throbber
Case IPR2016-01246 for
`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, VA 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 LIMITED,
`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 OPPOSITION TO
`PETITIONER’S MOTION TO EXCLUDE EVIDENCE
`
`
`
`1 Case IPR2016-01247 has been consolidated with this proceeding.
`GlobalFoundries U.S. Inc.’s motions for joinder in Cases IPR2017-00925 and
`
`IPR2017-00926 were granted.
`
`

`

`Case IPR2016-01246 for
`U.S. Patent No. 7,126,174
`
`TABLE OF CONTENTS
`
`I. PARAGRAPHS 33-159 OF EXHIBIT 2001, PARAGRAPHS 33-149 OF
`
`EXHIBIT 2011, AND PARAGRAPHS 4-10 AND 35-458 OF EXHIBIT 2012
` ARE NOT UNRELIABLE EXPERT TESTIMONY ....................................... 1
`
`A. Dr. Schubert’s Expertise As To Doping Is Highly Relevant To Petitioner’s
`
`Lee V. Noble/Ogawa Rejections ................................................................... 2
`
`B. Dr. Schubert Is An Expert In Both Locos And Trench Isolation ................... 5
`
`II.
`
`
`
`PATENT OWNER’S EXHIBITS 2002-2010, 2013-2019, 2026-2030, 2032,
`AND 2033 ARE NOT IRRELEVANT AND NON-PROBATIVE
`EVIDENCE. ................................................................................................. 8
`
`A. Exhibits 2002, 2003, 2004, 2032, and 2033 .................................................. 8
`
`B. Exhibits 2005, 2006, 2007, 2008, 2009, and 2010 ........................................ 9
`
`C. Exhibits 2013, 2014, 2015, 2016, 2017, 2018, and 2019 ............................... 9
`
`D. Exhibit 2026 ................................................................................................10
`
`E. Exhibits 2027, 2028, 2029, and 2030 ...........................................................11
`
`III. PATENT OWNER’S EXHIBITS 2003, 2004, AND 2026 SHOULD NOT
`
`BE EXCLUDED AS HEARSAY ................................................................12
`
`A. Exhibits 2003 AND 2004 ............................................................................12
`
`B. Exhibit 2026 ................................................................................................13
`
`
`
`
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`Case IPR2016-01246 for
`U.S. Patent No. 7,126,174
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`TABLE OF AUTHORITIES
`
`Rules
`
`Fed. R. Evid. 703 ...................................................................................... 11, 12, 13
`
`Fed. R. Evid. 807 ............................................................................................ 13, 14
`
`Regulations
`
`37 C.F.R § 42.64 (b)(2) .......................................................................................... 2
`
`37 C.F.R. § 42.64 (b) ............................................................................................. 1
`
`
`
`ii
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`Case IPR2016-01246 for
`U.S. Patent No. 7,126,174
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`Petitioner’s Motion To Exclude Evidence (“Motion”) seeks to exclude
`
`Exhibits 2001-2019, 2021-2033. For the reasons set forth herein, none of these
`
`exhibits should be excluded.
`
`I.
`
`
`
`
`PARAGRAPHS 33-159 OF EXHIBIT 2001, PARAGRAPHS 33-149 OF
`EXHIBIT 2011, AND PARAGRAPHS 4-10 AND 35-458 OF EXHIBIT
`2012 ARE NOT UNRELIABLE EXPERT TESTIMONY
`
`Petitioner’s entire basis for its objection to Dr. Schubert now is that he is not
`
`an expert in LOCOS isolation or STI in STI MOSFET devices. This challenge
`
`should be summarily dismissed because it was not raised in Petitioner’s earlier
`
`objections (Paper 13 and Paper 16) in accordance with 37 C.F.R. § 42.64 (b).
`
`Petitioner’s previous objections were based solely on Dr. Schubert’s lack of
`
`expertise with LDD (lightly doped drain) MOSFETs. Paper 13, pp. 2-3; Paper 16,
`
`pp. 3-4. Patent Owner responded pursuant to 37 C.F.R. § 42.64 (b)(2) by serving
`
`supplemental evidence, and then including this evidence as part of its Response
`
`(Exhibit 2012, pp. 213-273). In view of the supplementation, and possibly
`
`convinced that Dr. Schubert is indeed an expert about doping matters, including
`
`LDD, Petitioner has now entirely shifted to a new objection which Patent Owner
`
`has never had a chance to address by supplementation, i. e., Petitioner now asserts
`
`that Dr. Schubert is now not an expert and even has no experience with LOCOS
`
`isolation or STI with MOSFET devices. Motion to Exclude, Paper 29, p. 5.
`
`
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`Case IPR2016-01246 for
`U.S. Patent No. 7,126,174
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`Petitioner’s shift in position has given Patent Owner no opportunity to
`
`supplement as per 37 C.F.R § 42.64 (b)(2) and for this reason alone the Motion
`
`should be denied as to Dr. Schubert.
`
`A. Dr. Schubert’s Expertise As To Doping Is Highly Relevant To
`Petitioner’s Lee V. Noble/Ogawa Rejections
`
`
`Petitioner previously objected based only upon Dr. Schubert’s alleged
`
`inexperience with doping, which they now say is not a “focus” of this case. Paper
`
`29, p. 5. As such, it is impossible to know whether this objection is maintained.
`
`On pages 19-20 of the Reply (Paper 21), TSMC stated that the rejection
`
`based upon Lee is premised on the fact that after a trench is imported into Lee, and
`
`“gate oxide 115, polysilicon 117, and silicon nitride/silicon oxynitride layer 118
`
`are successively deposited (cite omitted),” that “the remainder of the process
`
`would have proceeded as Lee teaches resulting in the obviating structure below
`
`(Fig. 15’), which IPB ignored.” (citing to Paper 2 in ‘1246 proceeding, at 21,70).
`
`These are two false cites. Neither page says this.
`
`Petitioner’s Reply was the first time that TSMC ever stated that an
`
`“unembedded”2 trench from somewhere was to be imported into Lee, after which
`
`the remainder of the process would proceed according to Lee. The remainder of
`
`
`
`2 Unembedded – A trench which is formed by embedding it within a gate
`electrode/conductor and gate dielectric as per Noble/Ogawa.
`
`
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`2
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`Case IPR2016-01246 for
`U.S. Patent No. 7,126,174
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`the Lee process includes doping after forming sidewalls 19, 21 and 23 (Figs. 4-10)
`
`and 119, 121 and 123 (Figs. 13-15).
`
`Doping was extensively depicted on pp. 65-67 of the Petition (Paper 2 in
`
`‘1246 proceeding) with specific reference to ¶187 of Exhibit 1004, which states
`
`that this LDD (lightly doped drain structure) was a standard one known in the
`
`semiconductor processing art at the time.
`
`Dr. Banerjee acknowledged at his deposition that the sequence of forming
`
`the LDD structure of Lee is not the way such doping is to be performed, and he
`
`knows of no one who would perform such a doping sequence with an STI. Exhibit
`
`2078, 87:14 - 90:2. He says that he knows of no other instance where the doping is
`
`performed as depicted in Figs. 5 and 6 of Lee, i.e., spaced away from the gate due
`
`to the sidewalls of the STI. Exhibit 2078, Id.
`
`Then, despite his original declaration (Exhibit 1004, ¶187), and his earlier
`
`testimony, Dr. Banerjee testified that he offered no opinion on Lee’s doping
`
`sequence (Exhibit 2078, 89:21 – 90:8).
`
`Thus, contrary to TSMC’s assertion, how Lee dopes is highly relevant at
`
`least to the Lee rejection, whether Dr. Banerjee offered an opinion on it or not. Dr.
`
`Schubert’s knowledge and description of the special nature of Lee’s doping
`
`sequence is relevant to the Board’s understanding of the superficiality/inaccuracy
`
`
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`Case IPR2016-01246 for
`U.S. Patent No. 7,126,174
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`of Dr. Banerjee’s conclusory Declaration testimony and why it would not be
`
`compatible with trench.
`
`Dr. Schubert’s experience in doping is virtually unsurpassed. He was
`
`questioned on his doping experience at his deposition:
`
`A. In which time frame?
`
`Q. At any time frame.
`
`A. That was the goal of our work, of my work that I did at AT&T
`
`Bell Laboratories. Investigate the suitability of different doping
`
`profiles for silicon MOSFETs. At that time, it was difficult to
`
`produce shallow junctions. We wanted to produce shallow
`
`junctions in order to reduce the short channel effects in silicon
`
`MOSFETs.
`
`We reviewed and we developed various doping techniques that
`
`would improve the weaknesses that existed at that time in silicon
`
`MOSFETs. And a significant part of my work was done in the
`
`field of doping. I have written two books, or I have authored two
`
`books on the doping of semiconductors.
`
`And the field of doping has been an active field of my research for
`
`the last 30 years. And investigating doping profiles and suitability
`
`of doping profiles, the requirement for doping profiles, including
`
`doping profiles in silicon MOSFETs, including lightly doped drain
`
`MOSFETs has been part of my work.”
`
`Exhibit 1056, 54:3 – 55:4.
`
`
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`Case IPR2016-01246 for
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`For the above reasons, Dr. Schubert is eminently qualified to testify on
`
`issues of doping. His testimony is highly relevant and should not be excluded.
`
`B. Dr. Schubert Is An Expert In Both Locos And Trench
`
`Isolation
`
`Shying away from Dr. Schubert’s extensive doping expertise, Petitioner now
`
`for the first time asserts that Dr. Schubert does not have experience with LOCOS
`
`isolation or STI. Paper 29, p. 5.
`
`
`
`As noted above, Petitioner never challenged Dr. Schubert’s expertise in
`
`LOCOS/trench isolation, so there was no reason to further amplify/supplement the
`
`description of Dr. Schubert’s expertise in this area. If this Motion to Exclude as to
`
`Dr. Schubert is not otherwise stricken, Patent Owner notes the following.
`
`
`
`At ¶¶17- 22 of his Declaration (Exhibit 2012), Dr. Schubert describes a
`
`career totally devoted to research, development and academic work in the field of
`
`Si IC devices. Had an objection been filed as to his qualifications specifically
`
`regarding LOCOS/STI isolation, he would additionally have explained:
`
`•
`
`In the period (1985-1987 and 1989-1995, and at the present time for
`
`educational purposes), he designed, fabricated, and analyzed Si ICs that employed
`
`LOCOS isolation.
`
`•
`
`Starting in the early to mid-1990s, he designed, fabricated, and
`
`analyzed Si IC devices that employed trench isolation.
`
`
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`A particular research effort of his included the design, fabrication, and
`
`analysis of porous oxides employed for trench isolation. He developed the theory
`
`that explains the degree of porosity of porous silica (SiO2) deposited by PVD
`
`(physical vapor deposition). His research effort in porous silica had the purpose of
`
`decreasing parasitic capacitances associated with device trench isolation and
`
`device interconnection.
`
`
`
`At his deposition, Petitioner sought to explore this issue (very briefly) for the
`
`period 1989-1996. Dr. Schubert stated:
`
`And I personally had awareness of the various issues that are
`
`encountered with LOCOS isolation and trench isolation. […]
`
`We worked with various structures, including LOCOS isolation
`
`and shallow trench isolations.
`
`Exhibit 1056, 70:12-14; 71:21 – 72:1.
`
`
`
`Reference is made to Dr. Schubert’s CV, which specifically lists the
`
`following projects, in which he or members of his team worked with LOCOS/STI
`
`during the 1985-1996 timeframe:
`
`Demonstration of the spatial localization of dopants within 20
`
`Å for a number of doping elements in delta-doped
`
`semiconductors including GaAs and Si for MESFET and
`
`MOSFET applications and the analysis of delta-doped
`
`structures by SIMS (secondary ion mass spectrometry) (with
`
`colleague Henry S. Luftman, 1983-1995)
`
`
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`Case IPR2016-01246 for
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`
`
`Exhibit 2012, p. 214.
`
`Demonstration of delta doping in silicon for the fabrication of
`
`shallow junctions in scaled-down Si MOSFETs for integrated
`
`circuits (Si ICs) (with colleague Dr. H. J. Gossmann, 1990 –
`
`1995)
`
`
`
`Exhibit 2012, p. 214.
`
`Both projects included the design, fabrication and analysis of LOCOS
`
`isolation as well as trench isolation. The projects included the complete fabrication
`
`of Si ICs (silicon integrated circuits) in the so-called "Blue Zoo" fabrication facility
`
`in Murray Hill NJ; the Si IC circuits contained LOCOS isolation features in the
`
`earlier years and both LOCOS isolation and trench isolation in the later years of
`
`the time frame 1985 to 1995. Isolation features are always a necessary ingredient
`
`in Si ICs. Dr. Schubert designed experiments, and designed the Si ICs including
`
`the LOCOS isolation and trench isolation features. Si IC fabrication is always a
`
`team effort and includes a number of people. In these projects, he was the driving
`
`force and technical project leader.
`
`
`
`For the above reasons, Dr. Schubert is most eminently qualified to testify as
`
`to issues involving LOCOS/STI during the 1985-1996 timeframe.
`
`
`
`
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`Case IPR2016-01246 for
`U.S. Patent No. 7,126,174
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`
`
`II.
`
`
`
`
`
`PATENT OWNER’S EXHIBITS 2002-2010, 2013-2019, 2026-2030,
`2032, AND 2033 ARE NOT IRRELEVANT AND NON-PROBATIVE
`EVIDENCE.
`
`A. Exhibits 2002, 2003, 2004, 2032, and 2033
`
`These Exhibits are relevant to the issue of the “polishing step,” which was
`
`argued in Patent Owner’s Response (Paper 14), and which relates to the
`
`planarization which would take place if the Lowrey device were substituted with a
`
`trench isolation of Noble/Ogawa. They are directly relevant to the Petition, at least
`
`as to the difficulties of substituting a trench into Lowrey. They are intended to
`
`show how the planarization step associated with substitution of a trench would be
`
`detrimental to the Lowrey device, thus teaching away from insertion of a trench.
`
`Petitioner points to the fact that because the claims are “device structure
`
`claims”, the steps leading up to the final device are irrelevant. If the steps leading
`
`up to the final device are unworkable or inadvisable a POSITA would not have
`
`been motivated to perform those steps to arrive at the device, and the device itself
`
`would not have been obvious.
`
`Although Exhibits 2002, 2003 and 2004 postdate the filing date of the ‘174
`
`patent, if anything, they are all the more relevant in that even as of a later date
`
`these processes (which were presumably more advanced) still are being relied upon
`
`
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`Case IPR2016-01246 for
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`to show the difficulties in performing a CMP polishing as of the date of invention
`
`if a trench were to be substituted into Lowrey.
`
`B.
`
`
`
`Exhibits 2005, 2006, 2007, 2008, 2009, and 2010
`
` These exhibits were cited to confirm the obvious, i.e., that semiconductor
`
`manufacture is highly complex. Petitioner twice adopted the position that
`
`complexity is not an issue in this case by stating: “[T]he complexity of IC
`
`fabrication and the technical community’s recognition of that premise are not at
`
`issue in these proceedings.” Paper 13, p. 7; Paper 16, p. 6. They no longer seem to
`
`be asserting this, but these documents were made exhibits to attest to this most
`
`obvious fact.
`
`These exhibits were referenced to justify the need to illustrate how a device
`
`is made, given the complexity of Si IC fabrication, a final picture or drawing is not
`
`enough. The fact that the Exhibits do not specifically mention STI or LOCOS is
`
`meaningless. Trench and LOCOS are just one aspect of an overall highly complex
`
`technology; a change anywhere can affect the whole device.
`
`C. Exhibits 2013, 2014, 2015, 2016, 2017, 2018, and 2019
`
`
`
`These exhibits too were further cited to confirm the obvious, i.e., that
`
`semiconductor manufacture is highly complex. Petitioner twice adopted the
`
`position that complexity is not an issue in this case by stating: “[T]he complexity
`
`of IC fabrication and the technical community’s recognition of that premise are not
`
`
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`Case IPR2016-01246 for
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`at issue in these proceedings.” Paper 13, p. 7; Paper 16, p. 6. They no longer seem
`
`to be asserting this, but these documents were made exhibits to attest to this most
`
`obvious fact.
`
` These exhibits were referenced to justify the need to illustrate how a device
`
`is made, given the complexity of Si IC fabrication, a final picture or drawing is not
`
`enough. The fact that the Exhibits do not specifically mention STI or LOCOS is
`
`meaningless. Trench and LOCOS are just one aspect of an overall highly complex
`
`technology.
`
`D. Exhibit 2026
`
`All claims of the ‘174 patent relate to L-shaped sidewalls. Patent Owner has
`
`proposed a claim definition of L-shaped which is “a sidewall substantially
`
`resembling a capital ‘L’ or a mirror image thereof”. Response, Paper 14, pp. 41-42.
`
`Dr. Banerjee agrees. He says: “looks like the letter ‘L’.” Exhibit 2078, 272:20 -
`
`21.
`
`Such being the case, whether the combined layers of Lowrey can be seen or
`
`visualized to include an “L” is fundamental to determining whether there would be
`
`an L-shaped element in the actual device of Lowrey. The problem is that Lowrey
`
`teaches two nested sidewalls, which appear to include one L-shaped sidewall, but
`
`when the two sidewalls are combined as Lowrey does, they become a single
`
`element, which is not L-shaped. The question is whether using standard
`
`
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`Case IPR2016-01246 for
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`visualization means layer 81 could be imaged to an extent that an individual L-
`
`shaped layer could be visualized.
`
`Dr. Schubert pointed to SEM technology as being commonly used to
`
`visualize such structures and said that an SEM device would be unable to visualize
`
`any L-shape in Lowrey. Exhibit 2012, ¶¶384 - 386. Dr. Schubert cited this exhibit
`
`merely to establish that SEM was a standard microscopic assessment technique in
`
`1995.
`
`Exhibit 2026 has been cited in support of the use of SEM technology as a
`
`standard imaging technique for visualizing such sidewalls upon which Dr.
`
`Schubert is entitled to rely upon as an Expert under Fed. R. Evid. 703. The Exhibit
`
`should not be excluded.
`
`E.
`
`Exhibits 2027, 2028, 2029, and 2030
`
`
`
`All claims of the ‘174 patent relate to L-shaped sidewalls. Patent Owner has
`
`proposed a claim definition of L-shaped which is a sidewall substantially
`
`resembling a capital “L” or a mirror image thereof. Response, Paper 14, pp. 41-42.
`
`Petitioner’s Dr. Banerjee agrees. He says: “looks like the letter ‘L’.” Exhibit 2078,
`
`272:20-21.
`
`Such being the case, whether the combined layers of Lowrey can be seen or
`
`visualized to include an “L” is fundamental to determining whether there would be
`
`an L-shaped element in the actual device of Lowrey. The problem is that Lowrey
`
`
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`Case IPR2016-01246 for
`U.S. Patent No. 7,126,174
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`teaches two nested sidewalls, which appear to include one L-shaped, but when the
`
`two sidewalls are combined as Lowrey does, they become a single element, which
`
`is not L-shaped. The question is whether using standard visualization means layer
`
`81 could be imaged to an extent that an individual L-shaped layer could be
`
`visualized.
`
`Dr. Schubert pointed to SEM technology as being commonly used to
`
`visualize such structures, and said that an SEM device would be unable to visualize
`
`any L-shape in Lowrey. Exhibit 2012, ¶¶384-386. Dr. Schubert cited these Exhibits
`
`merely to establish that SEM was a standard microscopic assessment technique in
`
`1995. Dr. Schubert is entitled to rely upon Exhibit 2026 as an Expert under Fed. R.
`
`Evid. 703. The Exhibit should not be excluded.
`
`
`III. PATENT OWNER’S EXHIBITS 2003, 2004, AND 2026 SHOULD NOT
`
`BE EXCLUDED AS HEARSAY
`
`
`A. EXHIBITS 2003 AND 2004
`
`Exhibits 2003 and 2004 are admissible because they are not hearsay; they
`
`are not being relied upon for the truth of the matter being asserted in these
`
`publications.
`
`
`
`Patent Owner relies upon Exhibit 2003 at ¶61 and n. 5 of Exhibits 2001 and
`
`2011, and at ¶68 and n. 7 of Ex. 2012.
`
`
`
`
`
`Exhibit 2003 was downloaded by Dr. Schubert and shows a copyright date
`
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`Case IPR2016-01246 for
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`of 2000. As an Expert, Dr. Schubert is entitled to point to and rely upon these
`
`Exhibits under Fed. R. Evid. 703.
`
`
`
`Yet further, Dr. Schubert is entitled to rely upon both these depictions of a
`
`polishing process under the residual exception of Fed. R. Evid. 807 because Dr.
`
`Schubert, who was available for cross-examination, found the image instructive,
`
`trustworthy, and probative of a material fact. Admitting the document is in the
`
`interest of justice.
`
`
`
` Patent Owner is relying upon Exhibit 2004, which is a pictorial
`
`representation of what is shown in Exhibits 2032 and 2033. It is not being relied
`
`upon to prove any specific feature, other than to generally pictorially represent
`
`what polishing is with an actual device, and as such is not hearsay. Exhibits 2032
`
`and 2033 are texts, which are relevant because they show the polishing techniques
`
`slightly before the time of the invention, and help to establish that polishing would
`
`be detrimental to the Lowrey substitution being proposed by Petitioner.
`
`Exhibit 2026
`
`B.
`
`Exhibit 2026 is a three-part series of Exhibits cited by Dr. Schubert in ¶385
`
`
`
`of Exhibit 2012 to establish that SEM is a standard visualization technique for
`
`visualizing the structure semiconductor devices, such as that depicted by Lowrey. It
`
`is not being relied upon to establish that the contents of the image are accurate, but
`
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`Case IPR2016-01246 for
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`rather merely to show that SEM is to this day a standard visualization technique.
`
`As such, it is not hearsay.
`
`
`
`Yet further, Dr. Schubert is entitled to rely upon this depiction of an SEM
`
`image under the residual exception of Fed. R. Evid. 807 because Dr. Schubert, who
`
`was available for cross-examination, found the image instructive, trustworthy, and
`
`probative of a material fact. Admitting the document is in the interest of justice.
`
`Dated: July 26, 2017
`
`
`
`
`
` Respectfully submitted:
`
`
`
`
`/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
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`{J709902 03187297.DOC}
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`Case IPR2016-01246 for
`U.S. Patent No. 7,126,174
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`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true copy of the foregoing:
`
`PATENT OWNER’S OPPOSITION TO
`PETITIONER’S MOTION TO EXCLUDE EVIDENCE
`
`was served by electronic mail on this 26th day of July, 2017, upon Counsel for
`
`Petitioner, as follows:
`
`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 Cooper (kent.cooper@kjcooperlaw.com); and
`Adam Floyd (floyd.adam@dorsey.com).
`
`
`
`
`
`/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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