UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
` TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.
`Petitioner
`
`v.
`
`GODO KAISHA IP BRIDGE 1
`Patent Owner
`____________
`
`Case IPR2016-01377
`Patent 6,197,696 B1
`____________
`
`Before JUSTIN T. ARBES, MICHAEL J. FITZPATRICK, and JENNIFER
`MEYER CHAGNON, Administrative Patent Judges.
`
`
`
`
`
`
`
`DECLARATION OF JORDAN M. ROSSEN
`
`I, Jordan M. Rossen, make the following Declaration pursuant to 28 U.S.C.
`
`§ 1746:
`
`1.
`
`I am an attorney with the law firm of Ropes & Gray LLP. I have
`
`worked at Ropes & Gray LLP since 2008.
`
`2.
`
`I provide this Declaration in connection with Patent Owner’s
`
`Response to the above-captioned Petition for Inter Partes Review of U.S. Patent
`
`6,197,696 B1. Unless otherwise stated, the facts stated in this Declaration are
`
`based on my personal knowledge.
`
`
`
`1
`
`IP Bridge Exhibit 2022
`TSMC v. IP Bridge
` IPR2016-01377
`Page 0001
`
`
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
` TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.
`Petitioner
`
`v.
`
`GODO KAISHA IP BRIDGE 1
`Patent Owner
`____________
`
`Case IPR2016-01377
`Patent 6,197,696 B1
`____________
`
`Before JUSTIN T. ARBES, MICHAEL J. FITZPATRICK, and JENNIFER
`MEYER CHAGNON, Administrative Patent Judges.
`
`
`
`
`
`
`
`DECLARATION OF JORDAN M. ROSSEN
`
`I, Jordan M. Rossen, make the following Declaration pursuant to 28 U.S.C.
`
`§ 1746:
`
`1.
`
`I am an attorney with the law firm of Ropes & Gray LLP. I have
`
`worked at Ropes & Gray LLP since 2008.
`
`2.
`
`I provide this Declaration in connection with Patent Owner’s
`
`Response to the above-captioned Petition for Inter Partes Review of U.S. Patent
`
`6,197,696 B1. Unless otherwise stated, the facts stated in this Declaration are
`
`based on my personal knowledge.
`
`
`
`1
`
`IP Bridge Exhibit 2022
`TSMC v. IP Bridge
` IPR2016-01377
`Page 0001
`
`
`
`3.
`
`Exhibit 2010 is a true and correct copy of the Transcript of the
`
`Deposition of Dr. Smith taken on March 23, 2017. An exhibit label and page
`
`numbers have been added to the bottom of this document but no other alterations
`
`have been made.
`
`4.
`
`Exhibit 2011 is true and correct copy of a redline comparison of Grill
`
`(EX1005) with Grill’s Provisional Application (EX1017) that was prepared by Dr.
`
`Alexander Glew. An exhibit label and page numbers have been added to the
`
`bottom of this document but no other alterations have been made.
`
`5.
`
`Exhibit 2012 is a true and correct copy of the certified translation of
`
`Japanese Patent Application No. 7411290311 to Aoi, filed on March 26, 1998 by
`
`Matsushita Electric Industrial Co., Ltd., which was downloaded at my direction on
`
`April 11, 2017 from the European Patent Office’s Espacenet search page,
`
`http://worldwide.espacenet.com, to which all parties have access. An exhibit label
`
`and page numbers have been added to the bottom of this document but no other
`
`alterations have been made.
`
`6.
`
`Exhibit 2014 is a true and correct copy of an article entitled
`
`“Influence of reactor wall conditions on etch processes in inductively coupled
`
`fluorocarbon plasmas” published in the Journal of Vacuum Science & Technology
`
`A: Vacuum, Surfaces, and Film and dated 1998, which was obtained at my
`
`direction on April 13, 2017 from Reprints Desk (http://info.reprintsdesk.com). An
`
`
`
`2
`
`IPR2016-01377 Page 0002
`
`
`
`exhibit label and page numbers have been added to the bottom of this document
`
`but no other alterations have been made.
`
`7.
`
`Exhibit 2015 is a true and correct copy of an excerpt from Handbook
`
`of VLSI Microlithography, Second Edition, Principles, Technology, and
`
`Applications, published by Noyes Publications/William Andrew Publishing, LLC,
`
`in 2001, which was obtained at my direction on April 13, 2017 from the Kresge
`
`Engineering Library at the University of California-Berkeley. An exhibit label and
`
`page numbers have been added to the bottom of this document but no other
`
`alterations have been made.
`
`8.
`
`Exhibit 2016 is a true and correct copy of an excerpt from Silicon
`
`VLSI Technology Fundamentals, Practice and Modeling by James D. Plummer, et
`
`al., published by Prentice Hall in 2000, which was obtained at my direction on
`
`April 13, 2017 from the Kresge Engineering Library at the University of
`
`California-Berkeley. An exhibit label and page numbers have been added to the
`
`bottom of this document but no other alterations have been made.
`
`9.
`
`Exhibit 2017 is a true and correct copy of an excerpt from
`
`Microlithography: Science and Technology by James R. Sheats and Bruce W.
`
`Smith, published by Marcel Dekker, Inc. in 1998, which was obtained at my
`
`direction on April 11, 2017 from the Kresge Engineering Library at the University
`
`
`
`3
`
`IPR2016-01377 Page 0003
`
`
`
`of California-Berkeley. An exhibit label and page numbers have been added to
`
`the bottom of this document but no other alterations have been made.
`
`10. Exhibit 2018 is a true and correct copy of Deposition Exhibit No. 3
`
`from the Deposition of Dr. Smith taken on March 23, 2017. It contains an excerpt
`
`(Chapter 12) from Microlithography: Science and Technology by Kazuaki Suzuki
`
`and Bruce W. Smith, published by CRC Press Taylor & Francis Group in 2007,
`
`which was obtained at my direction on February 27, 2017 from the Kresge
`
`Engineering Library at the University of California-Berkeley. An exhibit label
`
`and page numbers have been added to the bottom of this document but no other
`
`alterations have been made.
`
`11. Exhibit 2019 is a true and correct copy of Deposition Exhibit No. 9
`
`from the Deposition of Dr. Smith taken on March 23, 2017. It contains an excerpt
`
`(Chapter 11) from Microlithography: Science and Technology by Kazuaki Suzuki
`
`and Bruce W. Smith, published by CRC Press Taylor & Francis Group in 2007,
`
`which was obtained at my direction on February 27, 2017 from the Kresge
`
`Engineering Library at the University of California-Berkeley. An exhibit label
`
`and page numbers have been added to the bottom of this document but no other
`
`alterations have been made.
`
`12.
`
` Exhibit 2020 is a true and correct copy of an excerpt from Silicon
`
`Processing for the VLSI Era Vol. 1 by S. Wolf and R.N. Tauber , published by the
`
`
`
`4
`
`IPR2016-01377 Page 0004
`
`
`
`Lattice Press in 1986, which was obtained at my direction on April 13, 2017 from
`
`the Kresge Engineering Library at the University of California-Berkeley. An
`
`exhibit label and page numbers have been added to the bottom of this document
`
`but no other alterations have been made.
`
`13. Exhibit 2021 is a true and correct copy of an excerpt from
`
`Kenkyusha’s New Japanese-English Dictionary, Fourth Edition, 35th Impression,
`
`published by Kenkyusha Ltd. in 1997, which was obtained at my direction on April
`
`14, 2017 from The Ropes & Gray LLP Library in New York. An exhibit label and
`
`page numbers have been added to the bottom of this document but no other
`
`alterations have been made.
`
`14.
`
` I make this declaration of my own personal knowledge. If called to
`
`testify as to the truth of the matters stated herein, I could and would testify
`
`competently.
`
`15.
`
` I declare under penalty of perjury that the foregoing is true and
`
`correct.
`
`Executed this 14th day of April 2017 in Washington D.C.
`
`
`5
`
`
`
`
`
`
`
`IPR2016-01377 Page 0005
`
`
`
`
`
`Jordan M. Rossen
`
`Jordan M. Rossen
`
`
`
`
`
`
`
`6
`
`IPR2016-01377 Page 0006
`
`IPR2016-01377 Page 0006
`
`
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