`
`Transcript of Bruce Smith, Ph.D.
`
`Date: August 2, 2017
`Case: Taiwan Semiconductor Manufacturing Co., LTD -v- Godo Kaisha IP Bridge 1
`(PTAB)
`
`Planet Depos
`Phone: 888.433.3767
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`WORLDWIDE COURT REPORTING | INTERPRETATION | TRIAL SERVICES
`
`IP Bridge Exhibit 2040
`TSMC v. IP Bridge
`IPR2016-01378
`Page 00001
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`- - - - - - - - - - - - - - - x
`TAIWAN SEMICONDUCTOR : Cases IPR2016-01376,
`MANUFACTURING COMPANY, LTD., : IPR2016-01377,
` Petitioner, : IPR2016-01378,
`v. : IPR2016-01379
`GODO KAISHA IP BRIDGE 1, :
` Patent Owner. : Patent 6,197,696
`- - - - - - - - - - - - - - - X
`
` Deposition of BRUCE SMITH, Ph.D.
` Washington, DC
` Wednesday, August 2, 2017
` 9:06 a.m.
`
`Job No.: 153651
`Pages 1 - 63
`Reported by: Debra A. Whitehead
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`Conducted on August 2, 2017
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`2
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` Deposition of BRUCE SMITH, Ph.D., held at the
`offices of:
`
` FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
` 901 New York Avenue, NW
` Washington, DC 20001-4413
` (202) 408-4000
`
` Pursuant to notice, before Debra A. Whitehead, an
`Approved Reporter of the United States District Court
`and Notary Public of the District of Columbia.
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
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`3
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` A P P E A R A N C E S
` ON BEHALF OF PETITIONER:
` JOSHUA L. GOLDBERG, ESQUIRE
` J. PRESTON LONG, ESQUIRE
` FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
` 901 New York Avenue, NW
` Washington, DC 20001-4413
` (202) 408-4000
`
`ON BEHALF OF PATENT OWNER:
` JAMES L. DAVIS, ESQUIRE
` ROPES & GRAY LLP
` 1900 University Avenue
` 6th Floor
` East Palo Alto, California 94303-2284
` (650) 617-4000
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`Conducted on August 2, 2017
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`4
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` C O N T E N T S
`EXAMINATION OF BRUCE SMITH, Ph.D. PAGE
` By Mr. Davis 6
` By Mr. Goldberg 57
`
` EXHIBITS MARKED IN PRIOR SESSIONS
` (Retained by Counsel)
`TSMC DEPOSITION EXHIBIT PAGE
` Exhibit 1001 U.S. Patent No. 6,197,696 16
` Exhibit 1005 U.S. Patent No. 6,140,226 40
` Exhibit 1014 Translation of Japanese 12
` Patent No. 10-079371
` Exhibit 1030 Silicon VLSI Technology, 55
` Fundamentals, Practice and
` Modeling, by Plummer, et al.
` Exhibit 1031 USLI Technology, Edited by 24
` Chang and Sze
` Exhibit 1049 Declaration of Dr. Bruce W. 7
` Smith, Ph.D., in Support of
` Petitioner's Reply
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`Conducted on August 2, 2017
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`5
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` EXHIBITS MARKED IN PRIOR SESSIONS - CONTINUED
`TSMC DEPOSITION EXHIBIT PAGE
` Exhibit 1050 Declaration of Dr. Bruce W. 7
` Smith, Ph.D., in Support of
` Petitioner's Reply
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
`
`6
`
` P R O C E E D I N G S
` BRUCE SMITH, Ph.D.,
` having been duly sworn, testified as follows:
` EXAMINATION BY COUNSEL FOR PATENT OWNER
`BY MR. DAVIS:
` Q Good morning, Dr. Smith.
` A Good morning.
` Q You understand --
` THE WITNESS: Close the door. Thanks.
` Q You understand that you're under oath?
` A I do.
` Q And you understand that that means you
`must testify truthfully as if you were in front of a
`judge or in a courtroom?
` A Yes, I do.
` Q And is there any reason that would prevent
`you from understanding my questions today that you
`know of?
` A I don't believe so, no.
` Q Are you taking any medications that would
`hinder your ability to understand questions?
` A No, I'm not.
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
`
`7
`
` Q How many times have you been deposed?
` A Somewhere around 15 to 20, maybe a little
`bit more, times.
` Q Do you understand that you are being
`deposed today concerning declarations that you
`signed on July 21, 2017, in IPR 2006-01376 to 01379?
` A That's right.
` Q I'm going to hand you those four
`declarations. And I believe those are Exhibit 1049
`in the 1376 proceeding, and Exhibit 1050 in the
`1377, 1378, and 1379 proceedings.
` (TSMC Exhibit 1049 and Exhibit 1050,
`previously marked, retained by counsel.)
` Q Is that correct?
` A That's what it says.
` Q Can I direct your attention to the -- I
`think we'll be working mostly with the 1376
`declaration that's Exhibit 1049.
` A Okay.
` Q I understand that there's some
`similarities and a lot of overlap between each of
`the four declarations. Is that correct?
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
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`8
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` A That's right.
` Q Turning to Page 6 of Exhibit 1049.
` A I'm there.
` Q Are you discussing the meaning of using
`the designated layer as a mask term here?
` A That's right.
` Q And particularly you're discussing what
`the board's construction or preliminary construction
`is for that term. Is that right?
` A That's right.
` Q Now, I want to ask you about your
`understanding of that construction.
` Does the board's construction preclude,
`for example, a layer positioned between an overlying
`layer and a layer being etched from acting as a mask
`in an instance where the overlying layer also is
`removed during the etching and, thus, the between
`layer acts to shield the layer being etched during
`etching?
` A A layer only becomes a mask if it defines
`an area or areas for etching.
` If, as you've described it, a layer is or
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
`
`9
`
`becomes a layer that is defined for etching, it may
`become a mask. I would have to look at any
`particular situation.
` Q So you would agree with the statement that
`I read, that it -- that the board's -- well,
`actually, let me strike that.
` Does the board's construction allow for
`that situation, where an underlying layer becomes
`exposed during the etching process and, therefore,
`acts to shield the layer being etched during
`etching?
` A No, not necessarily. It's not just a
`shield. It would have to act as a mask to define an
`area for etching. Beyond that, I would have to look
`at a particular example to give you my opinion on
`that.
` Q I'm handing you what is Paper Number 11 in
`the 1376 proceeding, the institution decision.
` Have you seen this document before?
` A I have looked at this document, yes.
` Q Can you turn to Page 18.
` A I'm there.
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
`
`10
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` Q Do you see that Footnote 7 there on the
`bottom of Page 18?
` A I see that.
` Q And you would agree with me that Footnote
`7 reads, "Our construction does not preclude, for
`example, a layer positioned between an overlying
`layer and a layer being etched from acting as a mask
`within the meaning of Claim 13, in an instance where
`the overlaying layer also is removed during the
`etching and, thus, the between layer acts to shield
`the layer being etched during etching"?
` A I see that.
` Q And does that comport with your
`understanding of the board's construction?
` A Yes. And as you've read, it says, our
`construction does not preclude this.
` So in a situation where this instance
`might happen, I have to take a look at that instance
`and decide or determine whether or not that an
`underlying layer that was referred to would actually
`act as a mask, and define area that would be etched
`underneath it.
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`Conducted on August 2, 2017
`
`11
`
` Q So the understanding of using a designated
`layer as a mask that you applied does not depend
`solely on whether the layer acts as a shield for the
`layer being etched during etching?
` A Well, as this statement says, it doesn't
`preclude situations like that. Again, I would have
`to look at the situation.
` But merely being a shield doesn't
`necessarily make it a mask. It would have to define
`an area of etching itself, that underlying layer
`would have to become a mask by defining an area that
`would be etched.
` Q So the understanding of the term "mask"
`that you applied doesn't depend solely on whether or
`not it is acting as a shield for the underlying
`layer being etched?
` A If that shield defines those areas and the
`underlying -- underlying layer that -- the
`underlying -- the layer underlying it is being
`etched by the masking of that layer, it would fit
`into this definition.
` But simply shielding it from -- shielding
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
`
`12
`
`it during etching -- during etching doesn't
`necessarily make it a mask, unless it defines an
`area that is etched under it.
` Q Can you give me an example of a situation
`where a layer would act as a shield for the
`underlying layer being etched but would not define
`an area that is etched?
` A Sure. If that layer that is being etched
`is actually not etched, no etching is occurring, no
`removal of that layer is occurring.
` Q Any other examples?
` A I think broadly that's -- that would fit
`into that.
` Q I'm handing you now what's been marked as
`Exhibit 1014 I believe in the 1376 proceedings.
` (TSMC Exhibit 1014, previously marked,
`retained by counsel.)
` A Can I put the last exhibit aside?
` Q You can, yes.
` Now, this is the translation of the
`Japanese '371 application that you relied on in your
`declarations?
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`Conducted on August 2, 2017
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`13
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` A I can't be sure if it's the same
`translation, but it looks like it's a translation of
`the '371.
` Q Why can't you be sure?
` A I don't recognize the front page,
`Certification of Translation. But I'm not saying
`it's not the same one; I'm not sure.
` Q So turning past the front page, do you
`recognize the remainder?
` A Yes, I do.
` Q So this is the translation of the Japanese
`'371 translation that you relied on in your
`declarations?
` A Again, I don't -- I know it is a
`translation by Richard Patner. I don't recall if
`the translation I used was the same one. But it
`just -- it may be.
` Q You're not sure?
` A Again, I can't -- I can't recall seeing
`this front page. I'm not saying it's not, though.
` Q Can you turn to Paragraph 93. And that is
`on Page 15.
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`Conducted on August 2, 2017
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`14
`
` Are you there?
` A I'm there.
` Q And you see that Paragraph 93 is
`describing Figure 16A?
` A That's what it says, yes.
` Q The last sentence of Paragraph 93 reads,
`"In this case the second resist pattern 359 is
`removed during the step of etching the organic film
`354."
` Do you see that?
` A Let me just read through this paragraph
`quickly.
` I see that last sentence, yes.
` Q And do you agree that the Japanese '371
`application discloses that the second resist pattern
`359 is removed during the step of etching the
`organic film 354?
` A It describes the removal of that resist
`pattern 359 during the etching of -- which, I'm
`sorry, that second resist pattern 359, which is an
`organic photoresist pattern. It states that that
`photoresist pattern 359 is being removed as the
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
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`15
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`organic film 354 is being etched. And that's
`because they are etchable in the same etch chemistry
`that would be used for that organic film 354.
` Q So it's your testimony that the second
`resist pattern 359 is removed during etching of the
`organic film 354?
` A Well, it doesn't say it's fully removed.
`It's a statement that says that 359 is removed
`during that step. That layer 359 would need to
`remain at least partially, some of that material,
`until all of 354 is etched through, becomes 354A.
` And then as the Figure 16B shows, to
`remove resist pattern 359A, one would continue the
`etch process through the organic film 354. Which
`would then completely remove 359.
` Q So your interpretation of this sentence is
`that the second resist pattern is at least partially
`removed during this step of etching the organic film
`354?
` A That's right. It's a -- it's an artifact
`or a consequence of etching an organic film like 354
`with an organic photoresist like 359.
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`Conducted on August 2, 2017
`
`16
`
` Q I'm going to hand you Exhibit 1001, which
`is the '696 patent.
` (TSMC Exhibit 1001, previously marked,
`retained by counsel.)
` Q Do you recognize this exhibit?
` A I do.
` Q Is this the patent at issue in these
`proceedings, U.S. Patent Number 6,197,696?
` A It is, yes.
` Q If I refer to this as the '696 patent,
`will you understand what I'm referring to?
` A Sure, I will.
` Q Can you turn to Figure 16B and C in the
`'696 patent.
` A I'm there.
` Q Moving from Figure 16B to Figure 16C, is
`film 355A being used as a mask in etching film 353?
` A You asked me is 355A being used as a film
`to etch 353?
` Q I'll repeat the question.
` A Thank you.
` Q As the figures transition from 16B to 16C,
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`Conducted on August 2, 2017
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`17
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`is film 355A being used as a mask in etching film
`353?
` A So the patent says, in Column 19, when it
`describes what's going on between Figure 16B and
`16C, Column 19, starting at Line 41, Next as shown
`in Figure 16C, the first silicon dioxide film 353 is
`dry etched using the patterned silicon dioxide film
`355A and the pattern organic 354A as a mask.
` 355A -- I think this is the answer to your
`question -- is used to -- used as the mask to dry
`etch the silicon dioxide film 353.
` Q So is your testimony that film 355A is
`being used as a mask in etching film 353?
` A The paragraph before says that the second
`resist pattern is removed during the step of etching
`the organic film 354. And it says that the second
`silicon dioxide film 353 is dry etched using a
`silicon dioxide film 355A. So those two statements
`in combination tell me that 359, the photoresist
`layer is gone, and that 355A is the mask for 353.
` Q I'm just asking a simple question. Is it
`your testimony that film 355A is being used as a
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
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`18
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`mask in etching film 353?
` A That's right.
` Q Is film 354A being used as a mask in
`etching film 353?
` A It says that in the specification, but
`354A is not -- would not be part of the mask that
`would be etching 353.
` Q So it is your testimony that film 354A is
`not being used as a mask in etching film 353? Well,
`strike that. Let me ask a different question.
` Turning to Figure 23B.
` A Okay.
` Q Do you see Figure 23B?
` A I do.
` Q And 23C? 23.
` A I'm sorry. Which figures, again?
` Q Figure 23B and 23C.
` A I see that.
` Q Is film 505A being used as a mask in
`etching film 503?
` A Can you repeat that, please.
` Q Sure. Is film 505A being used as a mask
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
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`19
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`in etching film 503?
` A It says in Column 24, describing the
`patterning of the second organic film 505A and the
`first organic film 503, using the mask pattern 509,
`and the pattern first silicon dioxide 504A, as
`respective masks. The organic -- first organic film
`503 is therefore etched using the patterned first
`silicon dioxide film 504A as a mask.
` I think that answers your question.
` Q I'm not sure it does, but you're reading
`from Column 24, Lines 7 to 10?
` A Yes, I'm sorry. That's where I'm reading
`from.
` Q My question was a bit different. Is film
`505A being used as a mask in etching film 503?
` A 505A is removed during the etch process
`using 509 as the mask. The same process that etches
`503.
` 504A becomes the defining mask for the
`openings 512, these are the contact hole openings in
`layer 503. And those are masked by 504A.
` Q So is it your testimony that 505A is not
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
`
`20
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`ever used as a mask in etching film 503?
` A 505A is consumed during the process. It's
`designed to be consumed during the process of
`etching 503.
` It defines the opening in 503 until 504A
`is reached. 504A becomes the etch stop to remove
`the contact holes 512.
` So -- go ahead.
` Q I don't mean to interrupt. Are you
`finished?
` A I'm finished, yeah. I'm ready for your
`next question.
` Q You said that film 505A defines the
`opening in 503 during the etch process.
` Is that right?
` A Right. The etch process is directed
`through the opening in 505A, which will act to mask
`503 until 504A is reached. 504A is designed as an
`etch stop in -- in 512. So 505A does act as -- as
`the mask for 503.
` Q Turning to Figure 32A and 32B. I have a
`somewhat similar question.
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
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`21
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` Is film 605A being used as a mask in
`etching film 603?
` A 32B you are asking me?
` Q 32A and B, yes.
` A All right. Is -- can you repeat that,
`please.
` Q Sure. Is film 605A being used as a mask
`in etching film 603?
` A So the onset of etching 605A is removed
`with the same etch process that etches 603.
` The patent describes in Column 29, around
`Line 6, the pattern second organic film 605A and the
`first organic film 603 are dry etched using the mask
`pattern 608, and the pattern silicon dioxide film
`604A as respective masks.
` So the patent describes 604A as a mask for
`the etching of hole 611 into film 603.
` Q Going back to my question. Is film 605A
`being used as a mask in etching film 603?
` A Prior to reaching 604A, the opening in
`605 -- in 605A will act to mask etching until that
`film is removed, until that film is completely
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
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`22
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`removed.
` Q I'm done with the '696 patent for now.
` After a dry etch, is the profile of the
`side walls perfectly vertical?
` A It depends on the dry etch.
` Q Is it your testimony that there are
`certain dry etches that give perfectly vertical side
`wall profiles?
` A Within the capability of measurement or
`within the requirements of manufacturing, yes.
` I -- the word "perfectly" would have to be
`defined in that context.
` Q A 90-degree angle relative to the base.
` A Within the margin allowed through
`measurement or manufacturing tolerances, yes.
` Q What does that mean?
` A It means there can be some allowance in
`variation from that 90 degrees if, for one thing, it
`can't be measured to be other than 90 degrees; or
`the manufacturing influence on a side wall angle
`less than 90 degrees has no impact on the process.
` Q Do all dry etches generate a profile of
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
`
`23
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`the side walls that is perfectly vertical?
` A No. That's -- it's in the requirements of
`engineering a dry etch, is that the side walls
`should be vertical. If anisotrophy,
`A-N-I-S-O-T-R-O-P-Y, is required.
` Q Would you agree that in -- or is it your
`testimony that even in anisotropic etches, there can
`be some finite angle less than 90 degrees from the
`base of the feature towards the top?
` MR. GOLDBERG: Objection. Form.
` A The desired attribute of a multi-layer
`process like dual-damascene and the requirements for
`such a process to operate is the side wall angle
`needs to be vertical. If it's less than 90 degrees,
`it would need to be determined through analysis and
`engineering of that process that its impact would
`influence its use to yield good results.
` Q Is it your testimony that in some
`anisotropic etches there can be some finite angle
`less than 90 degrees from the base of the feature
`towards the top?
` A A process wouldn't be designed that way,
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`09:44:43
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`09:45:36
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
`
`24
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`and it wouldn't be desired. Whether it would be
`allowed to some small extent, one would have to know
`what all the process requirements are.
` Without putting a number to it, some small
`deviation from 90 degrees may be tolerable. To
`understand how tolerable it would be, one would have
`to look at the specific process.
` Q I'm handing you what's been marked as
`Exhibit 1031 in the 1376 proceedings. I believe it
`is similar or the same exhibit that was used in the
`other three proceedings.
` (TSMC Exhibit 1031, previously marked,
`retained by counsel.)
` Q Do you recognize Exhibit 1031?
` A I do, yes.
` Q Is this the Chang and Sze, S-Z-E,
`reference?
` A It is, yes.
` Q And that's what you referred to in your
`declaration in each of these proceedings?
` A That's right.
` Q Did you review this document?
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
`
`25
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` A I did.
` Q Can you turn to Page 52.
` A The stamped Page 52?
` Q Stamped Page 52.
` Is Section 7.3 discussing plasma etching?
` A 7.3 is called Etch Mechanisms,
`Selectivity, and Profile Control, yes.
` Q So Section 7.3 is discussing plasma
`etching?
` A It's discussing certain attributes of
`plasma etching, yes.
` Q And plasma etching is a form of dry
`etching?
` A That's right.
` Q Turning to stamped Page 60.
` A I see that.
` Q Is it your understanding that this is a --
`that Figure 10 is a cross-sectional image of a dry
`etch?
` A It is, as it says, etching on a silicon
`trench edge. So it's as described above the figure.
`It says a typical trench is shown in Figure 10. And
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
`
`26
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`it's done with dry etching.
` Q And is it your testimony that the side
`wall profiles as shown in Figure 10 are vertical?
` A No, they are not vertical.
` Q They have some finite angle less than 90
`degrees from the base relative to the top?
` A Yes. If I can expand on my answer.
`They're not vertical in the sense they are not
`completely vertical. There is some angle which is
`less than 90 degrees.
` Q And the base is narrower than the top is?
` A That's what the picture shows, yes.
` Q Turning to Page 62.
` Section 7.5 is also about plasma etching?
` A That's right.
` Q And that's, again, a form of dry etching?
` A That's right.
` Q Turning to Page 65.
` A I see that.
` Q Looking at Figure 22B at the bottom.
` A I see that.
` Q Is that, again, another etch -- or another
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
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`27
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`trench profile formed by dry etching?
` A It is. It's a -- similar to the figure we
`looked at, Figure 10, it is a trench etch. We see
`micro marker bars in Figure 22A and B, which show
`for Figure 22 an etch through, it looks like
`approximately 5 microns of film. It looks like
`Figure 22B may also be many microns.
` And as we look at Figure 22A and 22B, you
`can see there is the ability to control side wall
`profile during the dry etch process depending on the
`choice of things like pressure, gas, temperature,
`and power.
` Q I am finished with the Chang and Sze
`reference for the moment.
` What is undercutting?
` A Undercutting is the -- in a very general
`sense, referred to -- it refers to the removal of a
`layer laterally under an overlying film.
` Q What causes undercutting?
` A Well, it can be a lot of things. In a
`purely isotropic etch, like a wet etch, if the layer
`being etched is etched downward, at the same or
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`Transcript of Bruce Smith, Ph.D.
`Conducted on August 2, 2017
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`28
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`similar rates that it i
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