Case: IPR2016-01247 - IPR2016-01246
`Glew Ph.D., P.E., Alexander D.
`
`June 30, 2017
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`1
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`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 IPR2016-01247/2016-01246
` U.S. Patent No. 7,126,174
` __________
` Palo Alto, California
` June 30, 2017
` CROSS-EXAMINATION
` ALEXANDER D. GLEW, Ph.D., P.E.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Page 1 of 171
`
`TSMC Exhibit 1047
`TSMC v. IP Bridge
`IPR2016-01376
`
`
`Glew Ph.D., P.E., Alexander D.
`
`June 30, 2017
`
`1
`
`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 IPR2016-01247/2016-01246
` U.S. Patent No. 7,126,174
` __________
` Palo Alto, California
` June 30, 2017
` CROSS-EXAMINATION
` ALEXANDER D. GLEW, Ph.D., P.E.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Page 1 of 171
`
`TSMC Exhibit 1047
`TSMC v. IP Bridge
`IPR2016-01376
`
`
`
`Case: IPR2016-01247 - IPR2016-01246
`Glew Ph.D., P.E., Alexander D.
`
`June 30, 2017
`
`2
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`Cross-Examination of ALEXANDER D. GLEW, Ph.D.,
`P.E., a witness herein, called for examination
`by counsel for Petitioner in the above-entitled
`matter, pursuant to notice, the witness being
`duly sworn by MARY HOGAN, CSR, a Certified
`Shorthand Reporter in and for the State of
`California, taken at the offices of Ropes &
`Gray, 1900 University Avenue, 6th Floor, East
`Palo Alto, California, commencing at 8:54 a.m.
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`Case: IPR2016-01247 - IPR2016-01246
`Glew Ph.D., P.E., Alexander D.
`
`June 30, 2017
`
`3
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`APPEARANCES:
`On behalf of the Patent Owner:
`JAMES L. DAVIS, ESQUIRE
`Ropes & Gray, LLP
`1900 University Avenue, 6th Floor
`East Palo Alto, California 94303
`(650) 617-4794
`james.l.davis@ropesgray.com
`On behalf of the Petitioner
`DARREN M. JIRON, ESQUIRE
`Finnegan, Henderson, Farabow, Garrett &
`Dunner, LLP
`Two Freedom Square
`11955 Freedom Drive
`Reston, Virginia 20190-5675
`(571)203-2700
`darren.jiron@finnegan.com
`-and-
`J. PRESTON LONG, Ph.D., ESQUIRE
`Finnegan, Henderson, Farabow, Garrett &
`Dunner, LLP
`901 New York Avenue, N.W.
`Washington, D.C.
`(202) 408-4000
`jp.long@finnegan.com
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`Case: IPR2016-01247 - IPR2016-01246
`Glew Ph.D., P.E., Alexander D.
`
`June 30, 2017
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`4
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` C O N T E N T S
`
`ALEXANDER D. GLEW, PH.D. EXAMINATION
`By Mr. Jiron 5
`
` E X H I B I T S
`**Exhibits previously marked
`IP BRIDGE EXHIBIT NO. 2009 68
`Declaration of
`Alexander D. Glew, Ph.D., P.E.
`TSMC EXHIBIT NO. 1001 94
`696 Patent
`
`**Exhibits marked
`GLEW EXHIBIT 1 86
`Layer Etching Pattern Sketch
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`Case: IPR2016-01247 - IPR2016-01246
`Glew Ph.D., P.E., Alexander D.
`
`June 30, 2017
`
`5
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` P R O C E E D I N G S
`
` Whereupon, ALEXANDER D. GLEW, PH.D.,
`P.E., was called as a witness by counsel for
`Petitioners, and having been duly sworn, was
`examined and testified as follows:
`
` CROSS-EXAMINATION
`BY MR. JIRON:
` Q Good morning, Dr. Glew.
` A Good morning.
` Q Could you state your full name and
`address for the record, please?
` A Yes. Work or home address?
` Q Work address.
` A Okay. Alexander David Glew, 240
`Pamela Drive, Mountain View, California 94040.
` Q You understand you are under oath
`today, correct?
` A Yes.
` Q That means you must testify
`truthfully as if you were in front of a judge or
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`Case: IPR2016-01247 - IPR2016-01246
`Glew Ph.D., P.E., Alexander D.
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`June 30, 2017
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`in a courtroom, okay?
` A Yes.
` Q Is there any reason that would
`prevent you from understanding my questions
`today that you know of?
` A No.
` Q Are you taking any medications that
`would hinder your ability to understand
`questions?
` A No.
` Q Earlier it sounded like you had been
`involved in some deposition prep, so I assume
`you have been involved in depositions before, is
`that right?
` A Yes, I have.
` Q About how many times have you been
`deposed?
` A Approximately 40.
` Q So given your experience, even in
`view of your experience, I'll just go over a
`couple of ground rules for today.
` As we have a court reporter today who
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`Case: IPR2016-01247 - IPR2016-01246
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`June 30, 2017
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`will be recording responses and questions, do you
`understand that she needs to hear verbal responses
`rather than head nods and things like that?
` A Yes.
` Q Also I'll ask a number of questions
`today and I'll ask you that if there is any
`question that you don't understand, could you
`let me know that you don't understand the
`question?
` A Yes.
` Q If you don't let me know that you
`don't understand the question, would it be fair
`to assume then that you do understand?
` A That's reasonable.
` Q I will try to take a break about
`once every hour but if you need a break any time
`other than that, just let me know, okay?
` A Okay. I will do that.
` Q The only request that I have is that
`if there is a question pending that you complete
`your answer to the question before we take a
`break. Understood?
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`Case: IPR2016-01247 - IPR2016-01246
`Glew Ph.D., P.E., Alexander D.
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`June 30, 2017
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` A I understand.
` Q You are currently employed at Glew
`Engineering and Consulting, is that right?
` A That's correct.
` Q You have been there since 1997?
` A Yes.
` Q What type of consulting do you do in
`that position?
` A Well, we do a few things. I wear
`two hats.
` I'm a mechanical engineer and material
`scientist. I have a BS and MS in Mechanical
`Engineering and a license in Mechanical
`Engineering. I am insured in errors and omissions
`in mechanical engineering, so we do some work
`which is largely equipment design.
` I started my career in semiconductor
`equipment, so we do a lot of equipment work, and
`the material science part of me, the Master's in
`Material Science does more of the material
`processing, which dovetails nicely with the
`equipment, as well as materials characterization.
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`Case: IPR2016-01247 - IPR2016-01246
`Glew Ph.D., P.E., Alexander D.
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`June 30, 2017
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` So in terms of technical areas, those
`are kind of the technical areas we largely work
`in.
` Along with the materials is a lot of
`semiconductor and thin film technology, some
`display technology now, and then I would divide
`the business in terms of its practice areas into
`largely engineering and litigation support, some
`small amount of general consulting, companies that
`want to evaluate technology or that sort of thing.
` Q How many people are at Glew
`Construction?
` A Currently three. We should be
`staffed at four. We're short one now.
` Q You mentioned litigation support.
`That falls under the umbrella of Glew
`Consulting?
` A Yes.
` Q About how much of your time in
`percentage numbers do you spend on litigation
`support versus the other types of work you
`mentioned?
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`June 30, 2017
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` A It depends year to year. My goal is
`to keep it about 50/50.
` Q When you mentioned that you do
`equipment design, what type of equipment are you
`designing?
` A Well, everything from semiconductor
`equipment, thin film processing, to some
`industrial equipment, what you might call
`general industry.
` Q So you mentioned that you do about
`50/50 litigation support and other work.
` Is that about what you would say an
`average year is in actual numbers or does it vary
`from 50/50?
` A It varies year to year. Engineering
`work is more predictable. There is usually a
`start and an end to a project.
` Litigation work is very unpredictable.
`Sometimes cases end the first week you're engaged,
`other times they carry on for -- I think I'm
`finishing a case that has been going on for 14
`years, so it's just hard to predict how much
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`litigation work comes out of the agreement.
` Q Maybe as an example, do you recall
`in 2016 what the percentage might have been
`roughly?
` A Probably 60 litigation, 40
`engineering.
` Q I would like to talk for a minute
`about your experience at Applied Materials.
` A Okay.
` Q You were at Applied Materials from
`1987 through 1997, is that right?
` A Yes.
` Q During that time it sounded like
`there were different divisions of Applied
`Materials. What were those divisions?
` A Well, the divisions changed over
`time. There was a CVD division, an etch
`division. The CVD and etch division merged for
`a while. I was in both.
` There was an implant division.
`Eventually there was a CMP division, chemical
`mechanical polishing.
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`June 30, 2017
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` There was a division for service.
`There was a division for high temperature
`processing. It was part of CVD, and then I think
`it got spun out to its own group.
` The divisions initially were more
`oriented along the lines of CVD etch, which you
`might think of as traditional technologies. Then
`over time they reoriented themselves to be more
`oriented toward the fabrication process, meaning
`there would be a group that focused on
`transistors, a group that focused on
`interconnects.
` Then there was also a corporate
`function, corporate entity, that I served in also
`that worked with all the divisions.
` Q So during the time that you were at
`Applied Materials you mentioned that you were a
`member at one time of both the CVD and the etch
`division?
` A Yes.
` Q How long did you spend in the CVD
`division?
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`June 30, 2017
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` A If I was there ten years, probably I
`would say at least six years were CVD.
` Then for another period of time it was
`a combination of CVD and etch, a few years of
`that.
` Q Then it was merged?
` A Yes.
` Q Approximately how long were you a
`member of the merged etch CVD group?
` A Probably something short of two
`years.
` Q Were you a member of any other
`divisions?
` A I was a member of -- I served in the
`corporate group.
` I was a core technologist, so I was
`one of 15 corporate experts, so I served at the
`corporate level and then worked with all of the
`divisions.
` Sometimes -- there was a period of
`time where I had a few appointments within the
`company. I was both -- I had a corporate position
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`as well as divisional responsibility.
` It's been a while, but I may have also
`been in a division that was toward the end an
`operations division responsible for manufacturing,
`but that's been a long time.
` There was also a TFT division, thin
`film transistors. Applied made tools to make flat
`panel displays.
` They eventually -- there was a joint
`venture. They eventually spun off. They were
`down the hall, in the same building, but I think
`they were at some point officially a joint
`venture.
` There may have been other divisions,
`too. By the time I left it was a $6 billion
`company.
` Q You were a member of the TFT
`division?
` A I was a core technologist then, so I
`worked with them, but I was not in the TFT
`division.
` Q You mentioned as a core
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`technologist. That was a corporate division?
` A That's like -- yes, it's a corporate
`function. There is a corporation, then there's
`divisions under the corporation, if you think of
`it like that.
` So there was a small cadre of core
`skills kept at the corporate level. I was one of
`15 corporate experts, core technologists, for a
`while, yes.
` Q What would you characterize as the
`responsibility of the division at the corporate
`level that you were working in?
` A The core technology group?
` Q Yes.
` A Well, there were about 15 of us. We
`each had a responsibility for one area of
`technology.
` We met monthly with either the
`president of the company or an executive vice
`president, sometimes the CEO.
` We tried to establish, make sure that
`we had expertise in the technologies that the
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`corporation thought we needed to have expertise
`in, and then propagate that expertise out to the
`divisions, making sure that one division wasn't
`lagging the other divisions.
` If one division knew it or had the
`skill set capability that all the divisions of the
`corporation as a whole had access or that ability,
`so one product wasn't lagging another group in an
`area that we actually had expertise in.
` Q What were the primary
`responsibilities of the CVD division while you
`were there?
` A Well, when I started there -- I
`think there had been a CVD tool years before,
`but it was no longer in production, had been
`defunct, so we made what I understood as the
`first competitive CVD tool at Applied Materials.
` We made the mainframe upon which
`process chambers hung, and then we developed the
`process chambers and the processes for the CVD
`processes.
` The tool that I worked on, Applied
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`Materials Precision 5000, was placed in the
`Smithsonian Institute next to a Caterpillar
`tractor.
` Eventually, even though it was a
`division, the mainframe we developed was used by
`other divisions, so the etch division took our
`mainframe and hung their process chambers on it.
` So what we did is we made the first
`single wafer processing. Up to that time all the
`equivalent was batch, 25 wafers at a time, maybe
`50.
` So we made a chamber that processed
`the single wafer, and there were perhaps up to
`four chambers on the system.
` Then after that we just started off
`with a couple of processes. At one point I
`counted over 25 different CVD processes that we
`sold chambers for. Some of them were minor
`variations on others, but we did that sort of
`thing.
` Then eventually that mainframe got
`older and the corporation as a whole tried to
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`develop a new mainframe instead of a division, and
`so we transitioned our processes and chambers to
`the new mainframe.
` We also developed different wafer
`sizes. So when I started the industry wafers were
`smaller. The biggest was 150 millimeter.
` People still used 50 and 75, so we
`developed the 200 millimeter processes, then
`eventually, the 300 millimeter processes.
` Q When you say mainframe, what
`components are you referring to?
` A Mainframe usually has a central load
`lock chamber and a robot.
` It has a port that accepts cassettes
`of wafers from the factory. So the robot will
`take the cassette and unload it into a load lock,
`put it under vaccuum and transfer the wafers out
`to the process chambers, attach the load lock
`or -- the mainframe is essentially a remote
`mainframe with the dirty gear that doesn't need to
`be in the clean room.
` There is a big umbilical cord, so to
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`speak, and some vaccuum pumps are right on the
`chambers and the bigger are remote, the big power
`supplies for generating RF plasmas or other types
`of plasmas.
` So the mainframe is pretty much
`everything except for the process chamber that the
`wafer goes into and the nasty chemicals go on.
` The mainframe also includes the gas
`delivery system, chemical vaporizers, things like
`that, a gas panel.
` Q So the wafers would transition from
`the mainframe into the different process
`chambers?
` A Yes.
` Q And what was your role, would you
`say, in developing the mainframe?
` A Well, initially quite a bit. I
`actually ended up releasing the mainframe in a
`manufacturing sense, so I was responsible for
`creating all of the business and materials and
`assembly drawings and configuring the system.
` It's something I had a knack for,
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`system engineering, so if you ordered a system
`nobody knew what to build, nobody, except for
`maybe two or three people, so sales would sell
`something, marketing would get an order, and you
`have to figure out how to -- what actually went on
`this.
` If you want two CVD chambers that
`deposit silicon oxide and one that deposited doped
`silicon oxide, what showed up on the sales order,
`what went to manufacturing, that's one element.
` Then the other element is how do you
`get that order into manufacturing because
`basically it just looked like a big menu with
`hundreds of choices of modules and subassemblies
`could be done.
` Over the first year I sorted all that
`out and made sense out of that.
` I also worked on detail design of many
`aspects of the mainframe, everything from the
`robot to the RF matches, the gas panels, the
`vaccuum pump systems, the remote frame.
` I ended up redesigning the rear half
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`of the mainframe to accommodate a bigger breaker
`box and bigger chemical delivery system, so
`various aspects of it.
` I re-did the hepa filters on it so
`they would run in Japan also on 50 hertz. There
`is numerous problems.
` After that I took over as a customer
`engineering specials manager. We ended up -- I
`don't want to say modifying every system we built.
`Every system was different, but there were a lot
`of idiosyncrasies to each manufacturer and each
`country and jurisdictions for safety, so ended up
`modifying the equipment with my team repeatedly
`over the first few years, so that type stuff.
` Q You mentioned the etch division.
`What were the primary responsibilities of the
`etch division at Applied Materials?
` A Well, when I started the etch
`division had their own batch processor.
` They didn't use the mainframe. They
`had their own tool, and I wouldn't call it a
`mainframe.
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` It was just a batch system with one
`big chamber and really wasn't reconfigurable, so
`the etch division initially transitioned their
`processors from batch to single wafer and put them
`on the mainframe, the 5,000, it was called.
` Then after that they had
`responsibility for modifying the mainframe in any
`way that they needed for their particular
`processes.
` Of course, any division is responsible
`for developing their processes and chambers. Of
`course, they have to support the marketing and
`sales teams with demonstrations, so whether it was
`CVD or etch, you had to run wafers for customers
`both for demonstrations and acceptance sometimes.
`You know, in the end these were billion dollar
`divisions.
` They had a lot of responsibilities.
`In the end they would, of course, have
`responsibility for support in the field when the
`service division needed high level support,
`specialized factory support, things along those
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`lines, from an engineering and operational sense.
` Q Sounds like the etch division and
`CVD division were both involved in developing
`this 5000 mainframe tool. Would that be
`accurate to say?
` A If you asked the CVD people, they
`developed it and they pretty much did.
` When this 5000 came out, there were no
`etch chambers on it, only CVD.
` Shortly after that -- it sold really
`well, customers loved it. It was considered big
`change to go to single wafer, so the company
`decided that the etch group had to use that
`mainframe.
` So rather reluctantly, you know, there
`was a lot of people with a lot of history, and you
`know, corporate politics, they adopted the new
`mainframe and transitioned their processes to
`single wafer.
` After that though, they had a big role
`in the mainframe because at the time when I
`started there were no CVD sales. It was a new
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`division. Etch was carrying the company.
` So going forward, to put etch on the
`5,000, it had to accommodate that -- the mainframe
`had to accommodate the largest division in the
`company, so they both over time had the large
`amount of influence over the mainframe.
` Eventually the mainframe went
`corporate though. It was built by the corporate
`group and then divisions had to work with the
`corporate group to manage their mainframe
`requests.
` Q So it sounds then like the CVD group
`initially developed and designed the 5,000
`mainframe tool, and the etch group incorporated
`their own etch specific chambers onto that tool?
` A Yes, that's reasonable.
` Q Did you ever have an opportunity to
`interact with the etch group or work with the
`etch group on the tools they were developing?
` A Yes, because as some point shortly
`after that the -- around that time, when all
`this activity was going on, the etch and CVD
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`groups merged.
` What better way to help the etch group
`get their chambers onto the tool than have the
`people who developed the tool work with them.
` So yes, at some point I was in a joint
`CVD etch division, and we were integrating the
`etch processes into the new platform, new
`mainframe.
` Q So what tasks did you work on to
`integrate the etch chambers to the mainframe
`device?
` A Well, very similar to what you would
`do in CVD. Once the mainframe was established
`you had less to do.
` You had to make sure that, from a
`systems point of view, that the interfaces
`existed, so you sort of break it down to
`electrical signals.
` You have analog ins and analog outs,
`digital ins and digital outs. This was before we
`went to a serial bus.
` Then you have pneumatics interfaces,
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`turn valves on and off, cooling water, a power
`limit.
` You have to understand how much power
`the plasma sources are going to draw or magnets
`for etch processes.
` The pumps are sometimes enormous.
`They have to physically fit. You have to design
`the flow paths. Vaccuum lines are kind of like
`car exhausts, very particular.
` So all of this, you had a lot of
`detail into getting these things to fit. This was
`back in the days where a lot of the design was
`done with pen and pencil and two dimensional CAD,
`so, you know, if you didn't have a lot of
`experience with the system, you couldn't design
`something without running into 14 other things, so
`it was a lot of key people that could make things
`work and fit.
` Of course, you had to -- I'm talking
`about the system level integration.
` Then at the chamber level integration
`you had more stuff along the lines of making sure
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`that, you know, there was adequate temperature
`control, that the magnetic system didn't talk to
`the rest of the system, that it was shielded, that
`the RF was shielded so that it didn't short
`everything out around it, that things were safe.
` I remember talking to an etch engineer
`once about the safety issues of the chamber, and
`he said, no, it's fine, while he had this big burn
`mark across his forehead.
` Then, of course, the gases were
`hazardous, deadly in a lot of cases.
` That was one of my areas of expertise,
`was hazardous chemicals that touch wafers, wedded
`gases. Gases wedded a wafer, so you had to make
`sure all of the safety was in place, and it was
`integrated properly into the tool, so that people
`didn't get hurt, and you couldn't assemble -- to
`the extent that you couldn't build a system that
`wasn't safe, there were kind of design features
`that were keyed, so to speak, that you couldn't
`put things that didn't go there, and then try to
`get some things in place so that sales couldn't
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`sell configurations that weren't safe.
` Q Did you ever have a chance to do any
`etching while you were at Applied Materials?
` A Yes.
` Q Can you describe what etching you
`did?
` A I'll start with one example. While
`I was at Applied I proposed a project to
`Sematech which they accepted that I managed, in
`which case we looked at the effects of micro
`contamination on a CVD process and an etch
`process.
` So we ran numerous etch processes,
`looked at the effect on the etch uniformity, the
`etch profiles. We examined them under SEMs
`ourselves.
` Some work we sent to outside labs for
`equipment we didn't have for measurements, but we
`could determine when there was an effect, or not,
`of a proposed contaminant upon the etch processing
`results.
` Q In that study do you recall what
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`percent were being etched?
` A I think in the Sematech program it
`was -- probably could have been a metal etch,
`aluminum. That would be one example, yes.
` Q Do you remember the chemistries that
`were being used to etch the aluminum?
` A My recollection, it's been a long
`time, is it was a bromine chlorine combination,
`hallogen gas species.
` Q You think it was called Sematech?
` A Sematech, yes. S E M A T E C H.
` Q In addition to the Sematech project
`were there other opportunities you had to
`perform any etch processes?
` A Yes. All of the processes we
`developed, we had to run wafers for, so I was on
`numerous teams with hardware process, software
`engineers, where we developed process chambers,
`and when we -- whether we were doing a CVD or an
`etch project, invariably a CVD film gets etched
`and you need to deposit a film to etch it, so
`they pretty much went hand in hand in all the
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`projects.
` One of the key measurements of a
`material is how well you can etch it. If you
`deposit a film, you have to create a pattern in
`it.
` Some films are difficult to pattern
`because they erode too quickly or are not
`selective, so we etched -- we deposited and etched
`oxides and nitrides and tungsten films.
` Basically any film that we sold, we
`had to be able to deposit an etch, so numerous
`silicon compounds and the various metals.
` Q It sounds, too, like you would do
`testing of the system or a demonstration of the
`system for customers?
` A Well, we did -- when we developed
`the process tools we ran processes.
` We had to characterize it and decide
`what its performance was, and invariably it wasn't
`what we wanted the first time, but testing went on
`for months typically until you went through the
`experimental parameters.
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