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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Taiwan Semiconductor Manufacturing Company, Limited
`Petitioner
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`v.
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`Godo Kaisha IP Bridge 1
`Patent Owner
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`Case IPR2016-01249
`Patent No. 6,538,324
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`PETITIONER’S OBJECTIONS TO PATENT OWNER’S EXHIBITS 2008-2042
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioner objects to the following
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`Case IPR2016-01249
`Patent 6,538,324
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`Patent Owner exhibits:
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`2014
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`2015
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`2016
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`2017
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`2018
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`2019
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`2020
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`2021
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`2022
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`2023
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`2024
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`2025
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`2026
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`2027
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`2028
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`2029
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`2030
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`JP H08-139092A.
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`English translation of JP H08-139092A.
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`JP H08-250596A.
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`English translation of JP H08-250596A.
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`JP H08-274098A.
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`English translation of JP H08-274098A.
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`JP H09-64044A.
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`English translation of JP H09-64044A.
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`JP H09-293690A.
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`English translation of JP H09-293690A.
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`JP H10-125627A.
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`English translation of JP H10-125627A.
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`JP H10-256256A.
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`English translation of JP H10-256256A.
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`JP H10-330938A.
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`English translation of JP H10-330938A.
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`JP H11-67686A.
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`1
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`English translation of JP H11-67686A.
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`Case IPR2016-01249
`Patent 6,538,324
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`D. Denning, et al., “An Inlaid CVD Cu Based Integration for
`Sub 0.25μm Technology.” 1998 Symposium on VLSI
`Technology Digest of Technical Papers, 1998, pp. 22-23.
`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.
`N. Awaya, “Semiconductor World.” Feb. 1998, pp. 91-96
`(“Awaya”).
`English translation of Awaya.
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`Declaration of Harlan Rusty Harris, Ph.D. in Support of Patent
`Owner’s Motion to Amend.
`U.S. Patent No. 6,346,745 to Nogami et al.
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`U.S. Patent No. 6,156,647 to Hogan.
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`U.S. Patent No. 6,139,699 to Chiang et al.
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`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).
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`2031
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`2032
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`2033
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`2034
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`2035
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`2037
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`2039
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`2040
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`2041
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`2042
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`I.
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`Exhibit 2037
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`Petitioner objects to Exhibit 2037 under FRE 702 because the opinions do
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`not disclose the underlying facts or data on which the opinions are based. See 37
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`C.F.R. § 42.65. For example, Dr. Harris opines that Exhibits 2014-2027, 2030-
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`2035, 2039, and 2040 do not anticipate or render obvious substitute claims, but he
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`provides no citations to any of the those exhibits.
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`2
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`II. Exhibits 2014-2035 and 2039-2042
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`Case IPR2016-01249
`Patent 6,538,324
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`Petitioner objects to Exhibits 2015, 2017, 2019, 2021, 2023, 2025, 2027,
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`2029, 2031, and 2035 for lack of authentication under FRE 901 and for unverified
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`English translations under FRE 604 and 37 C.F.R. § 42.63(b) because these
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`exhibits are alleged translations of Exhibits 2014, 2016, 2018, 2020, 2022, 2024,
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`2026, 2028, 2030, and 2034, but there is insufficient evidence to support a finding
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`that these exhibits are true and accurate translations by qualified translators.
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`Exhibits 2017, 2023, 2025, 2027, and 2035 were certified by a
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`sales/marketing representative rather than a person who performed the alleged
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`English-language translation. The manner in which these documents were prepared
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`is unknown and these translations are unreliable.
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`Exhibits 2015, 2019, 2021, 2029, and 2031 include verifications by different
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`translators, who only attest to accurate translations “to the best of my knowledge
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`and ability” without further specifying their credentials. One alleged translator is a
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`paralegal of Patent Owner’s counsel, Ex. 2038, ¶ 1, and no other credentials have
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`been provided for these translators. Patent Owner does not contend these exhibits
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`are “certified” translations of their corresponding Japanese patents.
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`Petitioner objects to Exhibits 2014, 2016, 2018, 2020, 2022, 2024, 2026,
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`2028, 2030, and 2034, and 2039-2042 under FRE 403 because they are irrelevant.
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`Any relevance of these exhibits depend on the accuracy of the English translations
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`3
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`in Exhibits 2015, 2017, 2019, 2021, 2023, 2025, 2027, 2029, 2031, and 2035. As
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`Case IPR2016-01249
`Patent 6,538,324
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`explained above, because sufficient proof has not been introduced to support a
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`finding that the English translations are accurate, Exhibits 2014, 2016, 2018, 2020,
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`2022, 2024, 2026, 2028, 2030, and 2034 are irrelevant. Additionally, Patent
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`Owner’s Response or Contingent Motion to Amend does not cite these exhibits.
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`Petitioner objects to Exhibit 2039-2041 under FRE 403 as irrelevant because
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`Dr. Harris does not state that he has reviewed Exhibits 2039-2041.
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`To the extent Patent Owner relies on the bibliographic information on page 1
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`of Exhibit 2042 for the truth of the information provided in this exhibit, Petitioner
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`objects to it as inadmissible hearsay. FRE 802.
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`Respectfully submitted,
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` By: /Stephen E. Kabakoff/
` Stephen E. Kabakoff
` Reg. No. 51,276
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`Dated: March 14, 2017
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`4
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`CERTIFICATE OF SERVICE
`This is to certify under 37 C.F.R. § 42.6(e) that, on this 14th day of March
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`Case IPR2016-01249
`Patent 6,538,324
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`2017, I caused counsel of record for the Patent Owner (as listed below) to be
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`electronically served a true and correct copy of the “PETITIONER’S
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`OBJECTIONS TO PATENT OWNER’S EXHIBITS 2008-2042.”
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`Michael Fink
`mfink@gbpatent.com
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`Neil Greenblum
`ngreenblum@gbpatent.com
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`Arnold Turk
`aturk@gbpatent.com
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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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`Dated: March 14, 2017
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