In The Matter Of:
`Taiwan Semiconductor Manufacturing Co., Ltd. v.
`Godo Kaisha IP Bridge 1
`
`Dr. Stanley R. Shanfield
`Vol. I
`March 27, 2018
`
`68 Commercial Wharf • Boston, MA 02110
`888.825.3376 - 617.399.0130
`Global Coverage
`court-reporting.com
`
`Original File Stanley R. Shanfield.txt
`Min-U-Script® with Word Index
`IP Bridge Exhibit 2009
`TSMC v. Godo Kaisha IP Bridge 1
`IPR2017-01841
`
`

`

`Taiwan Semiconductor Manufacturing Co., Ltd. v.
`Godo Kaisha IP Bridge 1
`
`Page 1
`
`Dr. Stanley R. Shanfield - Vol. I
`March 27, 2018
`Page 3
`
`VOLUME: I
`PAGES: 1-186
`EXHIBITS: 0
`
` 1
` 2
` 3
` 4
` 5
` 6
`PATENT 7,893,501
` 7 ____________________________________
` 8 TAIWAN SEMICONDUCTOR MANUFACTURING )
` 9 CO., LTD,
`)
`10
`11 vs.
`12 GODO KAISHA IP BRIDGE 1,
`13
`)
`Patent Owner.
`14 ____________________________________)
`15
`DEPOSITION OF STANLEY R.
`16 SHANFIELD, PhD, called as a witness by and on
`17 behalf of the Patent Owner, pursuant to the
`18 applicable provisions of the Federal Rules of Civil
`19 Procedure, before P. Jodi Ohnemus, RPR, RMR, CRR,
`20 CA-CSR #13192, NH-LSR #91, MA-CSR #123193, and
`21 Notary Public, within and for the Commonwealth of
`22 Massachusetts, at the offices of WilmerHale, 60
`23 State Street, Boston, Massachusetts, on Tuesday,
`24 March 27, 2018, commencing at 9:09 a.m.
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CASE NO. IPR2017-01841
`
`Petitioner,
`
`)
`
`)
`
`)
`
`WOLF GREENFIELD & SACKS, P.C.
`BY: Joshua J. Miller, Esq.
`-and-
`Richard F. Giunta, Esq.
`600 Atlantic Avenue
`Boston, MA 02210-2206
`617 646-8000
`Jmiller@wolfgreenfield.com
`Rgiunta@wolfgreenfield.com
`For the Patent Owner
`
`1 APPEARANCES: (CONT'D)
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`PAGE
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`6
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`Page 2
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`WILMER CUTLER PICKERING HALE
`
`AND DORR LLP
`
`BY: Michael H. Smith, Esq.
`
`-and-
`
`David Cavanaugh, Esq.
`
`1875 Pennsylvania Avenue, NW
`
`Washington, DC 20006
`
`202 663-6055
`
`Michaelh.smith@wilmerhale.com
`
`David.cavanaugh@wilmerhale.com
`
`-and-
`
`TAIWAN SEMICONDUCTOR MANUFACTURING
`
`COMPANY, LTD.
`
`BY: Willy Chang, Esq.
`
`8, Li-Hsin Rd.
`
`6 Hsinchu Science Park
`
`Hsinchu 30078, Taiwan
`
`For the Petitioner
`
`I N D E X
`
` 1
` 2
` 3 TESTIMONY OF:
` 4
` 5 STANLEY R. SHANFIELD, PhD
` 6 (By Mr. Miller)
` 7
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`Taiwan Semiconductor Manufacturing Co., Ltd. v.
`Godo Kaisha IP Bridge 1
`
`Page 5
`
` 1 E X H I B I T S
` 2 EXHIBIT DESCRIPTION PAGE
` 3
` 4 Exhibit 1002 previously marked 12
` 5 Exhibit 1001 previously marked 21
` 6 Exhibit 1004 previously marked 95
` 7
` 8
` 9
`10
`11
`12
`13
`14
`15
`16
`17
`18
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`
`Dr. Stanley R. Shanfield - Vol. I
`March 27, 2018
`Page 7
` 1 A. 342 Otis Street, Newton, Massachusetts.
` 2 Q. And your current employer?
` 3 A. Draper Laboratory.
` 4 Q. And what is your position?
` 5 A. I am distinguished member of technical
` 6 staff.
` 7 Q. And how long have you been at Draper
` 8 Laboratories?
` 9 A. Since 2003. So that would be about 15
`10 years.
`11 Q. And are you currently engaged in other
`12 expert matters?
`13 A. One other, yes.
`14 Q. And just for the ground rules for today,
`15 I'm sure you've been deposed before, but each time
`16 it's helpful to walk through them.
`17 You understand that you are under oath?
`18 A. Sure. Yes.
`19 Q. And you understand that because this is a
`20 question-answer format, any responses need to be
`21 audible, and a head nod or a head shake is
`22 insufficient.
`23 A. I understand that, yes.
`24 Q. All right. Thank you.
`
`Page 6
` 1 STANLEY R. SHANFIELD, PhD, having
` 2 satisfactorily been identified by
` 3 the production of a driver's license,
` 4 and being first duly sworn by the Notary
` 5 Public, was examined and testified as
` 6 follows to interrogatories
` 7 BY MR. MILLER:
` 8 Q. Good morning, Doctor Shanfield.
` 9 A. Good morning.
`10 Q. Could you --
`11 MR. SMITH: Real quick: I just wanted to
`12 note on the record Doctor Shanfield has a clean
`13 copy of the '501 patent, TSMC 1001, as well as
`14 copies of his declarations, and you guys are
`15 welcome to flip through those if you'd like.
`16 MR. MILLER: Okay. Thank you.
`17 Q. Could you state your name for the record,
`18 please.
`19 A. Stanley Shanfield.
`20 Q. And could you spell your name, please.
`21 A. Stanley, S-t-a-n-l-e-y, Shanfield,
`22 S-h-a-n-f-i-e-l-d.
`23 Q. Thank you.
`24 What is your address?
`
`Page 8
`
` 1 And even if Counsel objects, you still
` 2 need to respond to the question, unless your
` 3 counsel is instructing you not to answer.
` 4 A. I understand that. Thank you.
` 5 Q. And if at any point today if there -- if I
` 6 ask a question and it's unclear, please help me
` 7 understand what the point of misunderstanding is,
` 8 and we can fine tune the question so that we can
` 9 understand each other.
`10 A. Sure. Yes.
`11 Q. Have you ever been convicted of a crime?
`12 A. No.
`13 Q. Have you ever been convicted of perjury?
`14 A. No.
`15 Q. Have any of your expert reports ever been
`16 excluded?
`17 A. No.
`18 Q. So there's never been a report struck on
`19 Daubert grounds or anything like that?
`20 A. No, not to my knowledge.
`21 Q. And are you under the influence of any
`22 medication today or anything that would prevent you
`23 from testifying fully and honestly?
`24 A. No.
`
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`Taiwan Semiconductor Manufacturing Co., Ltd. v.
`Godo Kaisha IP Bridge 1
`
`Page 9
`
` 1 Q. So today's deposition is going to cover
` 2 your declarations that were filed in the 1841,
` 3 1842, 1843, and 1844 proceedings.
` 4 Do you understand that?
` 5 A. Yes.
` 6 Q. And do you understand that this deposition
` 7 is going to be used in both the 1841 and the 1843
` 8 proceedings?
` 9 A. Yes, I understand that.
`10 Q. How many hours did you spend leading up to
`11 the filing of declarations in these matters?
`12 A. I'd have to think through and look through
`13 my calendar to get a reasonable estimate, but it
`14 was significant.
`15 Q. Is significant more than 100?
`16 A. It's at least on that order of 100.
`17 Q. More than 200?
`18 A. Like I said, I -- to get any more accurate
`19 than that, I'd -- I would need to look in my
`20 calendar and add it up.
`21 Q. Was the time equally divided between the
`22 841 and 842 petitions, versus the 843 and 844
`23 petitions?
`24 A. I -- once again, to really know if it was
`
`Dr. Stanley R. Shanfield - Vol. I
`March 27, 2018
`Page 11
` 1 person, but it was all mostly these two gentlemen
` 2 (indicating).
` 3 Q. Did you review any documents during the --
` 4 these preparatory sessions?
` 5 A. Yes.
` 6 Q. And what documents did you review?
` 7 A. All the documents relevant to the case.
` 8 So everything I had originally looked at when I
` 9 wrote the declaration, and that's -- that's a lot
`10 of -- a long list of documents.
`11 Q. Did you look at any documents that were
`12 not filed in the IPRs?
`13 A. In the last few days, or over the course
`14 of the entire writing of my declaration?
`15 Q. Let's start with the writing of your
`16 declaration.
`17 A. Yes, I did.
`18 Q. So there were documents that you reviewed
`19 in drafting your declaration that were not filed
`20 with your declaration.
`21 A. To clarify: I looked through technical
`22 data, patents, published papers, and I made
`23 selections as to what to file from that.
`24 So that's what I'm referring to.
`
`Page 10
`
` 1 equal, I'd have to check.
` 2 Q. How many hours did you spend preparing for
` 3 today's deposition?
` 4 A. Specifically for coming here?
` 5 Well, I guess I consider the writing my
` 6 declaration as part of that preparation. So, I
` 7 mean, it would be essentially the time I've spent
` 8 on the declaration.
` 9 Q. And since the declaration was filed --
`10 there is a moment in time when that was filed.
`11 Since that time, has there been preparation in
`12 advance of this deposition today?
`13 A. Yes.
`14 Q. And how much time was spent in that
`15 preparation?
`16 A. In terms of hours, probably 20 to 30. And
`17 that's just an estimate. Once again, I have
`18 records of it, but I would need to check.
`19 Q. Were there several meetings leading up to
`20 this deposition?
`21 A. I met with counsel, yes.
`22 Q. Was it anyone besides the counsel that's
`23 here today?
`24 A. There were -- there was at least one other
`
`Page 12
` 1 Q. And for today's -- for the preparation for
` 2 today's deposition, were there documents that were
` 3 not filed that you reviewed?
` 4 MR. SMITH: Objection.
` 5 A. I don't recall any. Doesn't mean -- it's
` 6 possible, but I don't recall any.
` 7 Q. Do you have a copy of your Exhibit 1002
` 8 declaration?
` 9 A. Yes.
`10 Q. I'm actually thrown off my game. I've
`11 never had a witness come with their own exhibits
`12 before.
`13 You said you had a copy of the 1002
`14 declaration?
`15 A. Yes, I did.
`16 Q. Could you turn to paragraph 16, please.
`17 (Exhibit 1002, previously marked.)
`18 MR. SMITH: If -- Counsel, if you brought
`19 copies, could I get a copy of that?
`20 MR. MILLER: Okay. I feel like there's a
`21 joke in there about witness being ready and counsel
`22 not.
`23 Q. Do you see paragraph 16?
`24 A. Yes.
`
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`Taiwan Semiconductor Manufacturing Co., Ltd. v.
`Godo Kaisha IP Bridge 1
`
`Page 13
` 1 Q. It says that you were being compensated at
` 2 your normal consulting rate; is that correct?
` 3 A. Yes, that's correct.
` 4 Q. What is your normal consulting rate?
` 5 A. $385 an hour.
` 6 Q. Is that your normal consulting rate for
` 7 expert witness work?
` 8 A. Yes.
` 9 Q. Is it the same rate for technical expert
`10 work?
`11 Let me clarify that question.
`12 If you're hired in the semiconductor field
`13 outside of the patent context or outside of a
`14 litigation matter, what is your consulting rate?
`15 A. It might be that rate. Sometimes it's a
`16 different rate.
`17 Q. Is it a higher or lower rate?
`18 A. Lower.
`19 Q. We're going to go a little backwards.
`20 Do you see paragraph 15?
`21 A. Yes.
`22 Q. According to paragraph 15, you reviewed
`23 the file history of the '501 patent?
`24 A. (Witness reviews document.) Yes.
`
`Dr. Stanley R. Shanfield - Vol. I
`March 27, 2018
`Page 15
`
` 1 Q. Do you remember reviewing a patent
` 2 called -- with the -- excuse me. Let me rephrase.
` 3 Do you remember reviewing a document -- or
` 4 -- wow. I apologize. I'm tripping over my own
` 5 words.
` 6 Do you remember reviewing a patent with
` 7 the inventor Matsuda listed?
` 8 A. Well, it would help me if I had the
` 9 document in front of me of the history, and I can
`10 recall more clearly what I may have looked at.
`11 When a reference was mentioned, I
`12 typically at least take a look at it. And so
`13 depending on where that appeared and in what
`14 context in the document, I may have looked at it.
`15 Q. Did you review the institution decisions
`16 in these proceedings?
`17 A. I did.
`18 Q. Returning to Exhibit 100 -- your Exhibit
`19 1002 declaration --
`20 A. Uh-huh.
`21 Q. -- in paragraph 20, do you identify the --
`22 what you used as the priority date for the claims
`23 of the '501 patent?
`24 A. Yes, I do identify it in paragraph 20.
`
`Page 14
`
`Page 16
`
` 1 Q. Did you review the entirety of the file
` 2 history, or just the portions that were filed as
` 3 exhibits to your declarations?
` 4 A. I don't actually recall. I think it was
` 5 just what was listed as exhibits.
` 6 Q. In the file history the examiner would
` 7 occasionally identify what it -- what the examiner
` 8 asserted were prior art references; correct?
` 9 A. Yeah. Maybe if you want you could refer
`10 me to the document, and I'll -- I can comment on it
`11 probably more accurately.
`12 Q. We may get to that, but my -- my question
`13 is a little more focused on just simply what you
`14 reviewed --
`15 A. Uh-huh.
`16 Q. -- as you were preparing your
`17 declarations.
`18 Did you review the references that the
`19 examiner highlighted in the prosecution file
`20 history?
`21 A. I reviewed the -- the file history itself.
`22 I don't recall -- it depends on which document
`23 you're referring to, but chances are I didn't go
`24 through every document that was referenced.
`
` 1 Q. And what is that date?
` 2 MR. SMITH: Objection.
` 3 A. So what I wrote in paragraph 20 is --
` 4 applied the date of June 16, 2003, which is the
` 5 filing date of the foreign application.
` 6 Q. So that is the date for the person of
` 7 ordinary skill in the art that you applied in your
` 8 analysis?
` 9 MR. SMITH: Objection.
`10 A. Yes, that is. Yes.
`11 Q. Could you turn to paragraph 32 in your
`12 declaration, please.
`13 In paragraph 32 did you identify the
`14 qualifications of a person of ordinary skill in the
`15 art?
`16 A. Yes, I did.
`17 Q. And could you read that definition that
`18 you used.
`19 A. What I wrote was "A person of ordinary
`20 skill in the art at the time of the alleged
`21 invention of the '501 patent would have had the
`22 equivalent of a master's degree in electrical
`23 engineering, physics, chemistry, materials science,
`24 or equivalent training, and two years of work
`
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`Taiwan Semiconductor Manufacturing Co., Ltd. v.
`Godo Kaisha IP Bridge 1
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`Page 17
`
`Dr. Stanley R. Shanfield - Vol. I
`March 27, 2018
`Page 19
`
` 1 experience in the field of semiconductor
` 2 manufacturing."
` 3 Q. Would a person with any one of those
` 4 degrees and two years of experience in
` 5 semiconductor manufacturing qualify as a POSA?
` 6 A. Well, what I said was a person of ordinary
` 7 skill in the art would have had equivalent of -- of
` 8 a master's degree in any one of those fields I
` 9 named, or equivalent training, and two years of --
`10 of semiconductor manufacturing experience.
`11 Q. Would a person with a master's degree in
`12 electrical engineering and two years of work
`13 experience in the field of semiconductor
`14 manufacturing be a POSA?
`15 A. Yes, that would qualify him or her.
`16 Q. And if he or she had a master's degree in
`17 physics and two years of work experience in
`18 semiconductor manufacturing, that would also be a
`19 POSA?
`20 A. Yes, that is correct.
`21 Q. And the same thing: If a person had a
`22 master's degree in chemistry and two years of work
`23 experience in the field of semiconductor
`24 manufacturing they would be a POSA?
`
` 1 A. I probably did, but as I have said in
` 2 this -- in my declaration, I'm viewing and made my
` 3 opinions from the point of view of a person of
` 4 ordinary skill, as defined in paragraph 32.
` 5 Q. How did you go about ensuring that your
` 6 opinions were in the perspective of that person in
` 7 2003?
` 8 A. I'm familiar with people that meet that
` 9 description, and I understand how they would view
`10 the '501 patent, how they would interpret it.
`11 Q. You said that you're familiar with people
`12 that meet that description.
`13 Are you referring to people that you know
`14 today?
`15 A. The picture I form is of someone in
`16 2003 -- or thereabouts and meeting these
`17 qualifications, how they would view the prior art
`18 and the '501 patent at the time.
`19 Q. Are all of your opinions in your
`20 declarations provided through the prism of a POSA
`21 in the 2003 time frame?
`22 A. Well, I -- I don't know what you mean by
`23 "the prism." That -- that term isn't something I
`24 understand.
`
`Page 18
`
`Page 20
`
` 1 A. Yes, that's correct.
` 2 Q. And when I use the term "POSA," are -- are
` 3 we on the same page that "POSA" is an acronym for
` 4 person of ordinary skill in the art?
` 5 A. Yes. Yes, I understand.
` 6 Q. And if I use that throughout this
` 7 deposition, we'll understand each other?
` 8 A. That's fine.
` 9 Q. In the tail end of paragraph 32 it states,
`10 "I would have been a person with at least ordinary
`11 skill in the art of the '501 patent as of the time
`12 of its alleged invention."
`13 Do you see that statement?
`14 A. Yes, I do.
`15 Q. In 2003 what degrees did you have?
`16 A. I had the degrees I have now: A PhD in
`17 physics and a -- a bachelor's degree in physics.
`18 Q. In 2003 how long had you been working in
`19 semiconductor manufacturing?
`20 A. That would be approximately 20 years --
`21 15 -- 18 years.
`22 Q. Do you believe that you had more than
`23 ordinary skill as of 2003?
`24 MR. SMITH: Objection.
`
` 1 Q. Are all of your opinions in your
` 2 declarations provided through the eyes of a POSA in
` 3 the 2003 time frame?
` 4 MR. SMITH: Objection.
` 5 A. That is what I -- yes, that -- that
` 6 essentially what I provided is always viewing the
` 7 prior art and the -- the '501 patent itself in
` 8 terms of what someone of ordinary skill in the art
` 9 would either interpret or understand.
`10 Q. Do you understand that a POSA is aware of
`11 all prior art as of the priority date of the
`12 patent?
`13 A. What I understand is that a POSA is
`14 familiar with the prior art of the time, and that's
`15 as of -- my understanding of what a POSA would
`16 know.
`17 So, yes, they would be familiar with all
`18 prior art at the time.
`19 Q. In your Exhibit 1002 declaration, do you
`20 see paragraph 51?
`21 A. Yes.
`22 Q. In paragraph 51 did you identify the
`23 entire priority chain for the '501 patent?
`24 MR. SMITH: Objection.
`
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`Taiwan Semiconductor Manufacturing Co., Ltd. v.
`Godo Kaisha IP Bridge 1
`
`Page 21
` 1 A. I don't know what you mean by "identify
` 2 the entire priority chain."
` 3 I used the priority date, like I said.
` 4 Q. Do you have a copy of the '501 patent?
` 5 A. Yes.
` 6 Q. Is your copy of the '501 patent, is it
` 7 Exhibit 1001?
` 8 A. Yes.
` 9 Q. And even though the exhibit number might
`10 change between the different proceedings, it's the
`11 same '501 patent?
`12 That wasn't meant to be a trick question.
`13 Let me rephrase.
`14 (Exhibit 1001, previously marked.)
`15 A. Yeah, I don't even -- I'm not sure I
`16 understood.
`17 Q. There's -- there's multiple proceedings;
`18 correct?
`19 A. That's my understanding.
`20 Q. And even though the exhibit numbering
`21 might be different in each proceeding --
`22 A. Ah.
`23 Q. -- it's the same '501 patent in each
`24 proceeding.
`
`Dr. Stanley R. Shanfield - Vol. I
`March 27, 2018
`Page 23
` 1 Application Serial No. 11/730,988, filed April 5th,
` 2 2007."
` 3 Q. In paragraph 51 is there a reason that you
` 4 only listed the JP patent number and the US Patent
` 5 Application No. 10/859,219?
` 6 A. (Witness reviews document.) What was
` 7 relevant for me is what I wrote in paragraph 20 of
` 8 my declaration; that I had applied the date of June
` 9 16, 2003, the filing date of the foreign
`10 application to which the '501 patent claims
`11 priority.
`12 It's my understanding, as I wrote here,
`13 that the '501 patent may not actually be entitled
`14 to such an early priority date, but that's the date
`15 I took.
`16 Q. So in paragraph 51 you were explaining
`17 where the date you had provided in paragraph 20
`18 came from?
`19 A. Well, they say essentially the same thing,
`20 but that's right. It explains where the date came
`21 from.
`22 Q. So my next question isn't specific to the
`23 '501 patent, but I want to know, could you tell me
`24 what a CMOS device is.
`
`Page 22
` 1 A. Well, I can't say, without having seen
` 2 each exhibit, but I'll -- I'll take that as an
` 3 understanding.
` 4 Q. All right. On the front cover of the '501
` 5 patent -- actually, it might be easier if we go to
` 6 column 1 of the '501 patent.
` 7 Do you see in column 1 at approximately
` 8 line 4 where it says "Related Applications"?
` 9 A. Yes.
`10 Q. In your paragraph 51 did you list all of
`11 those applications that are listed in column 1,
`12 starting at line 6?
`13 A. Paragraph 31?
`14 Q. 51.
`15 A. 51. (Witness reviews document.) What I
`16 said there was "The '501 patent claims priority to
`17 a Japanese patent, JP 2003-170335, filed June 16,
`18 2003, and to Patent Application No. 10/859,219,
`19 filed June 3rd, 2004."
`20 Q. So in -- in paragraph 51, does that
`21 identify all of the patent applications that are
`22 listed in the '501 patent?
`23 A. No. For example, in that paragraph it
`24 says "This application is a continuation of US
`
`Page 24
` 1 A. CMOS stands for a complementary metal
` 2 oxide semiconductor.
` 3 Q. Is there more than one transistor in a
` 4 CMOS?
` 5 MR. SMITH: Objection.
` 6 A. So are you talking specifically in the
` 7 context of the '501?
` 8 Q. Let's take a look at -- in your 1002
` 9 declaration, paragraph 36.
`10 A. (Witness reviews document.)
`11 Q. Is paragraph 36 referring to the figure 1
`12 that you annotated on page 12 of your declaration?
`13 A. (Witness reviews document.) The sentence
`14 where I wrote "The region between --" excuse me
`15 "-- the source and drain electrodes where current
`16 flows is called the channel region, also shown in
`17 figure 1 above."
`18 Q. So is that a statement that what we see in
`19 figure 1 above is a CMOS?
`20 A. What I wrote was "a process that combines
`21 MOSFETs with p-doped channels and MOSFETs with
`22 n-doped channels is referred to as a
`23 complementary-metal-oxide-semiconductor process, or
`24 CMOS process."
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`Taiwan Semiconductor Manufacturing Co., Ltd. v.
`Godo Kaisha IP Bridge 1
`
`Page 25
` 1 Q. So if we look at figure 1, is that a CMOS
` 2 device?
` 3 A. Your question doesn't entirely make sense.
` 4 A CMOS process uses PMOS and NMOS devices, and
` 5 that's what's pictured in figure 1.
` 6 Q. How does a CMOS process use an NMOS and
` 7 PMOS?
` 8 A. Well, I think I explained it in -- in that
` 9 paragraph 36. It's when you combine MOSFETs with
`10 p-doped channels and MOSFETs with n-doped channels,
`11 that's referred to as a CMOS process.
`12 Q. So in figure 1 how many transistors are
`13 shown?
`14 MR. SMITH: Objection.
`15 A. Someone of skill in the art looking at
`16 figure 1 would understand that there are many of
`17 these devices, and that this is an illustration of
`18 a PMOS device and an NMOS device next to each
`19 other.
`20 Q. What does "PMOS" stand for?
`21 A. The "P" in PMOS is referring to the
`22 p-doped channel, and the "MOS" is metal oxide
`23 semiconductor.
`24 Q. Is a PMOS different than a pMOSFET?
`
`Dr. Stanley R. Shanfield - Vol. I
`March 27, 2018
`Page 27
` 1 transistors given many kinds of names, and outside
` 2 the context of this patent, there are other ways of
` 3 referring to those transistors which might -- might
` 4 use the word "PMOS."
` 5 But in the context here, yes.
` 6 Q. So in figure 1 there is there a transistor
` 7 on the left-hand side where it's labeled "PMOS"?
` 8 MR. SMITH: Objection.
` 9 A. There's a cross-sectional view of a PMOS
`10 device. This was taken from a textbook, "Silicon
`11 VLSI Technology Fundamentals, Practice, and
`12 Modeling."
`13 Q. Looking at figure 1, can you tell me how
`14 many transistors are shown?
`15 MR. SMITH: Objection.
`16 A. Like I said, a person of skill in the art
`17 would look at figure 1 and understand that they're
`18 meant to be many transistors, and this is
`19 illustrating the cross-section of a single PMOS
`20 transistor and a single NMOS transistor.
`21 Q. So in this cross-section we're seeing two
`22 transistors?
`23 MR. SMITH: Objection.
`24 A. As I was explaining, the view of a person
`
`Page 26
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`Page 28
`
` 1 A. You'd have to give me more context.
` 2 Q. So in paragraph 36 do you see the sentence
` 3 starting at the bottom of page 12 and carrying over
` 4 to page 13?
` 5 A. Yes.
` 6 Q. Are MOSFETs and MOS the same thing?
` 7 A. Well, like I wrote, it's -- metal oxide
` 8 semiconductor field effect transistors are even --
` 9 are MOSFETs or MOS transistors.
`10 Q. So does a PMOS have a transistor, or is it
`11 a transistor?
`12 A. PMOS is a MOSFET with p-doped channels.
`13 Q. And MOSFET stands for metal oxide
`14 semiconductor field effect transistor?
`15 A. I'm sorry. Could you repeat that.
`16 Q. MOSFET stands for metal oxide
`17 semiconductor field effect transistor?
`18 A. Correct.
`19 Q. A pMOSFET is a p-doped metal oxide
`20 semiconductor field effect transistor.
`21 Is that a correct statement?
`22 MR. SMITH: Objection.
`23 A. It usually is, and in the context of this
`24 '501 patent, it is. There's many kinds of MOS
`
` 1 of skill in the art is this diagram, figure 1,
` 2 illustrates the cross-section of a PMOS and NMOS
` 3 transistor, but it's not meant to literally say
` 4 there are only two transistors. It's illustrating
` 5 transistors that are a description -- PMOS or NMOS.
` 6 Q. So what you just said -- I am just trying
` 7 to make sure that I understand it -- is that in
` 8 figure 1 there are two transistors, but a person of
` 9 ordinary skill in the art would understand that
`10 it's not literally just two transistors.
`11 MR. SMITH: Objection.
`12 A. That's not exactly what I said.
`13 I'm saying for the purposes of
`14 illustration, figure 1 shows a single PMOS
`15 transistor and a single NMOS transistor in
`16 cross-section. A person of skill in the art,
`17 looking at this figure, would understand there are
`18 multiple devices -- many more than just pictured
`19 here, and this is just meant to illustrate what the
`20 cross-sections look like.
`21 Q. When you say that there's "many more"
`22 devices, looking at this cross-section, do you mean
`23 that there's more devices to the left or -- or to
`24 the right?
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`Taiwan Semiconductor Manufacturing Co., Ltd. v.
`Godo Kaisha IP Bridge 1
`
`Page 29
` 1 A. There are more devices possibly to the
` 2 left and right, possibly into the page or out of
` 3 the page.
` 4 Q. So let's look at the left-hand side, the
` 5 PMOS, of figure 1.
` 6 A. Yes.
` 7 Q. If there were another device going into
` 8 the page, would it be the same structure as what we
` 9 see in this cross-section?
`10 MR. SMITH: Objection.
`11 A. Not necessarily.
`12 Q. Would it be the same transistor?
`13 MR. SMITH: Objection.
`14 A. Not necessarily.
`15 Q. In figure 1 is the PMOS on the left-hand
`16 side a different transistor than the NMOS on the
`17 right-hand side?
`18 MR. SMITH: Objection.
`19 A. Could you be more specific?
`20 What -- different in what sense?
`21 Q. Let's back up.
`22 Could -- could you define transistor.
`23 MR. SMITH: Objection.
`24 A. Best way I could define transistor is by
`
`Page 30
` 1 pointing to figure 1 and giving you examples of
` 2 transistors.
` 3 So in figure 1 there's an example of a
` 4 PMOS transistor and an NMOS transistor.
` 5 Q. So what makes it an NMOS transistor?
` 6 A. Makes what an NMOS transistor?
` 7 Q. Sorry. In figure 1 are you referring to
` 8 the right-hand side when you say that there's an
` 9 example of an NMOS transistor?
`10 A. Yes, that's correct.
`11 Q. So how would a person of ordinary skill in
`12 the art identify that that is a transistor?
`13 MR. SMITH: Objection.
`14 A. There are a number of characteristics of
`15 an NMOS transistor they would recognize.
`16 Q. Could you tell me what those
`17 characteristics are.
`18 A. It's a long list. I -- I can.
`19 Q. Could we start with what's labeled on this
`20 annotated figure 1?
`21 A. It's in a -- a p-substrate of silicon. So
`22 that's one -- one characteristic of an NMOS
`23 transistor shown -- illustrated here.
`24 Q. Are you referring to the text that says "P
`
`Dr. Stanley R. Shanfield - Vol. I
`March 27, 2018
`Page 31
`
` 1 well"?
` 2 A. No, I'm referring to the fact that there's
` 3 a substrate that all of this is sitting on, and
` 4 I've labeled it "p-substrate" in figure 1. So it's
` 5 at the bottom of the figure.
` 6 Q. And what other characteristics are there
` 7 that a POSA would use to identify an NMOS on the
` 8 right-hand side?
` 9 A. They would see the label "P well,"
`10 indicating p-type material in the p-type substrate.
`11 Q. Are there any other characteristics?
`12 A. Yes.
`13 Q. And what are those?
`14 A. A POSA would see n-plus source-drain
`15 contact doping. It's been colored green in figure
`16 1.
`17 Q. Are the n-plus that are colored green, are
`18 those source-drain regions?
`19 MR. SMITH: Objection.
`20 A. When I annotated this drawing, I colored
`21 green the source-drain region for this
`22 illustration.
`23 Q. And what is colored red in this
`24 illustration?
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`Page 32
`
` 1 A. On the NMOS device?
` 2 Q. Yes.
` 3 A. That is a gate oxide -- "Gate Insulator,"
` 4 is what I labeled it.
` 5 Q. So in your opinion if there -- let me back
` 6 up.
` 7 Focusing on the right-hand side where it's
` 8 labeled an "NMOS" device, we see a series of
` 9 components; correct?
`10 A. Well, I don't know what you mean by
`11 "components."
`12 I've labeled a cross-section of an NMOS
`13 device.
`14 Q. Well, we see a series of elements that are
`15 the illustration itself; correct?
`16 A. Yes.
`17 Q. If we take that exact same series of
`18 elements and place it into the page -- do you
`19 follow me so far?
`20 A. I think so, but go ahead.
`21 Q. I don't know what -- the technical
`22 terminology -- but let's say that they're in a
`23 row.
`24 A. Yes.
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