`Filed By: David L. Cavanaugh, Reg. No. 36,476
`Dominic E. Massa, Reg. No. 44,905
`Michael H. Smith, Reg. No. 71,190
`1875 Pennsylvania Ave. NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: David.Cavanaugh@wilmerhale.com
`Dominic.Massa@wilmerhale.com
`MichaelH.Smith@wilmerhale.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY LTD.
`Petitioner
`
`v.
`
`GODO KAISHA IP BRIDGE 1
`Patent Owner.
`
`Case IPR2017-018411
`
`
`PETITIONER’S RESPONSE PURSUANT TO JULY 20, 2018 ORDER
`
`
`1 Case IPR2017-01842 has been consolidated with this proceeding.
`
`
`
`1. The Reply specifically identifies where and how the Patent Owner Response
`
`(“POR”) mischaracterizes the Petition (“Pet.”) (e.g., POR at 37), identifies where
`
`the Pet. showed that it would have been obvious to form Igarashi’s active region in
`
`the substrate 1 in Fig. 12 (e.g., Pet. at 32; see also id. at 31), and notes where the
`
`Board recognized this in the DI (e.g., DI at 16). The Reply specifically states at
`
`2:9-13 that this section responds to the POR at 37.
`
`2. The Reply simply identifies where and how the POR mischaracterizes the Pet.
`
`(e.g., POR at 58), identifies where the Pet. showed that it would have been obvious
`
`to use Igarashi’s STI to define the active region of substrate 1 in Fig. 12 (e.g., Pet.
`
`at 32; see also id. at 31), and notes where the Board recognized this in the DI (e.g.,
`
`DI at 16). A review of pages 2-3, 13-14, and 25-28 of the Reply, which quote
`
`extensively from the Pet., POR, and DI, confirms that the Reply properly responds
`
`to the POR and is grounded in the Pet. The Reply specifically states at 26:10 to
`
`27:1 that this section responds to the POR at 58.
`
`3. Page 14 of the Reply responds to the PO’s suggestion that some older devices
`
`did not have active regions because they did not use STI (POR at 46) and explains
`
`why this example is misleading. The Reply states at 13:6-9 that this section
`
`responds to ¶¶112-113 of Dr. Glew’s decl., cited on page 46 of the POR.
`
`4. The Reply at 9-13 and 19-22 responds to the arguments in the POR on pages
`
`14-21, 28-29, 33-36, and 58-74 that Igarashi’s Fig. 12 embodiment does not have a
`
`1
`
`
`
`U.S. Patent 7,893,501
`IPR2017-01841
`Petitioner’s Response Pursuant to July 20, 2018 Order
`
`
`single large active region or two smaller active regions that satisfy the claims. In
`
`response, the Reply confirms that a POSITA would have viewed the region
`
`between the two STI as the claimed active region and identifies where this is
`
`shown in the Pet. Reply at 19-20 (citing Pet. at 25-26). The Reply also confirms
`
`in response to the POR that Igarashi discloses the claimed active region under
`
`either view and that PO’s construction is unduly narrow. Reply at 9-13, 20-22.
`
`The Reply specifically states at 9:1-4 and 21:4-22:2 that these arguments respond
`
`to POR at 17-18, 33-34, 28-29, and 74. The Reply also responds to PO’s
`
`mischaracterization of Dr. Shanfield’s testimony. Reply at 22-25; see also Ex.
`
`2009 at 93:16-20 (clarifying region between STI is an active region, not two active
`
`regions); Ex. 2010 at 401:9-402:4 (confirming clarification); id. at 408:10-17,
`
`411:7-412:3 (confirming region between STI is the active region); id. at 429:12-
`
`430:5, 437:11-19 (attempting to clarify and answer confusing questions).
`
`5. As noted for 4., the Reply at 20-21 responds the POR’s arguments that Igarashi
`
`does not have a single large active region or two smaller active regions that satisfy
`
`the claims and confirms Igarashi discloses the active region under either view.
`
`Dated: July 27, 2018 Respectfully Submitted,
`
`/Michael Smith/
`_______________________________
`Michael H. Smith, Reg. No. 71,190
`
`2
`
`
`
`
`
`CERTIFICATE OF SERVICE
`I hereby certify that, on July 27, 2018, I caused a true and correct copy of the
`
`foregoing materials:
`
` Petitioner’s Response Pursuant to July 20, 2018 Order
`
`to be served via email on the following counsel of record as listed in Patent
`
`Owner’s Mandatory Notices:
`
`Gerald B. Hrycyszyn, Registration No. 50,474
`GHrycyszyn-PTAB@wolfgreenfield.com
`
`Richard F. Giunta, Registration No. 36,149
`RGiunta-PTAB@wolfgreenfield.com
`
`Edmund J. Walsh, Registration No. 32,950
`EWalsh-PTAB@wolfgreenfield.com
`
`Joshua Miller, pro hac vice
`Joshua.Miller@WolfGreenfield.com
`
`Wolf, Greenfield & Sacks, P.C.
`600 Atlantic Avenue
`Boston, Ma 02210
`
`Respectfully Submitted,
`
`___/Michael Smith/_____________
`Michael H. Smith
`Registration No. 71,190
`
`3
`
`
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