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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`and GLOBALFOUNDRIES U.S. INC.,
`Petitioners,
`
`v.
`
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`
`
`Case IPR2016-013781
`
`Patent 6,197,696 B1
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`Before JUSTIN T. ARBES, MICHAEL J. FITZPATRICK, and
`JENNIFER MEYER CHAGNON, Administrative Patent Judges.
`
`
`PETITIONER’S RESPONSES TO PATENT OWNER’S MOTION FOR
`OBSERVATIONS REGARDING THE CROSS-EXAMINATION OF
`BRUCE W. SMITH, PH.D.
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`
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`1 GlobalFoundries U.S. Inc.’s motion for joinder in IPR2017-00923 was granted.
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`Petitioner provides the following responses to Patent Owner’s observations
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`on the cross-examination testimony of Bruce W. Smith, Ph.D. (Paper 34).
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`Response to Observation No. 1:
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`Patent Owner’s Observation No. 1 is improper as it contains arguments the
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`Board’s rules do not permit. See Office Trial Practice Guide, 77 Fed. Reg. 48,767-
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`68 (Aug. 14, 2012). Under the guise of a statement of relevance, Patent Owner
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`argues Petitioner and Dr. Smith are attempting “to rewrite the Japanese
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`Application’s express disclosures.” Paper 34, at 1–2. That explanation has nothing
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`to do with relevance. Dr. Smith’s testimony referenced here and in Observation No.
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`1 is relevant, not for the reasons Patent Owner advances, but because that testimony
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`is consistent with the statement in the Japanese ’371 application that “the second
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`silicon dioxide film 355 and the organic film 354 are sequentially dry-etched using
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`the second resist pattern 359 as a mask.” EX1014, at ¶0093; see also EX1050, at
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`¶¶29–36. Observation No. 1 also references incomplete testimony. Dr. Smith was
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`asked, “So it’s your testimony that the second resist pattern 359 is removed during
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`etching of the organic film 354?” EX2040, at 15:4–6. Dr. Smith responded,
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`Well, it doesn’t say it’s fully removed. It’s a statement
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`that says that 359 is removed during that step. That layer
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`359 would need to remain at least partially, some of that
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`material, until all of 354 is etched through, becomes
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`354A. And then as the Figure 16B shows, to remove
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`resist pattern 359A [sic], one would continue the etch
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`process through the organic film 354. Which would then
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`completely remove 359.
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`Id. at 15:7–15.
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`Response to Observation No. 2:
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`As Observation No. 2 notes, Dr. Smith was asked, “Is film 354A being used
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`as a mask in etching film 353?” Dr. Smith responded, “It says that in the
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`specification, but 354A is not -- would not be part of the mask that would be
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`etching 353.” EX2040, at 18:3–7. Dr. Smith was also asked, “Does layer 354
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`become a mask during this process, after layer 355 is completely removed?” Dr.
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`Smith responded (after a form objection from Mr. Davis) that “354, once 355A is
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`removed -- and 354 being the organic film, or an organic film -- would then be
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`masking 353.” EX2040, at 59:20–60:3. This testimony is relevant because it
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`supports Petitioner’s argument that layer 354A does not act as a mask until it is
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`exposed (Paper 26, at 13–14), and supports the Board’s construction finding that “a
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`layer positioned between an overlying layer and the layer being etched” can act as a
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`mask “in an instance where the overlying layer is also removed during the etching,
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`and thus, the between layer acts to shield the layer being etched during etching.”
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`Paper 11, at 18, n.7. It does not contradict Petitioner’s arguments or the Board’s
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`construction, as Patent Owner incorrectly suggests. Dr. Smith’s testimony also
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`highlights the internally inconsistent usage of the term “mask” in the specification
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`of the ’696 patent, as Dr. Smith explained in his declaration. EX1050, at ¶¶20–28.
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`Contrary to Patent Owner’s assertion (Paper 34, at 2–3), Dr. Smith’s testimony
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`cited in Observation No. 2 (EX2040, at 16:1–17:20) is irrelevant to the process for
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`transitioning between Figures 16(c) and 16(d). Dr. Smith’s testimony relates to
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`transitioning between Figures 16(b) and 16(c), not between Figures 16(c) and 16(d).
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`EX2040, at 16:16–18:7.
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`Response to Observation No. 3:
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`Patent Owner’s Observation No. 1 is improper as it contains arguments the
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`Board’s rules do not permit, and because it extends nearly two pages, not a short
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`paragraph as permitted under the rules. See Office Trial Practice Guide, 77 Fed.
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`Reg. 48,767-68 (Aug. 14, 2012). Patent Owner argues that Dr. Smith’s testimony at
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`EX2040, at 18:13–20:20, is relevant to “whether a buried layer that has a lateral
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`edge ‘in line and flush with [a lateral] edge of’ an overlying layer can act as a
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`mask.” Paper 34, at 3. Dr. Smith’s testimony is not relevant to this issue. Nowhere
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`in this passage was Dr. Smith asked about, nor did he testify about buried layers,
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`lateral edges, or in line and flush edges with an overlying layer. Dr. Smith’s
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`testimony in the cited passage relates to the internally inconsistent treatment of
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`masks by the specification of the ’696 patent, as Dr. Smith has extensively opined.
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`EX1050, at ¶¶20–28. Contrary to Patent Owner’s arguments, Dr. Smith’s testimony
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`in this passage about layer 505A from Figs. 23(b) and 23(c) of the ’696 patent are
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`irrelevant to layers 355 and 358 from the Japanese ’371 application. Patent Owner
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`did not ask Dr. Smith about those layers in the cited excerpt. Figures 23(b) and
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`23(c) do not even appear in the Japanese ’371 application. Dr. Smith’s testimony in
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`Observation No. 3 is consistent with, and supports, the Board’s construction finding
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`that “a layer positioned between an overlying layer and the layer being etched” can
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`act as a mask “where the overlying layer is also removed during the etching, and
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`thus, the between layer acts to shield the layer being etched during etching” (Paper
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`11, at 18, n.7), because Dr. Smith explained layer 505A acts as a mask until layer
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`504A is exposed.
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`Response to Observation No. 4:
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`Patent Owner’s Observation No. 1 is improper as it contains arguments the
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`Board’s rules do not permit. See Office Trial Practice Guide, 77 Fed. Reg. 48,767-
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`68 (Aug. 14, 2012). Contrary to Patent Owner’s arguments, Dr. Smith’s testimony
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`at EX2040, at 20:21–22:1, about layer 605A from Figs. 32(a) and 32(b) of the ’696
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`patent is not relevant to different layers 355 and 358 from the Japanese ’371
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`application, about which Dr. Smith was not asked in the cited passage. Patent
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`Owner mischaracterizes and misquotes Dr. Smith’s testimony when it writes,
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`“605A will act to mask etching until the film [603] is removed.” Paper 34, at 5
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`(emphasis added). The proper quotation is, “605A will act to mask etching until
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`that film is removed,” and “that film” refers to layer 605A, not layer 603. EX2040,
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`at 21:20–22:1. Dr. Smith’s opinion about such layers has been consistent from the
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`beginning. See, e.g., EX1002, at ¶¶104–09. Figures 32(a) and 32(b) do not even
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`appear in the Japanese ’371 application. Dr. Smith’s testimony cited in Observation
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`No. 4 is consistent with, and supports, the Board’s construction finding that “a layer
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`positioned between an overlying layer and the layer being etched” can act as a mask
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`“in an instance where the overlying layer is also removed during the etching, and
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`thus, the between layer acts to shield the layer being etched during etching” (Paper
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`11, at 18, n.7), because he explained layer 605A acts as a mask until layer 604A is
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`exposed.
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`Response to Observation No. 5:
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`Patent Owner’s Observation No. 1 is improper as it contains arguments the
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`Board’s rules do not permit. See Office Trial Practice Guide, 77 Fed. Reg. 48,767-
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`68 (Aug. 14, 2012). Patent Owner argues Dr. Smith’s testimony at EX2040, at
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`27:13–33:12, contradicts his opinions provided regarding whether vertical sidewalls
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`have a role in masking. Paper 34, at 5–7. The testimony cited does not support
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`Patent Owner’s argument or lead to its conclusion, as nowhere in the cited passage
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`was Dr. Smith asked whether vertical sidewalls have a role in masking. Patent
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`Owner also improperly re-argues here that “vertical sidewalls block lateral removal
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`and lateral flow of etchant.” Id. at 7. None of the cited testimony supports this
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`argument, as Dr. Smith was never asked about, nor did he ever testify about any
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`function of a vertical sidewall in an etching process. Patent Owner was asking about
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`RIE in the abstract, not about any processes at issue in these proceedings or even
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`dual damascene processes. In that regard, Dr. Smith testified, “The desired attribute
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`of a multi-layer process like dual-damascene and the requirements for such a
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`process to operate is the side wall angle needs to be vertical.” EX2040, at 23:11–14.
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`He also stated that “[w]ithin the capability of measurement or within the
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`requirements of manufacturing,” dry etches can provide “perfectly vertical
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`sidewalls.” EX2040, at 22:6–10.
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`Response to Observation No. 6:
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`Patent Owner’s Observation No. 1 is improper as it contains arguments the
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`Board’s rules do not permit. See Office Trial Practice Guide, 77 Fed. Reg. 48,767-
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`68 (Aug. 14, 2012). Patent Owner argues Dr. Smith made a concession at EX2040,
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`at 33:13–38:9, whether vertical sidewalls block lateral removal and lateral flow of
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`etchant. Paper 34, at 8. The testimony cited does not support Patent Owner’s
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`argument or lead to its conclusion, as nowhere in the cited passage was Dr. Smith
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`asked about vertical sidewalls or whether they have any role in blocking lateral
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`removal or lateral flow of etchant. Patent Owner was asking about RIE in the
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`abstract, not about any processes at issue in these proceedings or even dual
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`damascene processes. In that regard, Dr. Smith testified, “The desired attribute of a
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`multi-layer process like dual-damascene and the requirements for such a process to
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`operate is the side wall angle needs to be vertical.” EX2040, at 23:11–14. He also
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`stated, “Within the capability of measurement or within the requirements of
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`manufacturing,” dry etches can provide “perfectly vertical sidewalls.” EX2040, at
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`22:6–10.
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`Response to Observation No. 7:
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`Patent Owner’s Observation No. 1 is improper as it contains arguments the
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`Board’s rules do not permit. See Office Trial Practice Guide, 77 Fed. Reg. 48,767-
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`68 (Aug. 14, 2012). Patent Owner argues Dr. Smith’s testimony (EX2040, at
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`40:13–50:3) “contradicts and is inconsistent with [his] earlier opinion . . . that
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`‘while concurrently removing’ covers a case where the photoresist layer is not
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`completely removed as an underlying film is etched.” Paper 34, at 8 (quoting
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`EX1050, at ¶46 n.1). Dr. Smith’s testimony directly supports his opinion. The
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`testimony in Observation No. 7 is incomplete and misleading. In full, the exchange
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`states the opposite of what Patent Owner suggests:
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`Q What is the difference between concurrently and partially
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`concurrently?
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`A
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`In the case of partially concurrently, since the etching is
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`being done in two layers, the first dielectric and the second dielectric,
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`simply -- that simply said, concurrently, it wouldn't cover the
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`situation where one layer is removed before another layer is
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`completely removed.
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`Q Okay.
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`A
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`If in the first instance there is a situation where not -- for
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`instance, not all the photoresist is gone during the concurrent
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`removal, one would know that an overetch would strip the
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`photoresist. So I don’t think “partially concurrently” is appropriate
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`in the first instance.
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`EX2040, at 44:16–45:6 (emphasis added). Dr. Smith explained several times that
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`“transferring [a pattern into a dielectric layer]. . . while concurrently removing [a
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`layer of photoresist]” (EX1005, at 13:47–50) means the photoresist is also being
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`etched during the entire period of time the pattern is being etched into the dielectric.
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`See EX2040, at 45:1–6, 46:4–48:5. He stated, “I think concurrent is appropriate,
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`since it’s talking about an etch step and a [concurrent] removal step,” not mutually
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`concurrent dielectric patterning and photoresist removal steps. EX2040, at 46:8–
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`47:1. In other words, dielectric patterning must be completed before the photoresist
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`removal is completed. He contrasted this with “transferring, at least partially
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`concurrently, [one dielectric] layer . . . and [another dielectric] layer” (EX1005, at
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`13:54–58), because “[t]here are two . . . transfer processes [that] are occurring
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`concurrently. But since they may not take the same time to complete, they would
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`only be partially concurrent.” EX2040, at 45:11–19. The “partially concurrent”
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`transfer step allows for either layer to finish being patterned before the other,
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`whereas the “concurrent” removal of the photoresist does not allow for the
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`photoresist mask to be completely removed before dielectric layer is done being
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`etched. Dr. Smith’s testimony cited in Observation No. 7 thus supports his opinion
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`that the Grill provisional supports Grill’s claim 28.
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`Response to Observation No. 8:
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`Patent Owner’s Observation No. 1 is improper as it contains arguments the
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`Board’s rules do not permit. See Office Trial Practice Guide, 77 Fed. Reg. 48,767-
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`68 (Aug. 14, 2012). Patent Owner argues Grill is not entitled to an earlier effective
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`prior-art date based on the same incomplete and misleading quotation it presented
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`in Observation No. 7 (discussed above). Patent Owner’s analysis of these
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`misleading and incomplete statements is improper for a motion for observations,
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`and premised on a failure to understand the difference between the phrase
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`“transferring . . . while concurrently removing” and the phrase “transferring, at least
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`partially concurrently, [one] layer . . . and [another] layer” (also discussed above).
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`EX1005, at 13:47–50, 13:54–57.
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`Response to Observation No. 9:
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`Patent Owner’s Observation No. 1 is improper as it contains arguments the
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`Board’s rules do not permit. See Office Trial Practice Guide, 77 Fed. Reg. 48,767-
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`68 (Aug. 14, 2012). Patent Owner argues Dr. Smith’s testimony (EX2040, at
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`43:13–50:5) “is inconsistent with [his] previous opinions in EX1050, at ¶36, that an
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`‘overetch’ technique is used to remove resist pattern 359” and “inconsistent with
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`Petitioner’s assertion that the ‘overetch’ technique is used to remove resist pattern
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`359.” Paper 34, at 10–11. To begin, Dr. Smith’s testimony is the opposite of what
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`Patent Owner claims. Dr. Smith testified, “That photoresist would be removed
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`through the continuation of that step until all the photoresist is gone, and overetch
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`would occur.” EX2040, at 48:2–5; see also id. at 45:1–6, 46:14–48:5. In addition,
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`Dr. Smith’s testimony in Observation No. 9 is about claim 28 of the Grill reference.
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`EX2040, at 43:13–50:5. It is not about resist pattern 359 of the ’696 patent or
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`Japanese ’371 application, and is thus irrelevant for Patent Owner’s purposes.
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`Response to Observation No. 10:
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`Patent Owner’s Observation No. 1 is improper as it contains arguments the
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`Board’s rules do not permit, and because by extending nearly two pages, it is not a
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`short paragraph as the rules permit. See Office Trial Practice Guide, 77 Fed. Reg.
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`48,767-68 (Aug. 14, 2012). Patent Owner argues “Dr. Smith’s understanding of the
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`term ‘substantially overlap’ includes situations where the feature (i.e., opening) of
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`underlying via pattern shares the exact same feature (i.e., opening) of an overlying
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`wire pattern, thereby eliminating the distinction between the via pattern and the
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`wire pattern.” Paper 34, at 12. Rather than make observations about Dr. Smith’s
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`cross-examination testimony, Observation No. 10 focuses solely on his declaration,
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`which states, “the via pattern substantially (even completely) overlaps the wiring
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`pattern.” EX1050, at ¶57. The statement means only that the entire via pattern
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`overlaps part of the wiring pattern, not that all of the wiring pattern completely
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`overlaps the via pattern. The testimony in Observation No. 10 merely states that
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`“the dual relief pattern collectively refers to the openings in the blue layer, that’s a
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`wiring pattern, and a green layer, a via pattern.” EX2040, at 50:20–51:1. Dr. Smith
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`nowhere suggests the wiring and via patterns would be identical patterns, which, as
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`Patent Owner observes, would be “nonsensical.” Paper 34, at 12.
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`Response to Observation No. 11:
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`Patent Owner’s Observation No. 1 is improper as it contains arguments the
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`Board’s rules do not permit. See Office Trial Practice Guide, 77 Fed. Reg. 48,767-
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`68 (Aug. 14, 2012). Under the guise of a statement of relevance, Patent Owner
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`improperly mischaracterizes Dr. Smith’s prior opinion, and argues his cross-
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`examination testimony contradicts it. Dr. Smith never opined that “no such cross-
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`sections proposed by Patent Owner in the preliminary response could exist.” Paper
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`34, at 13. He stated only that any such patterns would involve “obscure, restrictive,
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`and difficult-to-imagine circuit layouts with complex and unnecessary shapes.”
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`EX1050, at ¶26. Dr. Smith’s testimony (EX2040, at 52:2–53:6), referenced here
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`and in Observation No. 11, follows his position that the cross-sections illustrated in
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`the ’696 patent are not uniform throughout. See, e.g., EX2040, at 53:2–6; EX1002,
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`at ¶226. The conclusion IPB seeks to draw from Dr. Smith’s deposition testimony
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`(i.e., that the ’696 patent illustrates layer 509 acting as a mask in transitioning from
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`Figure 22(b) to 22(c)) does not follow. Even Patent Owner’s own expert rejected
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`Patent Owner’s unsupported argument layer 509 is a mask in Figures 22(b) to 22(c).
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`EX1048, at 97:12–99:21.
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`Response to Observation No. 12:
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`Patent Owner’s Observation No. 1 is improper as it contains arguments the
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`Board’s rules do not permit. See Office Trial Practice Guide, 77 Fed. Reg. 48,767-
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`68 (Aug. 14, 2012). Under the guise of a statement of relevance, Patent Owner
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`argues Dr. Smith’s prior declaration testimony “improperly imported descriptions
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`from Grill’s embodiment of Figure 6A into Grill’s embodiment of Figures 5A-5H.”
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`Paper 34, at 14. Whether column 8, lines 24 to 31, of Grill describe Figure 5 is
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`irrelevant. The preceding paragraph states FIGS. 6A–6F show a “variation of the
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`FIG. 5 method.” EX1005, at 8:9–13. Dr. Smith’s declaration, which Patent Owner’s
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`Observation No. 12 references, states, “Grill’s hard mask layers are about 20 to 50
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`nm thick,” finding the description of Grill at column 8, lines 24 to 31,
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`representative of what a POSITA would have understood the thickness of the hard
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`mask layers in Grill’s embodiments would be. EX1050, at ¶65. His opinion is
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`consistent not only with the written description of Grill, but also with the ’696
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`patent and other examples of record. See, e.g., EX1001, at 10:44–45, 15:9–11,
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`16:59–64, 19:8–12, 21:5–7, 23:1–3, 25:9–11, 28:14–16, 30:14–16; EX1005, at
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`8:24–31; EX1010, at 7:4–6.
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`Response to Observation No. 13:
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`Patent Owner’s Observation No. 1 is improper as it contains arguments the
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`Board’s rules do not permit. See Office Trial Practice Guide, 77 Fed. Reg. 48,767-
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`68 (Aug. 14, 2012). Under the guise of a statement of relevance, Patent Owner
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`argues Dr. Smith’s prior declaration testimony “is importing teachings into the ’696
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`patent and the Japanese ’371 application.” Paper 34, at 15. Whether the ’696 patent
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`or the Japanese ’371 application specifically use the term “overetch” is irrelevant to
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`whether they describe an overetch process. Dr. Smith’s declaration explains how
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`the Japanese ’371 application describes overetch, and explains that overetch is so
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`well known in the art it has a name. EX1050, at ¶36. The cited testimony (EX2040,
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`at 53:17–54:11) is also incomplete. See EX2040, at 54:12–57:4. Dr. Smith further
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`testified that overetch “was something that was commonly known, and one of
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`ordinary skill would have carried this out,” citing the Chang & Sze reference
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`(EX1032). EX2040, at 55:14–17. He also noted that “some overetch is always done
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`in manufacturing to ensure the etch goes to completion everywhere,” citing the
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`Plummer reference (EX1031). EX2040, at 56:21–57:4.
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`Dated: August 23, 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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`CERTIFICATE OF SERVICE
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`Under 37 C.F.R. § 42.6(e), this is to certify that I served a true and correct
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`copy of the PETITIONER’S RESPONSES TO PATENT OWNER’S
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`MOTION FOR OBSERVATIONS REGARDING THE CROSS-
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`EXAMINATION OF BRUCE W. SMITH, PH.D. by electronic mail, on this
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`23rd day of August, 2017, on counsel of record for the 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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`IPBridgeTSMCPTABService@ropesgray.com
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`Patent Owner has agreed to electronic service.
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`A true and correct copy of the PETITIONER’S RESPONSES TO
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`PATENT OWNER’S MOTION FOR OBSERVATIONS REGARDING THE
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`CROSS- EXAMINATION OF BRUCE W. SMITH, PH.D. was also served by
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`electronic mail, on this 23rd day of August, 2017, on counsel of record for
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`Petitioner GlobalFoundries U.S. Inc. at the following:
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`David Tennant
`dtennant@whitecase.com
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`Shamita Etienne-Cummings
`setienne@whitecase.com
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`Allen Wang
`allen.wang@whitecase.com
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`wcptab@whitecase.com
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`Dated: August 23, 2017
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`WCGlobalFoundriesIPR1Team@whitecase.com
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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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