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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`Petitioner,
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`v.
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`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
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`Case IPR2016-01246†
`Patent 7,126,174 B2
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`JOINT LIST OF OBJECTIONS TO DEMONSTRATIVES
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`† Case IPR2016-01247 has been consolidated with this proceeding.
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`Petitioner objects to Patent Owner’s slides 8, 9, 66, 68-71, 91, 92 and 124.
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`Slides 66, 68 and 69 incorrectly show processes Petitioner suggested for putting
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`STI into Lowrey by forming the channel-stop before etching the trench. Compare
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`Phases I–III, with Paper 21, at 21. In addition, slides 66 and 69 represent a new
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`position not in any exhibit or paper filed. Slides 8, 9, 66, 68-71, 91, and 92 merely
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`cite the Sur-Reply and only contain attorney argument, not evidence, and do not
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`respond to the Reply. Slides 8 and 9 discuss diffusion, and slides 91 and 92
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`discuss photolithography, both of which could have been in the Response. Slide
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`124 only has part of a speech by Patent Owner’s attorney during a deposition, with
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`no witness testimony.
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`Patent Owner objects to all of Petitioner’s slides because they are in the
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`form of a brief with dividers and banners that present a narrative. This violates the
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`PTAB’s Order (Paper 28), which states, “No further briefing ….”, e.g., see
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`Petitioner’s Slides 30, 40, 42, 62, 67, 75, 81, 83, 95, 106 and 113. Slides 9-10, 13,
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`24-25, 30, 32-33 35-37, 41, 60-65, 67, 69, 71, 77, 82, 88, 95, 106-107, 109, 113,
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`118, 121-122, 129-130, and 132 contain attorney argument in the body of the
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`slide. Slides 31 and 33 contain new arguments not in the Petition. Slides 89, 95,
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`116, 122 improperly cite to or lack a cite to the record. Slide 106 is factually
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`incorrect and misrepresents the process sequence of Lowrey with Noble/Ogawa.
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`Although not mentioned, issues raised in the Motions to Exclude are preserved.
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`Respectfully submitted,
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`By: /Darren M. Jiron/
`Darren M. Jiron
`Reg. No. 45,777
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`Lead Counsel for Petitioner
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`Dated: August 3, 2017
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`By: /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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`Lead Counsel for Patent Owner
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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 JOINT LIST OF OBJECTIONS TO DEMONSTRATIVES
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`by electronic mail, on this 3rd day of August, 2017, on counsel of record for the
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`Patent Owner as follows:
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`Neil F. Greenblum
`ngreenblum@gbpatent.com
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`Michael J. Fink
`mfink@gbpatent.com
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`Arnold Turk
`aturk@gbpatent.com
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`Dated: August 3, 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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