` ___________
` 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 Nos. IPR2016-01249 and IPR2016-01264
` U.S. Patent No. 6,538,324
` __________
` GlobalFoundries U.S. Inc.’s motions for joinder
`in Cases IPR2017-00919,-00920 were granted.
`
` DEPOSITION OF SANJAY K. BANERJEE, Ph.D.
` Washington, D.C.
` Tuesday, June 13, 2017
` 8:58 a.m.
`
`Job No.: 147285
`Pages 1 - 129
`Reported By: Joan V. Cain
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`IP Bridge Exhibit 2044
`TSMC v. IP Bridge
`IPR2016-01249
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`Transcript of Sanjay K. Banerjee, Ph.D.
`Conducted on June 13, 2017
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`2
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` Deposition of SANJAY K. BANERJEE, Ph.D., held
`at the law offices of:
`
` FINNEGAN HENDERSON FARABOW
` GARRETT & DUNNER, LLP
` 901 New York Avenue, Northwest
` Washington, D.C. 20001-4413
` (202) 408-4000
`
` Pursuant to Notice, before Joan V. Cain,
`Court Reporter and Notary Public in and for the
`District of Columbia.
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`3
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` A P P E A R A N C E S
`
`ON BEHALF OF PETITIONER:
` STEPHEN E. KABAKOFF, ESQUIRE
` SHAWN S. CHANG, ESQUIRE
` FINNEGAN HENDERSON FARABOW
` GARRETT & DUNNER, LLP
` 271 17th Street, Northwest
` Suite 1400
` Atlanta, Georgia 30363-6209
` Telephone: (404) 653-6400
` E-mail: stephen.kabakoff@finnegan.com
` shawn.chang@finnegan.com
`
`ON BEHALF OF CO-PETITIONER GLOBALFOUNDRIES:
` ALLEN WANG, ESQUIRE (By Telephone)
` WHITE & CASE SILICON VALLEY
` 3000 El Camino Real 5 Palo Alto Square
` 9th Floor
` Palo Alto, California 94306
` Telephone: (650) 213-0314
` E-mail: awang@whitecase.com
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` A P P E A R A N C E S C O N T I N U E D
`
`ON BEHALF OF PATENT OWNER:
` MICHAEL J. FINK, ESQUIRE
` NEIL F. GREENBLUM, ESQUIRE (By Telephone)
` ARNOLD TURK, ESQUIRE (By Telephone)
` GREENBLUM & BERNSTEIN, P.L.C.
` 1950 Roland Clarke Place
` Reston, Virginia 20191
` Telephone: (703) 716-1191
` E-mail: mfink@gbpatent.com
` rwhitehead@gbpatent.com
` aturk@gbpatent.com
`
`ALSO PRESENT:
` Willy Chang, Esquire, TSMC
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`Conducted on June 13, 2017
` C O N T E N T S
`
`5
`
`EXAMINATION OF SANJAY K. BANERJEE, Ph.D., PAGE
` By Mr. Fink 7, 121
` By Mr. Kabakoff 117
`
` E X H I B I T S
` (Attached to the Transcript.)
`IP BRIDGE EXHIBITS PAGE
`EXHIBIT 2043 Photocopied Pages from Hackh's 80
` Chemical Dictionary
`
` P R E V I O U S L Y M A R K E D E X H I B I T S
` (Attached to the Transcript.)
`TSMC EXHIBITS PAGE
`EXHIBIT 1001 US Patent No. 6,538,324 B1 32
`EXHIBIT 1003 Declaration of Dr. Banerjee in 26
` Support of Petition for Inter
` Partes Review of US Patent
` No. 6,538,324
`EXHIBIT 1005 Declaration of Dr. Banerjee in 21
` Support of Petition for Inter
` Partes Review of US Patent
` No. RE41,980
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`Conducted on June 13, 2017
` P R E V I O U S L Y M A R K E D E X H I B I T S
` C O N T I N U E D
` (Attached to the Transcript.)
`TSMC EXHIBITS PAGE
`EXHIBIT 1033 US Patent No. 6,458,255 B2 102
`EXHIBIT 1038 Declaration of Dr. Banerjee in 10
` Support of Petitioner's Reply
` to Patent Owners Response and
` Opposition to Motion to Amend
` for Inter Partes Review of
` US Patent No. 6,538,324
`
` P R E V I O U S L Y M A R K E D E X H I B I T S
` (Attached to the Transcript.)
`IP BRIDGE EXHIBITS PAGE
`EXHIBIT 2012 Excerpt from the Manual of 48
` Patent Examining Procedure,
` Original Ninth Edition
`EXHIBIT 2013 Claim Construction Memorandum 114
` and Order
`EXHIBIT 2036 Photocopied Pages from Hackh's 76
` Chemical Dictionary
`EXHIBIT 2039 US Patent No. 6,346,745 B1 85
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` P R O C E E D I N G S
` SANJAY K. BANERJEE, Ph.D.
`having been duly sworn under penalties of perjury,
`was examined and did testify as follows:
` EXAMINATION BY COUNSEL FOR PATENT OWNER
`BY MR. FINK:
` Q Good morning, Dr. Banerjee.
` A Good morning.
` Q Did I pronounce your name correctly?
` A Yes.
` Q You understand that you've submitted
`declarations in the IPRs that we're deposing you
`about today?
` A Yes.
` Q Okay. Have you ever been deposed before?
` A Yes.
` Q In what context?
` A Several ITC cases, a District case, and I
`think -- I've done several IPRs, and I think I've
`been deposed in those. I can't remember exactly.
` MR. TURK: Arnold Turk.
` MR. FINK: Arnold Turk's from my firm.
`Arnie, mute your line. Okay?
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` MR. TURK: All right.
` MR. FINK: All right. Just keep your
`line -- are you there?
` MR. TURK: Yeah.
` MR. FINK: Okay. Can you mute your line?
`Neil and Allen --
` MR. TURK: I'm going to mute.
` MR. FINK: Okay. Neil is on the line and
`Allen Wang from GlobalFoundries is also on the line.
` MR. TURK: Okay. Thanks.
`BY MR. FINK:
` Q How many IPRs have you submitted expert
`declarations in?
` A About half a dozen probably, so I've done
`two on -- with this case -- well, I've done two
`declarations for this patent and then I guess one
`for the '174 patent, and then I'm working with other
`firms that I've done five more.
` Q Is that it?
` A In the past also I believe I've done a few
`IPRs. I can't remember exactly.
` Q How many IPRs are you working on where TSMC
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`is the petitioner?
` A Two.
` Q Presently?
` A Yes.
` Q That's the --
` A '174.
` Q Patent and the '324 patent?
` A '174 and '324, yes.
` Q And did you previously submit a declaration
`relating to the reissued '980 patent?
` A The number rings a bell. I cannot remember
`exactly. I believe I did, but I can't remember
`offhand.
` Q And are you presently involved in any other
`IPR proceedings for petitioners other than TSMC?
` A Yes.
` Q And who is that for? Who is the
`petitioner?
` A Micron.
` Q Any others?
` A Currently, no.
` Q Did you submit a declaration in support of
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`a petition filed by GlobalFoundries?
` A Yes. Yeah. So what happened was -- yeah.
`So Global joined Micron -- see, initially, I started
`with Micron, but then Global decided to join Micron
`on two patents. I remember that.
` Q Do you remember what patents?
` A They were related to an atomic layer
`deposition by Professor Gordon from Harvard. I
`don't recall the patent numbers offhand.
` Q Were any of the patents owned by IP Bridge?
` A No.
` MR. KABAKOFF: Objection, relevance.
` (IP Bridge Exhibit 1038 was
`previously marked for identification and was
`attached to the deposition transcript.)
`BY MR. FINK:
` Q I'd like to give you a copy of your
`declaration in support of petitioner's reply in the
`opposition to motion to amend, which has previously
`been marked Exhibit 1038.
` Do you recognize this exhibit?
` A Yes.
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` Q And that's your signature at the last page
`of the exhibit?
` A Yes.
` Q How did you prepare this declaration?
` MR. KABAKOFF: Objection to form.
` THE WITNESS: Well, I had multiple form
`meetings with the lawyers, and this -- these are my
`opinions, and I wrote parts of it, and parts of it
`the lawyers wrote under my direction.
`BY MR. FINK:
` Q Which parts did you write?
` A A lot of the sections related to the
`technical discussions I wrote.
` Q Okay.
` A It was a collaborative effort, so the legal
`parts the lawyers provided in terms of legal
`standards and things like that.
` Q Did you receive a first draft before your
`discussions with your counsel?
` A So we had a lot of phone conversations
`where they asked me about the technical aspects, and
`I did receive a first draft, which I edited and
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`added to and things like that.
` Q Okay. So let's turn to page 2 -- actually,
`page 3 of 23 of Exhibit 1038.
` A Page 3 as in --
` Q Page 3 of 23. We'll use the numbers in the
`bottom left just for convenience.
` A Okay.
` Q And there's a section Materials Reviewed.
` A Yes.
` Q And the Materials Reviewed start on page 3
`and continue on pages 4, 5, 6, and 7; is that
`correct?
` A Yes.
` Q And you've reviewed all of these exhibits
`and other documents?
` A I reviewed them.
` MR. KABAKOFF: Objection to form.
` THE WITNESS: But some of them I've
`reviewed -- the ones that I've opined on, I reviewed
`in greater depth.
`BY MR. FINK:
` Q Okay. But you've reviewed all of them?
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`13
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` A To some extent, yes.
` Q Approximately how much time have you spent
`reviewing these documents?
` A I'd have to guess, but I've been working on
`this IPR total, less than 100 hours, somewhere
`between ten to a hundred hours I think.
` Q Between ten to a hundred? That's quite a
`spread.
` MR. KABAKOFF: Objection, form.
` THE WITNESS: I'd have to look at my notes.
`Maybe 50 to a hundred.
`BY MR. FINK:
` Q When you say 50 to a hundred, you mean the
`total hours spent working on this IPR?
` A Right.
` Q And by this IPR, you mean the two IPRs
`relating to the '324 patent?
` A No. I mean -- yeah, the two IPRs related
`to the '324, yeah, but not the '174.
` Q I'd like you to turn to page 7 of Exhibit
`1038, and it refers to level of ordinary skill in
`the art?
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` A Yes.
` Q And did you prepare this section?
` MR. KABAKOFF: Objection to form.
` THE WITNESS: Once again, this was written
`under my direction. It was a collaborative effort.
`I don't believe I wrote the first draft for this.
`BY MR. FINK:
` Q Okay. On page 8, the third line from the
`end of the first paragraph it says I was at least a
`person of ordinary skill in the art when the
`application leading to the '324 patent was filed.
` What is your basis for that statement?
` A Well, I believe the patent was filed in
`June 1999. I have a Ph.D. in electrical
`engineering, of course, and a master's, and I've
`been working in the field of semiconductor
`fabrication including CMOS.
` Q Mm-hmm.
` A I started at Texas Instruments in '87.
`Even prior to that when I did my Ph.D. from '83 to
`'87 at the University of Illinois, I worked on
`semiconductor fabrication, device fabrication, and
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`then -- so certainly counting my days from TI, so
`'83 to 1999 I've worked on CMOS device fabrication
`issues that are pertinent to this patent.
` Q When you say you worked on issues, what
`type of issues? Design issues?
` A The device fabrication issues,
`characterization.
` Q Have you actually fabricated device --
`semiconductor devices?
` A Yes.
` Q You've worked with sputtering chambers?
` A Yes. When you say work with, at university
`I have graduate students that I supervise.
` Q Okay. But when did you start at the
`university?
` A In '87.
` Q Okay. So prior to 1999, did you do any
`actually sputtering of tantalum layers?
` A I've worked with sputtering certainly of
`titanium layers, which is a transition metal in the
`same category as tantalum. I don't recall if I have
`worked with tantalum since leaving.
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` Q Have you worked with any tantalum nitride
`layers?
` MR. KABAKOFF: Objection to form.
` THE WITNESS: If work with various alloys
`of titanium -- of transition metals and other
`elements, so I remember working with -- offhand I
`couldn't remember if I worked specifically with
`tantalum and nitrogen alloys, no.
`BY MR. FINK:
` Q So as you sit here today, you have no
`recollection of any actual experience with
`sputtering of tantalum or tantalum nitride layers?
` MR. KABAKOFF: Objection, form.
`BY MR. FINK:
` Q Is that correct?
` A I have experience with sputtering of metals
`of this category.
` Q Okay. I'll try it again. I'm going to ask
`you a question, and I'd appreciate it, if possible,
`it could be answered yes or no, I'd appreciate if
`you'd answer yes or no.
` MR. KABAKOFF: Objection, argumentative.
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` THE WITNESS: Yes.
`BY MR. FINK:
` Q Dr. Banerjee, do you have any recollection
`of any actual experience with the sputtering of
`tantalum or tantalum nitride layers?
` MR. KABAKOFF: Objection.
` THE WITNESS: Offhand at this point, I do
`not recall, but I've, once again, worked with
`sputtering of similar systems where the teachings I
`believe apply.
`BY MR. FINK:
` Q Have you worked with a nitride layer where
`you later -- strike that.
` Have you worked with nitrogen in sputtering
`processes?
` A I believe I have in the case of deposition
`of silicon nitride targets, and the other thing that
`I forgot to mention was I've been teaching the
`graduate course on semiconductor device fabrication
`at university since 1987, where we discuss all these
`aspects in the course.
` Q Again, I'm trying to find your actual
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`experience, and you have a very long CV with a lot
`of things on it. Right now I'm trying to find out
`your experience with tantalum, tantalum nitride, and
`nitrogen. So have you been involved in any
`sputtering processes where there was a flow of
`nitrogen in the sputtering chamber?
` A The sputtering systems that I have
`certainly have nitrogen plumbed to them, and I
`believe we've done experiments where, you know,
`we've done reactive sputtering with nitrogen, but
`offhand I cannot remember a specific.
` Q As far as you know, you've not conducted
`any procedures involving nitrogen with tantalum or
`titanium or a similar metal?
` MR. KABAKOFF: Objection to form.
` THE WITNESS: I cannot remember working
`specifically with a combination of tantalum and
`nitrogen.
`BY MR. FINK:
` Q Have you been involved in any sputtering
`processes where there was a flow of nitrogen and the
`nitrogen was turned off?
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` MR. KABAKOFF: Objection to form.
` THE WITNESS: At this point offhand, I do
`not recall, but I have worked with sputtering
`systems involving reactive sputtering where we
`change the flow of one gas at some point or the
`other, but I don't recall specifically turning off
`nitrogen in the middle of the process.
`BY MR. FINK:
` Q Have you ever been involved in measuring
`the nitrogen content of any tantalum or titanium
`alloys from a process you fabricated?
` A I do not recall, but I believe I've
`measured nitrogen concentrations as a function of
`depth in other materials.
` Q What type of materials?
` A Semiconductor materials, such as silicon
`oxynitrides, gate dielectrics and things like that.
` Q What about measuring nitrogen in films made
`of a crystalline metal such as tantalum; have you
`ever measured a nitrogen content there?
` A I don't believe I have done that specific
`combination, but once again, these techniques carry
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`over from one particular material system to the
`other, things like secondary ion mass spectroscopy
`is one example which I'm very familiar with.
` Q I'd like to turn to page 9 of 23 of your
`declaration, and it's entitled "Claim Construction,"
`and paragraph 10 says I was informed by counsel
`that, for purposes of this Inter Partes Review
`proceeding, the claims in the '324 patent should
`have their broadest reasonable construction in light
`of the patent specification.
` What is your understanding of broadest
`reasonable construction?
` A My understanding is that's how person of
`ordinary skill in the art would understand it
`reading the patent.
` Q And did you apply that understanding
`throughout your declaration?
` A Yes.
` Q And throughout your analysis you applied
`that same understanding in determining whether --
`when analyzing the claims of the '324 patent?
` A Yes.
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`Transcript of Sanjay K. Banerjee, Ph.D.
`Conducted on June 13, 2017
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`21
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` Q Have you ever been involved in an IPR where
`the patent was going to expire within 18 months of
`institution?
` MR. KABAKOFF: Objection, relevance.
` THE WITNESS: I do not recall.
`BY MR. FINK:
` Q Are you familiar in certain IPRs that a
`District Court claim interpretation is applied?
` MR. KABAKOFF: Objection, relevance.
` THE WITNESS: I do not recall, no.
` (IP Bridge Exhibit 1005 was
`previously marked for identification and was
`attached to the deposition transcript.)
`BY MR. FINK:
` Q Just in an attempt to refresh your
`recollection, I have select pages of basically -- a
`front page, one of the internal pages, and a
`signature page of a declaration that bears your name
`that was submitted in IPR 2016-01331, which was
`marked as TSMC Exhibit 1005 in that proceeding.
` Does this refresh your recollection of
`whether you filed a declaration relating to the
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`Conducted on June 13, 2017
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`22
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`reissue of the 41,980 patent?
` A I remember the number 980, as I mentioned
`before.
` Q And on the last page of that document, is
`that your signature?
` A Yes.
` MR. KABAKOFF: Objection to the extent the
`document is incomplete.
`BY MR. FINK:
` Q I'd like you to look at the second page of
`the document, which is 32 of 174. And there's one
`paragraph that relates to claim construction.
` Do you see that paragraph, 56?
` A Yes.
` Q It says I have been told that in District
`Court claim terms are given their ordinary and a
`custom meaning as understood by a person of ordinary
`skill in the art as of the applicable priority date.
` Do you understand that?
` A Yes.
` Q Okay. How is that different from your
`understanding of broadest reasonable interpretation
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`Transcript of Sanjay K. Banerjee, Ph.D.
`Conducted on June 13, 2017
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`23
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`that you just testified related to how one of
`ordinary skill in the art would understand the
`terms?
` MR. KABAKOFF: Objection to form.
` THE WITNESS: I don't really review this
`'980 declaration to refresh my memory to be more
`specific, but I can speak to the claim construction
`statement in the current IPR. So my understanding
`of the broadest reasonable construction is, for
`instance, you look to what's given in the
`specifications of the patent, for example, or the
`meaning of these terms in dictionaries or in the
`technical literature.
`BY MR. FINK:
` Q So that's pretty much -- the way you
`understand broadest reasonable interpretation sounds
`very similar to how a District Court would interpret
`a claim in view of the specification and
`dictionaries and other literature as to how a person
`of ordinary skill in the art would understand the
`claim terms, correct?
` A Once again, I haven't looked at this '980
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`Conducted on June 13, 2017
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`24
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`IPR in a while so really --
` Q It's a legal statement, construction under
`two different standards, District Court standard and
`BRI standard. And I want to understand your
`understanding if there's a difference between the
`two, and if there is, what difference do you see?
` MR. KABAKOFF: Objection, relevance.
`BY MR. FINK:
` Q It appears that both relate to the
`understanding of a person of ordinary skill in the
`art at the time of the invention.
` A Well, obviously, I'm not an attorney, so
`without reviewing the '980 IPR in detail, I couldn't
`at this point tell you what the differences --
` Q Has nothing to do with the patent. It has
`to do with the standard that you would review the
`patents.
` A Right.
` Q And I just want to know, based on your
`understanding of the two standards, District Court
`type construction and broadest reasonable
`interpretation, in your experience, is there any
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`difference?
` MR. KABAKOFF: Objection, relevance.
` THE WITNESS: Without, frankly, refreshing
`my memory about the legal claim construction issues
`that were explained to me during that other IPR
`proceeding, I couldn't tell you the differences of
`nuances between the two standards.
`BY MR. FINK:
` Q At this moment, are you aware of any
`differences between the two claim construction
`standards?
` A When I spoke to my lawyers in context of
`the current IPR, my understanding of broadest
`standards was as I explained before, how a POSITA
`would understand those claim terms based on the
`claim specifications, dictionary meanings, relevant
`technical literature and things like that.
` Q And other external sources?
` MR. KABAKOFF: Objection, form.
` THE WITNESS: Other relevant external
`sources.
`BY MR. FINK:
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` Q Did you apply that understanding of
`broadest reasonable construction throughout your
`analysis in both declarations in both of the IPRs
`relating to the '324 patent?
` A I believe I did, but certainly for this
`one. I'd have to look at my first declaration to
`confirm that.
` MR. FINK: I don't have a copy for you.
`I'm sorry.
` (IP Bridge Exhibit 1003 was
`previously marked for identification and was
`attached to the deposition transcript.)
`BY MR. FINK:
` Q But here's Exhibit 1003 filed in these
`IPRs.
` MR. FINK: And you're welcome to look over
`his shoulder if you need it. I will represent it is
`an accurate copy of his declaration including CV
`filed as Exhibit 1003.
`BY MR. FINK:
` Q The claim construction section is on page
`32.
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` MR. KABAKOFF: I'm sorry. Counsel, which
`proceeding is this from? The 1264 or the 1249?
` MR. FINK: Isn't it the same declaration in
`both?
` MR. KABAKOFF: I just want to print out the
`same copy he's looking at.
` MR. FINK: Again, it's the same declaration
`in both. You filed one for both proceedings.
` MR. KABAKOFF: I just want to make sure
`whatever I print is the same thing he's looking at.
` MR. FINK: As far as I understand, it's the
`exact same declaration in both proceedings. If not,
`let me know because then we might have a problem.
`BY MR. FINK:
` Q Okay. So it's paragraph 66 on page 32.
` A Yes.
` Q Okay. Does that help you?
` A Yes.
` Q Okay. So your opinions are consistent with
`your understanding of the broadest reasonable
`construction?
` A Yes.
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` Q How do you understand the words "in light
`of the patent specification," going back to
`paragraph 10 on page 9 of 23 of your second
`declaration?
` A So the way I understood that was you look
`to the sources that we've talked about a few minutes
`back when talking about those terms, but in some
`cases the patentee may act as his or her own
`lexicographer, where he or she may define the terms
`in the specifications slightly differently from how
`it's described in the dictionary for example. In
`which case, the definition in the dictionary would
`take precedence --
` Q What is your --
` A -- the description in the specifications
`would take precedence.
` Q So is that the only time you consider the
`specification, to understand the meaning of the
`claim terms?
` MR. KABAKOFF: Objection.
` THE WITNESS: I'm not quite sure I
`understand the question.
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`BY MR. FINK:
` Q Well, you mentioned that you can look to
`the specification to determine if the patentee was
`his own lexicographer and defined terms in a certain
`way, correct?
` A Yes. Right.
` Q And earlier you said you looked at the
`specification and dictionary definitions and
`relevant literature to determine the scope and
`meaning of the terms used in the claims.
` A Yes.
` Q So what does it mean to be reasonable in
`light of the patent specification?
` MR. KABAKOFF: Objection to form.
` THE WITNESS: My understanding is when you
`interpret claim terms, you look to the
`specifications, not for limiting the claim terms --
`so the specifications do not limit the claim terms,
`but, again, look to the specifications to interpret
`the terms in the claims and --
`BY MR. FINK:
` Q To understand what they mean?
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`30
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` A Yes.
` Q Well, are you -- what would it be if it
`were unreasonable in light of a patent
`specification? What's your understanding of that?
` A I mean, for instance, if one interprets a
`word in a claim in a way that's inconsistent with
`the way it's been used in the specification, that
`would be an unreasonable interpretation.
` Q If it's overly broad, would it be
`unreasonable?
` MR. KABAKOFF: Objection, form.
` THE WITNESS: I mean, if it was overly
`broad to the extent that it would contradict the use
`of the term in the specifications, I think that
`would be unreasonable.
`BY MR. FINK:
` Q What if it's overly broad as to the
`teachings of the patent, still would be a reasonable
`interpretation in your opinion?
` A Aren't the specifications part of the
`teachings of the patent?
` Q Yes.
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`31
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` A So it seems like you're asking the same
`thing.
` Q So as long as the claim terms are not
`construed overly broadly in view of the teachings of
`the specification, they're considered reasonable; is
`that correct?
` MR. KABAKOFF: Objection, form.
` THE WITNESS: Yeah, as long as you don't
`interpret the terms in a way that it's inconsistent
`with the explanation in the specifications.
`BY MR. FINK:
` Q So in your opinion, if the claim terms were
`construed much more broadly than what was disclosed
`in the patent specification, that would be
`unreasonable; is that correct?
` A If the claim terms were interpreted in a
`way that's inconsistent -- when you say much more
`broadly, I interpret that as inconsistent with the
`way they're described in the specifications. That
`would be unreasonable.
` Q Okay. So in preparing your declaration --
`I'm looking at the opinions beginning on page 9 of
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`32
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`23 -- and you reviewed patent owner's substitute
`claims 11 through 13?
` A Yes.
` Q And you construed all the claim terms
`recited in those claims?
` A Yes.
` Q So substitute claim 11 at the bottom of
`page 8 begins a multi-layered wiring structure
`comprising. What is your understanding of the
`term "comprising"?
` A Consisting of.
` Q And by that does it -- is the term open
`ended? It can include other things or just these
`things?
` A May I have a copy of the patent, please?
` Q Sure.
` (IP Bridge Exhibit 1001 was
`previously marked for identification and was
`attached to the deposition transcript.)
`BY MR. FINK:
` Q Here's a copy of Exhibit 1001, which is
`U.S. Patent No. 6,538,324, which is the patent which
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