify it.
`
`C. Exhibits 2013, 2014, 2015, 2016, 2017, 2018, and 2019
`
`Petitioner objected to Exhibits 2013, 2014, 2015, 2016, 2017, 2018, and
`
`2019 as irrelevant and non-probative in objections dated March 31, 2017. Paper 16,
`
`at 6. Patent Owner cites Exhibits 2013–2019 at pages 2, 3, 10, and 13 of its
`
`Response (Paper 14). Dr. Schubert cites them at ¶¶ 49, 61, and 77 of Exhibit 2012.
`
`Patent Owner suggests that Exhibits 2013–2019 show the “complexity” of matters
`
`relating to the ’174 patent, but Exhibits 2013–2019 are directed to irrelevant
`
`technologies unrelated to LOCOS isolation or STI.
`
`None of Exhibits 2013–2019 even mentions LOCOS isolation or STI. Patent
`
`Owner instead cherry-picks isolated statements from irrelevant contexts to suggest
`
`substituting STI for LOCOS isolation would be “complex”:
`
` “An Introduction to Lithography” (EX2013, Title);
`
` “Process for Forming a Negative Pattern in a Photoresist Layer” (EX 2014,
`
`Title);
`
` “Integrated Circuit Polishing Method” (EX2015, Title);
`
` “Titanium/Aluminum/Nitrogen Material for Semiconductor Devices”
`
`(EX2016, Title);
`
` 9
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` “Process for Depositing a Thin-Film Layer of Magnetic Material Onto an
`
`Insulative Dielectric Layer of a Semiconductor Substrate” (EX2017, Title);
`
` “Integrated Circuit Micro-Fabrication Using Dry Lithographic Processes”
`
`(EX2018, Title); and
`
` “A method and apparatus for determining integrated circuit layouts from a
`
`virtual circuit description” (EX2019, Abstract).
`
`These exhibits are irrelevant to the substitutability of LOCOS isolation and STI
`
`and more likely to confuse this issue than to clarify it.
`
`D. Exhibit 2026
`
`Petitioner objected to Exhibit 2026 as irrelevant and non-probative in
`
`objections dated March 31, 2017. Paper 16, at 6–7. Exhibit 2026 is a reproduction
`
`of a 161-page “Sample Report” from a company called Chipworks downloaded
`
`from the Internet. See Paper 14, at ix; Paper 25, at 5. None of Patent Owner’s
`
`papers or supporting exhibits identify or discuss any specific portions of this
`
`Sample Report, making it impossible to establish its applicability to Patent
`
`Owner’s arguments or the issues in these proceedings. Patent Owner cites Exhibit
`
`2026 at pages 103 and 104 of its Response (Paper 14), and Dr. Schubert cites it at
`
`¶¶ 385 and 410 of Exhibit 2012.
`
`Exhibit 2026 is irrelevant to the claims at issue in these proceedings, none of
`
`which relate to scanning electron microscopy (SEM), the only reason for which
`
`
`10
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`IPR2016-01246, IPR2016-01247
`Patent 7,126,174 B2
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`Patent Owner cites it. Exhibit 2026 is further irrelevant because it bears a date of
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`January 2008 and significantly post-dates the invention, providing only
`
`“impermissible . . . later knowledge about later art-related facts.” Hogan, 559 F.2d
`
`at 605. The Sample Report provides analysis of a “45 nm process,” which did not
`
`exist at the time of alleged invention. See, e.g., EX1054 at 25 (showing the state-
`
`of-the-art was 350 to 250 nm).
`
`E.
`
`Exhibits 2027, 2028, 2029, and 2030
`
`Petitioner objected to Exhibits 2027–2030 as irrelevant and non-probative in
`
`objections dated March 31, 2017. Paper 16, at 7. None of Patent Owner’s papers or
`
`supporting evidence identify or discuss specific portions of Exhibits 2027–2030,
`
`making it impossible to establish any specific applicability of these documents to
`
`the issues in these proceedings. Patent Owner cites Exhibits 2027–2030 at pages
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`103 and 104 of its Response (Paper 14), and Dr. Schubert cites them at ¶¶ 385 and
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`410 of Exhibit 2012 to suggest “a microscopic assessment technique such as
`
`scanning electron microscopy (SEM) in 1995 would show the two layers [of
`
`Lowrey’s sidewalls] as an indistinguishable entity.” Paper 14, at 103; Exhibit 2012
`
`at ¶ 385. Because the validity of the claims-at-issue have nothing to do with SEM
`
`techniques, Exhibits 2027–2030 are irrelevant to the issues in this case. Finally, the
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`poor resolution of the SEM images in Exhibits 2027–2030 renders these exhibits
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`unusable and more likely to confuse the issues than to clarify them.
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`11
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`IPR2016-01246, IPR2016-01247
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`IV. The Board should exclude in their entirety Patent Owner’s Exhibits
`2003, 2004, and 2026 as hearsay.
`
`The Board should exclude Exhibits 2003, 2004, and 2026 in their entirety
`
`because they are hearsay under Fed. R. Evid. 801 and 802.
`
`A. Exhibits 2003 and 2004
`
`Exhibits 2003 and 2004 are from third-party websites about which neither
`
`Dr. Schubert nor anyone else provided evidence of personal knowledge. Petitioner
`
`objected to Exhibits 2003 and 2004 as hearsay in objections dated January 19,
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`2017. Paper 13, at 7. Petitioner further objected to Exhibit 2004 as hearsay in
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`objections dated March 31, 2017. Paper 16, at 7. Dr. Schubert cites Exhibits 2003
`
`and 2004 at ¶ 61 & n.5 of Exhibits 2001 and 2011 and at ¶ 68 & n.7 of Exhibit
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`2012. Patent Owner cites Exhibit 2004 at page 102 of its Response (Paper 14).
`
`Patent Owner and Dr. Schubert rely on Exhibits 2003 and 2004 for the truth of the
`
`matters asserted therein, and no hearsay exception applies.
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`B.
`
`Exhibit 2026
`
`Exhibit 2026 is from a “Sample Report” created by a third-party and hosted
`
`by third-party website about which neither Dr. Schubert nor anyone else provided
`
`evidence of personal knowledge. Petitioner objected to Exhibit 2026 as hearsay in
`
`objections dated March 31, 2017. Paper 16, at 7. Patent Owner cites Exhibit 2026
`
`at pages 103 and 104 of its Response (Paper 14). Dr. Schubert cites it at ¶¶ 385 and
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`12
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`410 of Exhibit 2012. Patent Owner and Dr. Schubert rely on this material for the
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`truth of the matters asserted therein, and no hearsay exception applies.
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`Dated: July 12, 2017
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`Respectfully submitted,
`
`
`
`By: /Darren M. Jiron/
`Darren M. Jiron
`Reg. No. 45,777
`
`
`Lead Counsel for Petitioner
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`13
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), this is to certify that I served a true and
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`correct copy of the Petitioner’s Motion To Exclude Evidence by electronic mail,
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`on this 12th day of July, 2017, on counsel of record for the Patent Owner as
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`follows:
`
`
`Neil F. Greenblum
`ngreenblum@gbpatent.com
`
`Michael J. Fink
`mfink@gbpatent.com
`
`Arnold Turk
`aturk@gbpatent.com
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`
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`Dated: July 12, 2017
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`By: /Lauren K. Young/
`Lauren K. Young
`Litigation Legal Assistant
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, L.L.P.
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