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`Paper No. __
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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 CO., LTD,
`Petitioner,
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`v.
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`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
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`IPR2017-018411
`Patent 7,893,501
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`PATENT OWNER’S OBJECTIONS TO EVIDENCE SERVED WITH
`PETITIONER’S REPLY
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`1 Case IPR2017-01842 has been consolidated with this proceeding.
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner submits the following
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`objections to evidence served in connection with the Petitioner’s Reply to Patent
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`Owner’s Response. These objections have been timely filed and served within five
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`business days of the service of evidence to which the objection is directed.
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`Exhibit 1025 is a patent (U.S. Patent No. 5,389,810, “Agata”). Patent
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`Owner objects to Exhibit 1025 as new evidence that is not properly included in a
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`reply as it is only cited in Petitioner’s Reply to support new arguments. See Paper
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`No. 22 at pp. 10-13. Accordingly, Exhibit 1025 is irrelevant and/or substantially
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`more prejudicial than probative pursuant to F.R.E. 401, 402, and 403
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`Exhibit 1026 is a patent (U.S. Patent No. 8,618,607, “Rashed”). Patent
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`Owner objects to Exhibit 1026 as new evidence that is not properly included in a
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`reply as it is only cited in Petitioner’s Reply to support new arguments. See Paper
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`No. 22 at pp. 10-13. Accordingly, Exhibit 1026 is irrelevant and/or substantially
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`more prejudicial than probative pursuant to F.R.E. 401, 402, and 403. Patent
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`Owner also objects to Exhibit 1026 pursuant to F.R.E. 401, 402, and 403 because
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`Exhibit 1026 issued from an application which was filed on July 2, 2012 (see
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`Exhibit 1026), more than 9 years after the priority date of the ’501 Patent.
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`Accordingly, Petitioner has not shown that Rashed has any bearing on claim
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`construction or the knowledge of a POSA at the time of the invention.
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`Exhibit 1027 is the Reply Declaration of Stanley R. Shanfield, Ph.D.
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`Several portions of Exhibit 1027 contain new evidence and/or support for new
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`theories that are not properly included in a reply as they are only cited in
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`Petitioner’s Reply to support new arguments. Patent Owner objects to the
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`following portions because they are an improper reply and are therefore irrelevant
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`and/or substantially more prejudicial than probative pursuant to F.R.E. 401, 402,
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`and 403.
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`• Exhibit 1027, ¶ 5 improperly raises a new argument that it would have
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`been obvious to apply Igarashi’s teaching of isolation regions to
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`Igarashi’s Fifth Embodiment that is only cited in Petitioner’s Reply to
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`support new arguments. See Paper No. 22 at p. 3.
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`• Exhibit 1027, ¶¶ 19, 37-39 improperly raise a new argument that it
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`would have been obvious based on Woerlee to use isolation regions in
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`Igarashi’s Fifth Embodiment that is only cited in Petitioner’s Reply to
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`support new arguments. See Paper No. 22 at pp. 14, 26, 28.
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`• Exhibit 1027, ¶ 19 improperly raises a new argument that transistors
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`that do not use isolation regions still have active region because the
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`absence of an isolation region does not signify the absence of an
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`active region that is only cited in Petitioner’s Reply to support new
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`arguments. See Paper No. 22 at p. 14.
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`• Exhibit 1027, ¶ 29 improperly raises a new argument that there is one
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`active region in the TSMC-modified Figure 12 of Igarashi that is only
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`cited in Petitioner’s Reply to support new arguments. See Paper No.
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`22 at pp. 19-20.
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`• Exhibit 1027, ¶ 16-18 improperly raise a new argument that where
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`two transistors share a drain, both transistors are formed within the
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`same active region that is only cited in Petitioner’s Reply to support
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`new arguments. See Paper No. 22 at pp. 10-13. Further, these
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`paragraphs discuss Exhibits 1025 and 1026 which as discussed above
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`are new evidence that is not properly included in a reply.
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`Furthermore, the discussion of Exhibit 1026 in these paragraphs is
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`irrelevant and/or substantially more prejudicial than probative because
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`Exhibit 1026 issued from an application which was filed more than 9
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`years after the priority date of the ’501 Patent.
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`Dated: July 13, 2018
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`Respectfully submitted,
`Godo Kaisha IP Bridge 1
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`By /Gerald B. Hrycyszyn /
`Gerald B. Hrycyszyn, Reg. No. 50,474
`Richard F. Giunta, Reg. No. 36,149
`Edmund J. Walsh, Reg. No. 32,950
`Joshua J. Miller (admitted pro hac vice)
`WOLF GREENFIELD & SACKS, P.C.
`600 Atlantic Ave.
`Boston, MA 02210-2206
`Tel: 617-646-8000/Fax: 617-646-8646
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. §42.6 (e)(4)
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`I certify that on July 13, 2018 I will cause a copy of the foregoing document
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`to be served via electronic mail, as previously consented to by Petitioner, upon the
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`following:
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`David L. Cavanaugh
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`David.Cavanaugh@wilmerhale.com
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`Dominic.Massa@wilmerhale.com
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`MichaelH.Smith@wilmerhale.com
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`Dominic E. Massa
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`Michael H. Smith
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`Date: July 13, 2018
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`/MacAulay Rush/
`MacAulay Rush
`Patent Paralegal
`WOLF GREENFIELD & SACKS, P.C.
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`5
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