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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
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`
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`Taiwan Semiconductor Manufacturing Company Limited
`
`Petitioner
`
`v.
`
`Godo Kaisha IP Bridge 1
`
`Patent Owner
`
`
`
`PETITION FOR INTER PARTES REVIEW
`OF UNITED STATES PATENT NO. 6,538,324
`
`
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`DECLARATION OF DR. LI JIANG
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`TSMC Exhibit 1011
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`Page 1 of 5
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`
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`I, Li Jiang, declare:
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`1.
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`I am a patent agent at the law firm of Finnegan, Henderson, Farabow,
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`Garrett and Dunner LLP.
`
`2.
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`I provide this Declaration in connection with the above-identified
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`Inter Partes Review proceeding. Unless otherwise stated, the facts stated in this
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`Declaration are based on my personal knowledge.
`
`3.
`
`Ex. 1006 is a copy of the paper, Holloway et al., “Tantalum as a
`
`diffusion barrier between copper and silicon: Failure mechanism and effect of
`
`nitrogen additions,” Journal of Applied Physics, 71(11), 5433-5444 (1992), along
`
`with the cover, title pages, and table of contents of the journal. Page 3 of Ex. 1006
`
`(page 4 of Ex. 1006 is a color copy of the same page in the journal) includes a
`
`June 17, 1992, Library of Congress Copyright Office stamp. On June 15, 2016, I
`
`visited https://catalog.loc.gov/, and printed a copy of the Library of Congress
`
`Online Catalog Record of this journal under LC Control No. 33023425 from
`
`https://lccn.loc.gov/33023425. The copy of this record is now Exhibit 1012.
`
`4.
`
`Ex. 1007 is a copy of the paper, Sun et al., “Properties of reactively
`
`sputter-deposited Ta-N thin films,” Thin Solid Films, 236 (1993) 347-351, along
`
`with the cover, title pages, and table of contents of the journal. Page 2 of Ex. 1007
`
`(page 3 of Ex. 1007 is a color copy of the same page in the journal) includes a
`
`December 28, 1993, Library of Congress Copyright Office stamp. On June 15,
`
`2
`
`Page 2 of 5
`
`
`
`2016, I visited https://catalog.loc.gov/, and printed a copy of the Library of
`
`Congress Online Catalog Record of this journal under LC Control No. sf 81005059
`
`from https://lccn.loc.gov/sf81005059. The copy of this record is now Exhibit 1013.
`
`5.
`
`Ex. 1010 is a copy of excerpts from a book, El-Kareh, “Fundamentals
`
`of Semiconductor Processing Technology,” Kluwer Academic Publishers (1995),
`
`obtained from the Library of Congress. Page 2 of Ex. 1010 includes a December
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`21, 1994 Library of Congress Copyright Office stamp, and the text
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`“LCCN 94-37113.” On June 16, 2016, I visited https://catalog.loc.gov/, and printed
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`a copy of the Library of Congress Online Catalog Record of this book under LC
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`Control No. 94037113 from https://lccn.loc.gov/94037113. The copy of this record
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`is now Exhibit 1014.
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`6.
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`Ex. 1015 is a copy of the paper, Stavrev et al., “Crystallographic and
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`morphological characterization of reactively sputtered Ta, Ta-N and Ta-N-O thin
`
`films,” Thin Solid Films, 307 (1997) 79-88, along with the cover, title pages, and
`
`table of contents of the journal. Page 3 of Ex. 1015 (page 4 of Ex. 1015 is a color
`
`copy of the same page in the journal) includes a January 20, 1998, Library of
`
`Congress Copyright Office stamp. On June 20, 2016, I visited
`
`https://catalog.loc.gov/, and printed a copy of the Library of Congress Online
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`Catalog Record of this journal under LC Control No. sf 81005059 from
`
`https://lccn.loc.gov/sf81005059. The copy of this record is now Exhibit 1016.
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`3
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`Page 3 of 5
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`
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`7.
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`Ex. 1017 is a copy of the paper, Duan et al., “Magnetic Property and
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`Microstructure Dependence of CoCrTa/Cr Media on Substrate Temperature and
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`Bias,” IEEE Transactions on Magnetics, Vol. 28, No. 5, September 1992, along
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`with the cover, title pages, and table of contents of the journal. Page 3 of Ex. 1017
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`includes a January 13, 1993, Library of Congress Copyright Office stamp. On June
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`23, 2016, I visited https://catalog.loc.gov/, and printed a copy of the Library of
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`Congress Online Catalog Record of this journal under LC Control No. 74004562
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`from https://lccn.loc.gov/74004562. The copy of this record is now Exhibit 1018.
`
`8.
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`Ex. 1019 is a copy of the paper, Moussavi et al., “Comparison of
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`Barrier Materials and Deposition Processes for Copper Integration,” Proceedings
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`of the IEEE 1998 International Interconnect Technology Conference, pp. 295-97
`
`(1998), along with the cover, title pages, and table of contents of the journal. Page
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`2 of Ex. 1019 includes an August 4, 1998, Library of Congress Copyright Office
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`stamp. Page 3 of Ex. 1019 includes the text “97-80205.” On June 23, 2016, I
`
`visited https://catalog.loc.gov/, and printed a copy of the Library of Congress
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`Online Catalog Record of this book under LC Control No. 97080205 from
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`https://lccn.loc.gov/97080205. The copy of this record is now Exhibit 1020.
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`9.
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`Ex. 1021 is a copy of the paper, Wijekoon et al., “Development of a
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`Production Worthy Copper CMP Process,” 1998 IEEE/SEMI Advanced
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`Semiconductor Manufacturing Conference, pp. 354-63 (1998), along with the
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`4
`
`Page 4 of 5
`
`
`
`cover, title pages, and table of contents of the journal. Page 2 of Ex. 1021 includes
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`an October 30, 1998, Library of Congress Copyright Office stamp. On June 23,
`
`2016, I visited https://catalog.loc.gov/, and printed a copy of the Library of
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`Congress Online Catalog Record of this journal under LC Control No. 96643156
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`from https://lccn.loc.gov/96643156. The copy of this record is now Exhibit 1022.
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`10. Ex. 1023 is a copy of the paper, Wang et al., “Barrier Properties of
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`Very Thin Ta and TaN layers Against Copper Diffusion,” J. Electrochem. Soc.,
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`Vol. 145, No. 7, pp. 2538-45, along with the cover, title pages, and table of
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`contents of the journal. Page 2 of Ex. 1021 includes a July 1998, Library of
`
`Congress Copyright Office stamp. On June 23, 2016, I visited
`
`https://catalog.loc.gov/, and printed a copy of the Library of Congress Online
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`Catalog Record of this journal under LC Control No. 48010635 from
`
`https://lccn.loc.gov/48010635. The copy of this record is now Exhibit 1024.
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`11.
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`I declare that all statements made herein of my knowledge are true,
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`and that all statements made on information and belief are believed to be true, and
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`that these statements were made with the knowledge that willful false statements
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`and the like so made are punishable by fine or imprisonment, or both, under
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`Section 1001 of Title 18 of the United States Code.
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`
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`Dated: June 24, 2016
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`
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`
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`By: /Li Jiang/
`Li Jiang
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`
`
`5
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`Page 5 of 5
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`
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