`By: Christopher Frerking (chris@ntknet.com)
`
`Reg. No. 42,557
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`
`
`
`
`SAMSUNG ELECTRONICS CO., LTD.,
`
`Petitioner
`
`v.
`
`DANIEL L. FLAMM,
`
`Patent Owner
`
`CASE IPR2016-01512
`U.S. Patent No. RE40,264
`
`
`PATENT OWNER’S DEMONSTRATIVE EXHIBIT
`
`
`
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`Petitioner’s Reply, from pages 7-8
`In sum, Patent Owner’s argument that “the specific
`
`time interval to change the temperature between etches
`is of no importance” (Response at 5, 19-20) is
`contradicted by Dr. Flamm’s own testimony and
`Kadomura. Moreover, Patent Owner’s assertion that the
`time interval to change temperature does “not constitute
`a factor in the process,” (id. at 9, citing, inter alia, Ex.
`1006 at 6:55-62) misreads Kadomura’s disclosure,
`which simply states that the time interval does “not
`constitute a factor of delaying” (Ex. 1006 at 6:55-62,
`emphasis added) the etch process.4 The time interval to
`change the temperature is a “factor” affecting the
`process and must be controlled as evidenced by Dr.
`Flamm’s testimony. (Ex. 1011 at 101:20-25; see also
`Ex. 1013 at ¶¶ 6-7.)
`
`
`
`
`
`
`
`1
`
`
`
`Unedited Quotations from Patent Owner’s Response
`
`In sum, Patent Owner’s argument that “the specific
`time interval to change the temperature between etches
`is of no importance, since the time interval to change the
`temperature is equal or less than time interval to change
`the gas.” (Response at 5, 19-20) is contradicted by Dr.
`Flamm’s own testimony and Kadomura. Moreover,
`Patent Owner’s assertion that the time interval to change
`temperature does “2. Accordingly, the time period for
`changing the temperature ‘does not constitute a factor’
`in the process,” (id. at 9, citing, inter alia, Ex. 1006 at
`6:55-62) misreads Kadomura’s disclosure, which simply
`states that the time interval does “not constitute a factor
`of delaying” (Ex. 1006 at 6:55-62, emphasis added) the
`etch process.4 The time interval to change the
`temperature is a “factor” affecting the process and must
`be controlled as evidenced by Dr. Flamm’s testimony.
`(Ex. 1011 at 101:20-25; see also Ex. 1013 at ¶¶ 6-7.)
`…………………………………………………………..
`
`Kadomura’s specification teaches:
` 1. The time interval for changing the gas is “equal
`with or more” than the time interval to change the
`temperature;
`2. Accordingly, the time period for changing the
`temperature “does not constitute a factor” in the process.
`Ex. 1006 6:55-62, 7:22-30, 8:43-50, 10:13-16, (Ex.
`2001, ¶16)
`
`
`
`2
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the foregoing PATENT
`
`
`
`
`OWNER’S DEMONSTRATIVE EXHIBIT was served by electronic mail
`
`on this day, October 11, 2017, on the following individuals:
`
`Naveen Modi
`naveenmodi@paulhastings.com
`
`Joseph E. Palys
`josephpalys@paulhastings.com
`
`Chetan R. Bansal
`chetanbansal@paulhastings.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`By: /Christopher Frerking/
` Christopher Frerking, reg. no. 42,557
`
`3
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`
`
`
`
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`
`
`
`
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