`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`Petitioner,
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`v.
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`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`
`
`Case IPR2016-01376
`Patent 6,197,696 B1
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`PETITIONER’S OBJECTIONS TO PATENT OWNER’S EVIDENCE
`SUBMITTED WITH ITS PATENT OWNER’S RESPONSE
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`IPR2016-01376
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`Patent 6,197,696 B1
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`In accordance with 37 C .F.R. § 42.64(b)(1), Petitioner Taiwan
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`Semiconductor Manufacturing Company, Ltd. submits the following list of
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`objections to Patent Owner IP Bridge’s Exhibits 2014 through 2019:
`
`Exhibit
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`.
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`.
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`2014
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`Influence ofreactor wall conditions on etch processes in inductively
`coupledfluorocarbon plasmas, by M. Schaepkens, et al., J. Vac. Sci.
`Tech. A 16(4), Jul/Aug 1998.
`
`
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`Handbook of VLSI Microlithography, Second Edition, Principles,
`Technology, and Applications, edited by John N. Helbert, Noyes
`Publications, William Andrew Publishing, LLC, 2001 (excerpted).
`
`Silicon VISI Technology Fundamentals, Practice and Modeling, by
`James D. Plummet, et al., Prentice Hall, 2000 (excerpted).
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`Microlithography: Science and Technology, by James R. Sheats
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`and Bruce W. Smith, Marcel Dekker, Inc., 1998 (excerpted).
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`Microlithography: Science and Technology, 2nd ed., by Kazuaki
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`Suzuki and Bruce W. Smith, CRC Press, 2007 (Chapter 12)
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`(excerpted) (Smith Deposition Exhibit 3).
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`Microlithography: Science and Technology, 2nd ed., by Kazuaki
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`Suzuki and Bruce W. Smith, CRC Press, 2007 (Chapter 11)
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`(excerpted) (Smith Deposition Exhibit 9).
`
`I.
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`Objection to Patent Owner’s Exhibits 2014 through 2019—Irrelevant
`and Non—Probative Evidence
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`Patent Owner’s Exhibits 2014 through 2019 are irrelevant to any material
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`facts at issue in these proceedings, and any probative value Patent Owner may try
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`to assign them is substantially outweighed by their tendency to confuse the issues,
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`IPR2016-01376
`Patent 6,197,696 B1
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`mislead the Board, waste time, and needlessly present cumulative evidence.
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`Exhibits 2014 through 2019 are therefore inadmissible under Fed. R. Evid. 401,
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`402, and 403.
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`Exhibit 2015, which bears a copyright date of 2001, appears to have been
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`published after the date of invention (March 23, 1999, see Paper 11, at 19–26).
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`Similarly, Exhibit 2016 bears a copyright date of 2000, and Exhibits 2018 and
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`2019 each bear copyright dates of 2007, all of which post-date the alleged
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`invention. Exhibits 2015, 2016, 2018, and 2019 thus provide only “impermissible
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`. . . later knowledge about later art-related facts,” In re Hogan, 559 F.2d 595, 605
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`(CCPA 1977), and are inadmissible under Fed. R. Evid. 401, 402, and 403.
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`Patent Owner has not submitted evidence to establish that Exhibit 2014 or
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`Exhibit 2017 were publicly available at the time of alleged invention, making them
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`inadmissible under Fed. R. Evid. 401, 402, and 403.
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`Dated: April 21, 2017
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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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` 2
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`IPR2016-01376
`Patent 6,197,696 B1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), I certify that I served a true and correct
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`
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`copy of the PETITIONER’S OBJECTIONS TO PATENT OWNER’S
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`EVIDENCE SUBMITTED WITH ITS PATENT OWNER’S RESPONSE by
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`electronic mail, on this 21st day of April, 2017, on counsel of record for the
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`Patent Owner as follows:
`
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`Andrew N. Thomases
`andrew.thomases@ropesgray.com
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`J. Steven Baughman
`sbaughman@paulweiss.com
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`Jordan M. Rossen
`jordan.rossen@ropesgray.com
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`James L. Davis, Jr.
`james.l.davis@ropesgray.com
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`
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`IPBridgeTSMCPTABService@ropesgray.com
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`Dated: April 21, 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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