`
`Filed on behalf of Godo Kaisha IP Bridge 1
`
`By: Michael J. Fink (mfink@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 LIMITED,
`Petitioner,
`
`v.
`
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`____________
`
`Case IPR2016-01249
`U.S. Patent No. 6,538,324
`____________
`
`DECLARATION OF RUMIKO WHITEHEAD
`
`
`
`Mail Stop PATENT BOARD, PTAB
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`Page 1 of 7
`
`IP Bridge Exhibit 2038
`TSMC v. IP Bridge
`IPR2016-01249
`
`
`
`
`
`Case IPR2016-01249
`for U.S. Patent No. 6,538,324
`
`
`I, Rumiko Whitehead, declare as follows:
`
`1.
`
`2.
`
`I am a paralegal at the law firm of Greenblum & Bernstein, P.L.C.
`
`I provide this Declaration in connection with the above-identified
`
`Inter Partes Review proceeding.
`
`3.
`
`Exhibit 2001 is a true copy of Chang, C.C., Chen, J.S. and Hsu, W.S.,
`
`“Failure Mechanism of Amorphous and Crystalline Ta-N Films in the Cu/Ta
`
`N/Ta/SiO2 Structure.” Journal of The Electrochemical Society, 151(11), pp.G746-
`
`G750 (2004). I added an exhibit label and pagination labels.
`
`4.
`
`Exhibit 2003 is a true copy of a dictionary definition of “amorphous”
`
`from Merriam-Webster.com., which I downloaded from http://www.merriam-
`
`webster.com/ dictionary/amorphous on September 30, 2016. I highlighted the
`
`word “amorphous.” I added an exhibit label and pagination labels.
`
`5.
`
`Exhibit 2004 is a true copy of a dictionary definition of “nitride” from
`
`Merriam-Webster.com which I downloaded from http://www.merriam-
`
`webster.com/ dictionary/nitride on September 30, 2016. I highlighted the word
`
`“nitride.” I added an exhibit label and pagination labels
`
`6.
`
`Exhibit 2008 is a true copy of excerpts from a dictionary, Guralnik, D.
`
`B., ed., Webster’s New World Dictionary of the American Language, Prentice Hall
`
`Press (1979). I scanned the title page, copyright page, and page 16 of the
`
`dictionary, and then added an exhibit label and pagination labels. I also
`
`1
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`Page 2 of 7
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`
`
`Case IPR2016-01249
`for U.S. Patent No. 6,538,324
`
`
`highlighted the word “amorphous”. The copyright page indicates that the
`
`copyright years of the dictionary are 1976 and 1979.
`
`7.
`
`Exhibit 2009 is a true copy of excerpts from a dictionary, Grant, J.,
`
`ed., Hackh’s Chemical Dictionary, 4th ed., McGraw-Hill (1969). I scanned the
`
`title page, copyright page, and page 457 of the dictionary, and then added an
`
`exhibit label and pagination labels. I also highlighted the definition of “nitride”.
`
`The copyright page indicates that the copyright year of the dictionary is 1969.
`
`8.
`
`Exhibit 2010 is a copy of Sienko, M.J., Plane, R.A. Chemistry. 2d ed.
`
`New York, McGraw-Hill, 1961, pp. 193-195. Print. I scanned the cover, title page,
`
`copyright page, and pages 192-195, and then added an exhibit label and pagination
`
`labels. The copyright page indicates that the copyright year of the dictionary is
`
`1961.
`
`9.
`
`Exhibit 2012 is a true copy of an excerpt from the USPTO Manual of
`
`Patent Examining Procedure (MPEP), Section 2111 Claim Interpretation; Broadest
`
`Reasonable Interpretation [R-07.2015], Subsection 2111.03 Transitional Phrases
`
`[R-08.2012], which I downloaded from https://www.uspto.gov/web/offices/pac/mp
`
`ep/index.html. I added an exhibit label and pagination labels.
`
`10. Exhibit 2013 is a true copy of the Claim Construction Memorandum
`
`And Order, November 9, 2016, pp. 31-32 (Godo Kaisha IP Bridge 1 v. Broadcom
`
`2
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`Page 3 of 7
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`
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`Case IPR2016-01249
`for U.S. Patent No. 6,538,324
`
`
`Limited et al., USDC EDTEX 2:16-cv-00134-JRG-RSP). I added an exhibit label
`
`and pagination labels.
`
`11. Exhibit 2014 is a true copy of JP H08-139092A downloaded from the
`
`European Patent Office’s Espacenet Patent Search website. I added an exhibit
`
`label and pagination labels.
`
`12. Exhibit 2015 is a verified English translation of JP H08-139092A. I
`
`added an exhibit label and pagination labels.
`
`13. Exhibit 2016 is a true copy of JP H08-250596A downloaded from the
`
`European Patent Office’s Espacenet Patent Search website. I added an exhibit
`
`label and pagination labels.
`
`14. Exhibit 2017 is a verified English translation of JP H08-250596A. I
`
`added an exhibit label and pagination labels.
`
`15. Exhibit 2018 is a true copy of JP H08-274098A downloaded from the
`
`European Patent Office’s Espacenet Patent Search website. I added an exhibit label
`
`and pagination labels.
`
`16. Exhibit 2019 is a verified English translation of JP H08-274098A. I
`
`added an exhibit label and pagination labels.
`
`17. Exhibit 2020 is a true copy of JP H09-64044A downloaded from the
`
`European Patent Office’s Espacenet Patent Search website. I added an exhibit
`
`label and pagination labels.
`
`3
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`Page 4 of 7
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`
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`18. Exhibit 2021 is a verified English translation of JP H09-64044A. I
`
`
`
`Case IPR2016-01249
`for U.S. Patent No. 6,538,324
`
`
`added an exhibit label and pagination labels.
`
`19. Exhibit 2022 is a true copy of JP H09-293690A downloaded from the
`
`European Patent Office’s Espacenet Patent Search website. I added an exhibit
`
`label and pagination labels.
`
`20. Exhibit 2023 is a verified English translation of JP H09-293690A. I
`
`added an exhibit label and pagination labels.
`
`21. Exhibit 2024 is a true copy of JP H10-125627A downloaded from the
`
`European Patent Office’s Espacenet Patent Search website. I added an exhibit
`
`label and pagination labels.
`
`22. Exhibit 2025 is a verified English translation of JP H10-125627A. I
`
`added an exhibit label and pagination labels.
`
`23. Exhibit 2026 is a true copy of JP H10-256256A downloaded from the
`
`European Patent Office’s Espacenet Patent Search website. I added an exhibit
`
`label and pagination labels.
`
`24. Exhibit 2027 is a verified English translation of JP H10-256256A. I
`
`added an exhibit label and pagination labels.
`
`25. Exhibit 2028 is a true copy of JP H10-330938A downloaded from the
`
`European Patent Office’s Espacenet Patent Search website. I added an exhibit
`
`label and pagination labels.
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`4
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`Page 5 of 7
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`
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`26. Exhibit 2029 is a verified English translation of JP H10-330938A. I
`
`
`
`Case IPR2016-01249
`for U.S. Patent No. 6,538,324
`
`
`added an exhibit label and pagination labels.
`
`27. Exhibit 2030 is a true copy of JP H11-67686A downloaded from the
`
`European Patent Office’s Espacenet Patent Search website. I added an exhibit
`
`label and pagination labels.
`
`28. Exhibit 2031 is a verified English translation of JP H11-67686A. I
`
`added an exhibit label and pagination labels.
`
`29. Exhibit 2032 is a true copy of D. Denning, et al., “An Inlaid CVD Cu
`
`Based Integration for Sub 0.25mum Technology.” 1998 Symposium on VLSI
`
`Technology Digest of Technical Papers, 1998, pp. 22-23. I added an exhibit label
`
`and pagination labels.
`
`30. Exhibit 2033 is a true copy of K. Kwon et al., “Characteristics of Ta
`
`As An Underlayer for Cu Interconnects.” Advanced Metallization and Interconnect
`
`Systems for ULSI Applications in 1997, 1998, pp. 711-716. I added an exhibit
`
`label and pagination labels.
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`31. Exhibit 2034 is a true copy of N. Awaya, “Semiconductor World.”
`
`Feb. 1998, pp. 91-96 (“Awaya”). I added an exhibit label and pagination labels.
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`32. Exhibit 2035 is a verified English translation of Awaya. I added an
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`exhibit label and pagination labels.
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`33. Exhibit 2036 is a true copy of excerpts from a dictionary, Grant, J.,
`
`5
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`Page 6 of 7
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`
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`Case IPR2016-01249
`for U.S. Patent No. 6,538,324
`
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`ed., Hackh’s Chemical Dictionary, 4th ed., McGraw-Hill (1969). I scanned the
`
`title page, copyright page, and page 623 of the dictionary, and then added an
`
`exhibit label and pagination labels. I also highlighted the definition of “solid
`
`solution.” The copyright page indicates that the copyright year of the dictionary is
`
`1969.
`
`34. Exhibit 2042 is a true copy of Min, K. H. et al., “Comparative study
`
`of tantalum and tantalum nitrides (Ta2N and TaN) as a diffusion barrier for Cu
`
`metallization.” Journal of Vacuum Science & Technology B: Microelectronics and
`
`Nanometer Structures Processing, Measurement, and Phenomena, 14(5), pp. 3263-
`
`3269 (1996). I added an exhibit label and pagination labels.
`
` I
`
` declare that all statements made herein of my knowledge are true, and that
`
`all statements made on information and belief are believed to be true, and that
`
`these statements were made with the knowledge that willful false statements and
`
`the like so made are punishable by fine or imprisonment, or both, under Section
`
`1001 of Title 18 of the United States Code.
`
`
`
`
`
`
` March 7, 2017
`Date
`
`
`
`
`
`
`
`By:
`
`/Rumiko Whitehead /
`Rumiko Whitehead
`
`
`
`6
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`Page 7 of 7
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`
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