Inter Partes Review
`U.S. Patent No. 6,538,324
`
`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,
`and GLOBALFOUNDRIES U.S. INC.,
`Petitioners,
`v.
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`____________
`
`Case Nos. IPR2016-01249 and IPR2016-012641
`U.S. Patent No. 6,538,324
`____________
`
`PATENT OWNER’S REPLY
`TO PETITIONER’S OPPOSITION TO PATENT OWNER’S
`CONTINGENT MOTION TO AMEND FOR INTER PARTES
`REVIEW OF UNITED STATES PATENT NO. 6,538,324
`
`
`Mail Stop PATENT BOARD, PTAB
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`1 GlobalFoundries U.S. Inc.’s motions for joinder in Cases IPR2017-00919,-00920
`
`were granted.
`
`

`

`Inter Partes Review
`U.S. Patent No. 6,538,324
`
`TABLE OF CONTENTS
`
`Page
`
`THE PATENTS CITED BY PETITIONER ARE NOT MATERIAL .......... 1
`
`I.
`
`A. None Of The 7 References (Exs. 1025-1031) Is Material ................... 2
`
`1.
`
`UK Patent 2,298,657 is not material and merely
`
`cumulative ............................................................................... 2
`
`2.
`
`U.S. Patent No. 5,780,908 is not material and merely
`
`cumulative ............................................................................... 3
`
`3.
`
`U.S. Patent No. 5,869,902 is not material and merely
`
`cumulative ............................................................................... 4
`
`4.
`
`U.S. Patent No. 5,882,399 is not material and merely
`
`cumulative ............................................................................... 4
`
`5.
`
`6.
`
`7.
`
`U.S. Patent No. 6,057,237 is not material ................................ 5
`
`U.S. Patent No. 6,136,682 is not material ................................ 6
`
`U.S. Patent No. 6,242,804 is not material and merely
`
`cumulative ............................................................................... 6
`
`B.
`
`Exhibits 1025-1031 Are Not Discussed In The Expert Report In
`
`The Related Litigation Or Discussed By Petitioner’s Expert
`
`Here ................................................................................................... 6
`
`II.
`
`THE SUBSTITUTE CLAIMS ARE PATENTABLE .................................. 7
`
`A.
`
`B.
`
`The Substitute Claims Are Patentable Over Zhang and Ding ............. 7
`
`The Substitute Claims Are Patentable Over Zhang, Ding and
`
`Nogami .............................................................................................. 8
`
`C.
`
`Chiang 2 Does Not Overcome The Deficiencies of Ding, Zhang
`
`And Nogami......................................................................................10
`
`D.
`
`Substitute Claim 13 Has Adequate Written Support ..........................12
`
`III. CONCLUSION ..........................................................................................12
`
`
`
`
`
`i
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`

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`Inter Partes Review
`U.S. Patent No. 6,538,324
`
`TABLE OF AUTHORITIES
`
`Page(s)
`
`Cases
`
`Shinn Fu Company of America, Inc. et al. v. The Tire Hanger Corporation,
`
`IPR2015-00208, Paper 24, (April 22, 2016) ........................................................ 1
`
`
`
`ii
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`

`

`Inter Partes Review
`U.S. Patent No. 6,538,324
`
`Patent Owner submits this Reply To Petitioner’s Opposition To Patent
`
`Owner’s Contingent Motion to Amend (“Reply”). Patent Owner has met its
`
`burden, procedurally and substantively, of establishing that Substitute Claims 11-
`
`13 are novel, non-obvious, and supported by the ‘324 patent’s written description.
`
`I.
`
`THE PATENTS CITED BY PETITIONER ARE NOT MATERIAL
`
`In the Motion To Amend, Patent Owner discussed 28 references, including
`
`references not cited in the Petition. Ex.2037, ¶¶13, 83a-y. Petitioner asserts that
`
`Patent Owner did not discuss 7 of the 46 references identified in Ex.1037, i.e.,
`
`Exhibits 1025-1031. Exhibits 1025-1031 are not material and, at most, cumulative
`
`to the prior art of record.
`
`There is no requirement that a patent owner seeking to amend its claims in
`
`an IPR must analyze immaterial and cumulative references, particularly where, as
`
`here, there are many different permutations. See Shinn Fu Company of America,
`
`Inc. et al. v. The Tire Hanger Corporation, IPR2015-00208, Decision, (April 22,
`
`2016), p.20. Given the cumulative nature of the references and numerous possible
`
`permutations, Patent Owner complied with its duty of candor. Nevertheless, the
`
`deficiencies of Exhibits 1025-1031 are discussed herein.
`
`
`
`
`
`1
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`

`

`Inter Partes Review
`U.S. Patent No. 6,538,324
`A. None Of The 7 References (Exs. 1025-1031) Is Material
`
`1. UK Patent 2,298,657 is not material and merely cumulative
`
`UK 2,298,657 (“Cho”)(Ex.1025) is the only one of the 7 references
`
`substantively discussed by Petitioner (Opp., pp.2-4). Thus, Petitioner likely
`
`considers Cho to be most relevant, even though it is not substantively discussed in
`
`the expert’s declaration. Ex.1038.
`
`Cho is cumulative to JP H8-250596A (“JP ‘596”)(Exs. 2016, 2017). Cho
`
`and JP ‘596 claim priority to KR 1995-4447, and the allegedly relevant portion of
`
`Cho’s disclosure is the same in JP ‘596. Cho and JP ‘596 disclose a process of
`
`CVD forming layer 3 of Ti and layer 4 of amorphous TiN. Layer 4 is annealed to
`
`form layers 5-7, where layer 5 is amorphous titanium nitride, layer 6 is crystalline
`
`titanium nitride, and layer 7 is crystalline nitrogen-rich titanium nitride. Ex.1025,
`
`p.9 of 13; Ex.2017, p.5 of 9. Cho and JP ‘596 disclose that layer 4 (amorphous)
`
`has a high resistance, which is decreased by phase transitioning layer 4 to the
`
`three-layered titanium nitride (layers 5,6,7) each having different properties. Id.
`
`Thus, Cho and JP ‘596 disclose a specifically configured diffusion barrier
`
`including titanium layer 3 with annealed layers 5,6,7 formed by a specialized
`
`CVD/annealing process forming a specifically configured diffusion barrier. There
`
`is no disclosure of the relative nitrogen content in layers 5,6,7, however, layer 7 is
`
`2
`
`

`

`Inter Partes Review
`U.S. Patent No. 6,538,324
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`disclosed as a “nitrogen-rich” crystalline layer, indicating that it has a higher
`
`nitrogen content than layers 5 and 6. Ex.1025, 9:14; Ex.2017, p.5.
`
`Except for an unsupported assertion of inherency, the Opposition does not
`
`provide any indication how to arrive at the amended claims from Cho, including
`
`the recited relative nitrogen content. The configuration of layers in Cho and JP
`
`‘596 are so different from that of Ding and Zhang, that a PHOSITA would not
`
`have combined the disclosures, and would not have arrived at the amended claims.
`
`Ex, 2037, ¶83e. Thus, Cho is not material and cumulative.
`
`2. U.S. Patent No. 5,780,908 is not material and merely cumulative
`
`U.S. Patent No. 5,780,908 (“Sekiguchi”)(Ex.1026) is directed to a
`
`semiconductor apparatus that comprises a substrate; a conductive layer; a
`
`refractory metal film; a nitrided metal layer formed in an area in the vicinity of a
`
`top surface of the refractory metal film and having a structure in which nitrogen
`
`atoms and refractory metal atoms are bonded; and a metallic interconnection
`
`formed on the refractory metal film with the nitrided metal layer interposed
`
`therebetween and made of a metal material reactive with the refractory metal.
`
`Ex.1026, 4:51-60. Sekiguchi does not teach at least the first or second layers and/or
`
`the nitrogen content recited in the amended claims. The formation of the bonded
`
`structure in Sekiguchi includes multiple steps. The nitrogen in Fig. 11 is shown
`
`3
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`

`

`Inter Partes Review
`U.S. Patent No. 6,538,324
`
`with an upward/downward curve, and does not teach the relative nitrogen content
`
`of layers as recited in the amended claims.
`
`In fact, Sekiguchi is cumulative to Min (Ex.2042), U.S. Patent 6,139,699
`
`(Ex.2041), and Sun (Ex.1007). See Ex.2045, paragraph bridging pp.38-39;
`
`Ex.2037, ¶¶83y, 83x, 81. Thus, Sekiguchi is not material and cumulative.
`
`3. U.S. Patent No. 5,869,902 is not material and merely cumulative
`
`U.S. Patent No. 5,869,902 (“Lee”)(Ex.1027) discloses at 12:25-38, a
`
`diffusion barrier layer 35 comprised of material selected from transition metals,
`
`such as Ti, and transition metal compounds, such as TiN. Lee discloses diffusion
`
`barrier layer 35 is preferably a single layer of TiN, and more preferably a
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`composite layer consisting of a transition metal first diffusion barrier layer and a
`
`transition metal compound second barrier layer formed by depositing a transition
`
`metal, such as Ti, to form a first layer and depositing thereon a transition metal
`
`compound, such as TiN. Lee does not teach or suggest the layers, the morphology
`
`of the layers nor the nitrogen content as recited in the amended claims. Thus, Lee is
`
`not material and cumulative.
`
`4. U.S. Patent No. 5,882,399 is not material and merely cumulative
`
`U.S. Patent No. 5,882,399 (“Ngan”)(Ex.1028) discloses at 9:3-20 that to
`
`obtain a reactive ion-deposition sputtering rate for TiNx upon the TiN second layer
`
`surface, process conditions were set at those specified for the TiN second layer;
`
`4
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`Inter Partes Review
`U.S. Patent No. 6,538,324
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`however, at the beginning of sputtering, the flow of nitrogen to the chamber was
`
`discontinued. Ngan discloses that since the titanium target becomes nitrided during
`
`the TiN deposition, TiN continues to be produced for a limited time after the
`
`nitrogen flow is discontinued, typically, under the operational conditions specified,
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`the nitrided target portion is sputtered away within 5 to 10 seconds, and the TiNx
`
`layer deposition was carried out for a period of about 30 to about 40 seconds after
`
`nitrogen flow chamber was discontinued. Thus, the features of the amended claims
`
`including the nitrogen being present throughout the first film, the first film
`
`containing nitrogen in a portion being in contact with the copper film, and an
`
`amorphous layer are not taught or suggested by Ngan. Ex.2044, 95:2-96:13
`
`(shutting off nitrogen flow to obtain surface of pure tantalum); Ex.2011, ¶¶32,115,
`
`140, 172-178, 199-202; Ex.2037, ¶74. Thus, Ngan is not material, and is also
`
`cumulative to Ding and Zhang which also shut off the flow of nitrogen gas.
`
`5. U.S. Patent No. 6,057,237 is not material
`
`U.S. Patent No. 6,057,237 (“Ding 2”)(Ex.1029) discloses depositing a layer
`
`of amorphous tantalum nitride over an amorphous tantalum layer by adding
`
`nitrogen gas to the sputtering chamber. This tantalum nitride layer prevents
`
`formation of a columnar structure in the growing tantalum film. Id., 2:41-47. Thus,
`
`Ding 2 is not material.
`
`
`
`
`
`5
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`

`

`6. U.S. Patent No. 6,136,682 is not material
`
`Inter Partes Review
`U.S. Patent No. 6,538,324
`
`U.S. Patent No. 6,136,682 (“Hegde”)(Ex.1030) includes two amorphous
`
`layers of titanium nitride, and discloses layer 14 is titanium nitride layer deposited
`
`in an amorphous state mimicking underlying amorphous layer 12. Ex.1030, 4:63-
`
`5:6. Hegde also does not teach a first film containing nitrogen in a smaller content
`
`than that of the second film. Thus, Hegde is not material.
`
`7. U.S. Patent No. 6,242,804 is not material and merely cumulative
`
`U.S. Patent No. 6,242,804 (“Inoue”)(Ex.1031) is cumulative to JP H10-
`
`125627A (“JP ‘627”)(Exs.2024, 2025). Inoue and JP ‘627 claim priority to JP 8-
`
`282211, and have similar disclosures. Thus, Inoue is not material and cumulative.
`
`Ex.2037, ¶83i.
`
`B.
`
`Exhibits 1025-1031 Are Not Discussed In The Expert Report In
`The Related Litigation Or Discussed By Petitioner’s Expert Here
`
`The immateriality of Exhibits 1025-1031 is further established by the fact
`
`the Invalidity Expert Report (Ex.2045) in the related litigation involving the ‘324
`
`patent did not rely on any of these references as a primary reference or in
`
`combination with any primary reference to allege obviousness.
`
`Similarly, Petitioner’s expert likewise does not discuss Exhibits1025-1031
`
`(other than to mention that they were reviewed). Exs.1003, 1038. If any of Exhibits
`
`1025-1031 were material, they would have been discussed. The fact that
`
`Petitioner’s expert does not discuss how any of Exhibits 1025-1031 would render
`
`6
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`Inter Partes Review
`U.S. Patent No. 6,538,324
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`any of the amended claims unpatentable further establishes that they are not
`
`material and, at most, cumulative.
`
`II. THE SUBSTITUTE CLAIMS ARE PATENTABLE
`
`A. The Substitute Claims Are Patentable Over Zhang and Ding
`
`Substitute Claims 11 & 12 recite “composed of” which should be construed
`
`to mean “consisting essentially of.” Ex.2044, 53:3-56:13; Ex.2012; Ex.2013.
`
`Neither Zhang nor Ding disclose a film “composed of” crystalline metal containing
`
`nitrogen.… Both Zhang and Ding teach the desirability of forming a film having a
`
`surface of pure tantalum to contact a copper film. A person having ordinary skill in
`
`the art (“PHOSITA”) combining Zhang and Ding would have retained the desired
`
`upper surface of pure tantalum for contacting a copper layer. Ex.2011, ¶¶86, 89-91,
`
`96-105, 112-120, 124-166; 172-174, 177, 183, 188-220; Ex.1036, 34:6-35:14;
`
`38:3-7; 60:11-62:1, 88:16-21, 131:3-12, 140:18-142:11, 167:7-14, 178:1-179:5,
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`180:6-14, 220:15-221:12, 221:21-223:6, 225:4-226:5, 251:2-6, 250:11- 252:11;
`
`Ex.2044, 96:8-14, 100:6-101:16, 104:9-105:9; Ex.2037, ¶¶49, 74-82.
`
`Substitute Claim 11 recites nitrogen throughout the first film, and Substitute
`
`Claim 12 recites a first film contains nitrogen in a portion being in contact with the
`
`copper film. Ex.2037, ¶¶30, 68. Neither Zhang nor Ding teach these limitations,
`
`and therefore the substitute claims are patentable over any combination of Zhang
`
`and Ding. Ex.2037, ¶¶74-80.
`
`7
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`

`

`B.
`
`The Substitute Claims Are Patentable Over Zhang, Ding and
`Nogami
`
`Nogami (Ex.2039) is directed to addressing electromigration resistance/
`
`Inter Partes Review
`U.S. Patent No. 6,538,324
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`diffusion problems upon forming a combined interconnect structure comprising an
`
`Al or Al alloy feature (“Al feature”) electrically connected to a Cu or Cu alloy
`
`feature (“Cu feature”). Ex.2039, 4:8-12. Nogami’s diffusion barrier has four layers.
`
`In the embodiment referenced in the Opposition, Nogami discloses a first layer of
`
`Ta (not containing nitrogen) in contact with the Al feature; a second layer of TaN
`
`having a nitrogen content, a third layer of TaN having a nitrogen content less than
`
`that of the second layer, a fourth layer of Ta (not containing nitrogen) or TaN, the
`
`TaN having a nitrogen content of less than the third layer, and the fourth layer
`
`being in contact with the Cu feature. Ex.2039, 3:8-15. The layers are configured
`
`with respect to each other to obtain an interrelationship between the four layers to
`
`address the disclosed problems. Ex.2039, 5:21-42.
`
`The Opposition refers to Nogami’s third and fourth layers, and notes that the
`
`upper (fourth) layer is in contact with the Cu feature. Opp., pp.14-15. However,
`
`Nogami is silent with respect to the morphology of the fourth layer, and does not
`
`teach that the fourth layer is a film composed of crystalline metal containing
`
`nitrogen. Ex.2037, ¶83v. In fact, when a specific morphology for a layer is desired,
`
`Nogami discloses the morphology for that layer, i.e., Nogami discloses that the
`
`8
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`Inter Partes Review
`U.S. Patent No. 6,538,324
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`second layer is polycrystalline and that the third layer is amorphous. Ex.2039,
`
`3:40-42, 4:60-63, 5:31-39, Nogami claims 4, 7, 12, 15.
`
`The Opposition (p.14) contends that, “To the extent Nogami does not
`
`expressly disclose a crystalline upper layer, it would have been obvious to a
`
`POSITA to modify Nogami to ensure its upper layer is crystalline, for example, in
`
`view of Ding, for enhancing the adhesion of Cu and electromigration resistance.”
`
`In contrast, Nogami discloses that the fourth layer can comprise Ta or TaN.
`
`Ex.2039, 3:13-14, 23-24, 38-39; 4:53, 59; 5:39; Ex. 2044, 94:4-96:14. The
`
`assertion of obviousness is without any supporting basis when applied to a fourth
`
`layer of Nogami that is formed from TaN as compared to Ta. At most, the alleged
`
`assertion of obviousness may be more appropriate for a fourth layer of Nogami
`
`formed from Ta not containing nitrogen. Ex.2044, 96:8-14, 100:6-101:16, 104:9-
`
`105:9. In this regard, in Zhang and Ding, the surface of the layer in contact with
`
`the copper layer is pure Ta. Ex.2037, ¶¶49, 74-82.
`
`Any modification based upon the combined disclosures of Ding, Zhang and
`
`Nogami would include a surface for contacting a copper layer that would have a
`
`pure metal surface, i.e., no nitrogen, to thereby achieve the desired crystalline
`
`orientation disclosed by Ding. For example, in the process regimes of Ding and
`
`Zhang, adding nitrogen would likely destroy the <002> crystalline orientation of
`
`the upper surface of Ding’s tantalum layer, which is desired to obtain a copper
`
`9
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`Inter Partes Review
`U.S. Patent No. 6,538,324
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`layer having a high <111> crystal orientation. Ex.2011, ¶161; Ex.2037, ¶82;
`
`Ex.2044, 101:9-102:7. Similarly, a PHOSITA based upon the totality of the
`
`teachings in Ding, Zhang and Nogami, to the extent that a PHOSITA would
`
`attempt to combine Ding, Zhang and Nogami, would ensure that the top layer
`
`remained pure tantalum. Ex.2037, ¶¶77-82; Ex.2044, 111:6-15. The Petitioner’s
`
`expert’s reliance upon the ‘324 patent disclosure as compared to knowledge in the
`
`prior art in an attempt to arrive at the amended claims is improper. Ex.2044,
`
`118:19-119:18, cf. 109:5-110:9, 111:6-15.
`
`Substitute Claim 11 expressly recites that the nitrogen is present throughout
`
`the first film, and Substitute Claim 12 further includes a copper film formed on the
`
`first film, the copper film being in direct contact with the first film, and the first
`
`film contains nitrogen in a portion being in contact with the copper film. Ex.2037,
`
`¶¶30, 68. Thus, the substitute claims are patentable over Zhang, Ding and Nogami.
`
`C. Chiang 2 Does Not Overcome The Deficiencies of Ding, Zhang
`And Nogami
`
`Petitioner contends (Opp., p.9) that the inventors of the Ding patent disclose
`
`in their co-pending application, Chiang 2 (Ex.1033), that the surface of Ding’s top
`
`barrier film may contain “a small amount of nitrogen (typically less than about 15
`
`atomic percent).” However, reliance of upon Chiang 2, which is later-filed than
`
`Ding, is improper. Additionally, the referenced portion of Chiang 2 does not state
`
`that Ding discloses the asserted disclosure.
`
`10
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`Inter Partes Review
`U.S. Patent No. 6,538,324
`
`The filing date of Chiang 2 is September 24, 1998, which is after the filing
`
`date of Ding, December 19, 1997. Petitioner has not established that the later-filed
`
`disclosure of Chiang 2 is within Ding’s disclosure. The later-filed disclosure of
`
`Chiang 2 should not be used in an attempt to rewrite Ding’s earlier disclosure.
`
`The full paragraph of Chiang 2 that includes Petitioner’s quoted language
`
`does not support that the surface of Ding’s top barrier film may contain nitrogen.
`
`The sentence following the disclosure pertaining to the 08/995,108 application
`
`(Ding application) merely makes a statement that Ding provides excellent barrier
`
`properties while increasing the <111> content of an overlying copper layer and
`
`provides a copper layer having improved electromigration resistance. This
`
`statement does not indicate that Ding’s disclosed barrier diffusion layer has any
`
`nitrogen at the surface. As noted above, adding nitrogen would likely destroy the
`
`<002> crystalline orientation of the upper surface of Ding’s tantalum layer, which
`
`is desired to obtain a copper layer having a high <111> crystal orientation.
`
`Ex.2037, ¶82. Petitioner has not provided any documentary evidence to establish
`
`that a PHOSITA would have included nitrogen at Ding’s surface.
`
`Additionally, Chiang 2’s “tantalum film” is substantially pure tantalum,
`
`containing no nitrogen. Ex.1033, 7:44-48. Chiang 2 also discloses that the films
`
`containing nitrogen are “less preferred.” Id., 10:17, 10:29.
`
`
`
`11
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`

`

`D.
`
`Substitute Claim 13 Has Adequate Written Support
`
`The ‘415 application that issued as the ‘324 patent discloses a “barrier-
`
`Inter Partes Review
`U.S. Patent No. 6,538,324
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`diffusion film is comprised of a crystalline Ta film containing nitrogen in solid
`
`solution and an amorphous metal TaN film.” Ex.1002, p.67 (emphasis added);
`
`Ex.1001, 8:27-29. This film would be understood by a PHOSITA as being a solid
`
`solution composed of crystalline metal containing nitrogen. It would be understood
`
`by a PHOSITA that nitrogen can be present within the solid solubility of the
`
`components within the film including the crystalline metal. It would also be
`
`understood by a PHOSITA that the solid phase can include one solid phase
`
`dispersed in another. Ex.2043; Ex.2036; Ex.2037, ¶¶33-35, 40-41, 51-53, 61;
`
`Ex.2044, 80:4-82:7.
`
`A PHOSITA at the time of the invention would readily understand that the
`
`inventors possessed the recited “first film being composed of crystalline metal
`
`containing nitrogen therein is a solid solution.” Accordingly, there is adequate
`
`written description to support Substitute Claim 13 and the term “solid solution.”
`
`III. CONCLUSION
`
`For the reasons above, the Motion to Amend should be granted.
`
`Dated: June 21, 2017
`
`
`
`
`
`
`
`
`
`Respectfully submitted by:
`
`
`
`/Michael J. Fink/
`Michael J. Fink
`Registration No. 31,827
`Greenblum & Bernstein, P.L.C.
`
`12
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`Inter Partes Review
`U.S. Patent No. 6,538,324
`
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
`Fax: 703-716-1180
`Email: mfink@gbpatent.com
`
`Attorney for Patent Owner,
`IP Bridge
`
`
`
`
`
`{J709905 03144926.DOCX 3}
`
`13
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`Inter Partes Review
`U.S. Patent No. 6,538,324
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`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true copy of the foregoing:
`
`PATENT OWNER’S REPLY
`TO PETITIONER’S OPPOSITION TO PATENT OWNER’S
`CONTINGENT MOTION TO AMEND FOR INTER PARTES
`REVIEW OF UNITED STATES PATENT NO. 6,538,324
`
`was served by electronic mail on this 21st day of June, 2017, upon Counsel for
`
`Petitioners, as follows:
`
`E. Robert Yoches (bob.yoches@finnegan.com);
`Stephen E. Kabakoff (stephen.kabakoff@finnegan.com);
`Joshua L. Goldberg (joshua.goldberg@finnegan.com);
`TSMC-IPB-PTAB@finnegan.com;
`Christopher P. Carroll (christopher.carroll@whitecase.com); and
`Shamita Etienne-Cummings (setienne@whitecase.com).
`
`
`
`
`
`/Michael J. Fink/
`Michael J. Fink
`Registration No. 31,827
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
`Fax: 703-716-1180
`Email: mfink@gbpatent.com
`
`
`
`
`
`
`