`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`and GLOBALFOUNDRIES U.S. INC.,
`Petitioners,
`
`v.
`
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`
`
`Case IPR2016-013791
`
`Patent 6,197,696 B1
`
`
`
`
`
`
`
`
`
`Before JUSTIN T. ARBES, MICHAEL J. FITZPATRICK, and
`JENNIFER MEYER CHAGNON, Administrative Patent Judges.
`
`
`JOINT LIST OF OBJECTIONS TO DEMONSTRATIVES
`
`
`
`
`
`
`
`
`1 GlobalFoundries U.S. Inc.’s motion for joinder in IPR2017-00924 was granted.
`
`
`
`
`
`Petitioner objects to Patent Owner’s slides 9–20, 23, 36, and 38 because
`
`they falsely portray a factual dispute over the application of a claim construction as
`
`a dispute over the claim construction itself. Petitioner further objects to Patent
`
`Owner’s slides 14, 17, 21–23, 36, 38, 41, and 51 because they misrepresent Dr.
`
`Smith’s testimony by using incomplete testimony, taking his testimony out of
`
`context, mischaracterizing it as inconsistent, and/or imputing false significance to
`
`it. Petitioner also objects to Patent Owner’s slides 14–17, 22, 36, 38, 41, 43, 44,
`
`51, and 57 because they present new arguments not presented in the Patent
`
`Owner’s Response, only in improperly argumentative “observations” regarding Dr.
`
`Smith’s cross-examination testimony.
`
`Patent Owner maintains its scope objections (Pap. 36) and objects to the
`
`new arguments/cites in Petitioner’s slides: 5 (reliance on EX1039-EX1040 for this
`
`point), 18-25 (re shifting production burden; improper reliance on Reply to Prelim.
`
`Resp.), 86 (same), 147 (same), 36 (thickness of 355, 353; EX2040 57:22-59:19),
`
`41 (EX1047 95:4-96:21), 45 (fourth bullet), 47 (bullet), 49 (reliance on EX1006,
`
`EX1011 for this point), 64 (bullet), 66 (second bullet on left and parenthetical in
`
`second bullet on right), 68 (three blue bullets), 75 (“No Thinning of Layer 68,”
`
`Figs. 6E-6F), 80 (assertion that layer 58 is “equivalent” to layer 45), 86 (right
`
`column—see 8/18/17 email to Board), 159-160 (entire slides), 162 (header), 165-
`
`166 (citation to references 51-56), 172 (entire slide), 178 (Smith Tr. 27:8-12).
`
`
`
`Dated: September 8, 2017
`
`By: /James L. Davis, Jr./
`James L. Davis, Jr.
`Reg. No. 57,325
`ROPES & GRAY LLP
`1900 University Avenue, 6th Floor
`East Palo Alto, CA 94303-2284
`P: 650-617-4794/F: 617-235-9492
`james.l.davis@ropesgray.com
`
`Lead Counsel for Patent Owner
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`By: /Darren M. Jiron/
`Darren M. Jiron
`Reg. No. 45,777
`
`
`
`
`
`Lead Counsel for Petitioner
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that this JOINT LIST OF OBJECTIONS
`
`TO DEMONSTRATIVES was served by filing this document through the Patent
`
`Trial and Appeal Board PTAB E2E, as well as providing a courtesy copy via e-
`
`mail to the following attorneys of record for the Petitioner listed below:
`
`Petitioner TSMC’s Counsel of Record:
`
`Darren M. Jiron, Darren.jiron@finnegan.com
`E. Robert Yoches, bob.yoches@finnegan.com
`J. Preston Long, j.preston.long@finnegan.com
`Joshua L. Goldberg, Joshua.Goldberg@finnegan.com
`
`FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, LLP
`ATTN: Patent Administration, Two Freedom Square, 11955 Freedom Drive,
`Reston, VA 20190-5675
`
`Petitioner GlobalFoundries’s Counsel of Record:
`
`Christopher Carroll, christopher.carroll@whitecase.com
`75 State St, Boston, MA 02109-1814
`Shamita Etienne-Cummings, setienne@whitecase.com
`701 Thirteenth St NW, Washington, DC 20005-3807
`
`WHITE & CASE, LLP
`Dated:
`September 8, 2017
`
`Respectfully submitted,
`
`
`
`
`
`
`By:
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Crena Pacheco/
`Name: Crena Pacheco
`
`
`ROPES & GRAY LLP
`
`
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