In The Matter Of:
`Taiwan Semiconductor Manufacturing Co., LTD v.
`GODO Kaisha IP Bridge 1
`
`Stanley R. Shanfield, Ph.D.
`Vol. II
`March 28, 2018
`
`68 Commercial Wharf • Boston, MA 02110
`888.825.3376 - 617.399.0130
`Global Coverage
`court-reporting.com
`
`Original File Stanley R. Shanfield, Ph.D. 3-28-18.txt
`Min-U-Script® with Word Index
`IP Bridge Exhibit 2010
`TSMC v. Godo Kaisha IP Bridge 1
`IPR2017-01841
`
`

`

`Taiwan Semiconductor Manufacturing Co., LTD v.
`GODO Kaisha IP Bridge 1
`
`Page 187
` 1 VOLUME: II
` PAGES: 187-447
` 2 EXHIBITS: 2001-2006
` 3 UNITED STATES PATENT AND TRADEMARK OFFICE
` 4 BEFORE THE PATENT TRIAL AND APPEAL BOARD
` 5 CASE NO. IPR2017-01841
` 6 PATENT 7,893,501
` 7 ____________________________________
` 8 TAIWAN SEMICONDUCTOR MANUFACTURING )
` 9 CO., LTD, )
`10 Petitioner, )
`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 Wednesday,
`24 March 28, 2018, commencing at 9:00 a.m.
`
`Stanley R. Shanfield, Ph.D. - Vol. II
`March 28, 2018
`Page 189
`
` 1 APPEARANCES: (CONT'D)
` 2
` 3
` 4 WOLF GREENFIELD & SACKS, P.C.
` 5 BY: Joshua J. Miller, Esq.
` 6 -and-
` 7 Richard F. Giunta, Esq.
` 8 600 Atlantic Avenue
` 9 Boston, MA 02210-2206
`10 617 646-8000
`11 Jmiller@wolfgreenfield.com
`12 Rgiunta@wolfgreenfield.com
`13 For the Patent Owner
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`
`Page 188
`
`Page 190
`
` 1 APPEARANCES:
` 2
` 3 WILMER CUTLER PICKERING HALE
` 4 AND DORR LLP
` 5 BY: Michael H. Smith, Esq.
` 6 -and-
` 7 David Cavanaugh, Esq.
` 8 1875 Pennsylvania Avenue, NW
` 9 Washington, DC 20006
`10 202 663-6055
`11 Michaelh.smith@wilmerhale.com
`12 David.cavanaugh@wilmerhale.com
`13 -and-
`14 TAIWAN SEMICONDUCTOR MANUFACTURING
`15 COMPANY, LTD.
`16 BY: Willy Chang, Esq.
`17 8, Li-Hsin Rd.
`18 6 Hsinchu Science Park.
`19 Hsinchu 30078, Taiwan
`20 For the Petitioner
`21
`22
`23
`24
`
` 1 I N D E X
` 2
` 3 TESTIMONY OF: PAGE
` 4
` 5 STANLEY R. SHANFIELD, PhD
` 6
` 7 (Cont'd by Mr. Miller) 192, 440
` 8 (By Mr. Smith) 439
` 9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
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`Taiwan Semiconductor Manufacturing Co., LTD v.
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`Page 191
`
`Stanley R. Shanfield, Ph.D. - Vol. II
`March 28, 2018
`Page 193
`
`Exhibit 2001 US Patent 7,893,501 192
`
` 1 E X H I B I T S
` 2 EXHIBIT DESCRIPTION PAGE
` 3
` 4
` 5
`Exhibit 2002 US Patent 2002/0145156 A1 192
` 6 Exhibit 2203 previously marked 194
` 7 Exhibit 1005 previously marked 258
` 8 Exhibit 1202 previously marked 286
` 9
`Exhibit 2003 Hawley's Condensed Chemical 333
`10 Dictionary excerpt
`11 Exhibit 2202 previously marked 389
`12 Exhibit 1203 previously marked 391
`13 Exhibit 2004 US Patent 6,437,404 397
`14
`Exhibit 2005 diagram, figure 12 414
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`
`Exhibit 2006 diagram, figure 12 431
`
` 1 you did and which I did?
` 2 Q. Yes.
` 3 A. Okay.
` 4 Q. Doctor Shanfield, getting started this
` 5 morning, is there anything that you want to change
` 6 or clarify in your prior testimony?
` 7 A. No.
` 8 Q. Since we started this deposition
` 9 yesterday, have you discussed your deposition or
`10 the subject matter of these proceedings with your
`11 counsel?
`12 A. No, I have not.
`13 Q. Did you discuss the deposition or the
`14 subject matter of these proceedings with your
`15 counsel last night?
`16 A. No.
`17 Q. This morning?
`18 A. No.
`19 Q. I'm going to hand you what's marked
`20 Exhibit 2202.
`21 (Exhibit 2202, previously marked.)
`22 Q. And, Doctor Shanfield, do you understand
`23 that you're still under oath from yesterday's
`24 deposition?
`
`Page 192
` 1 STANLEY R. SHANFIELD, PhD, having
` 2 satisfactorily been identified by
` 3 the production of a driver's license,
` 4 and being previously sworn by the Notary
` 5 Public, was examined and testified as
` 6 follows to continued interrogatories
` 7 BY MR. MILLER:
` 8 Q. Good morning, Doctor Shanfield.
` 9 A. Good morning.
`10 MR. MILLER: Before we get started, a
`11 couple of housekeeping items.
`12 Counsel, I was going to put a deposition
`13 stamp on the exhibits that we annotated
`14 yesterday --
`15 MR. SMITH: Okay.
`16 MR. MILLER: Just so that when they're
`17 filed, there's a separate one that kind of follows
`18 the record. Can we mark the '501 patent with the
`19 2001 label.
`20 (Exhibit 2001, US Patent 7,893,501.)
`21 MR. MILLER: Let's mark the Igarashi, also
`22 annotated with the 2002 label.
`23 (Exhibit 2002, US Patent 2002/0145156 A1.)
`24 A. It's clear in the record which annotation
`
`Page 194
`
` 1 A. Yes, I do understand that.
` 2 Q. Are you familiar with this reference,
` 3 Doctor Shanfield?
` 4 A. Yes. I am familiar with it.
` 5 Q. In what context are you familiar with this
` 6 reference?
` 7 A. I believe this is in the record of the
` 8 proceedings to -- for the '501 patent and -- from
` 9 the patent office.
`10 Q. Did you review this reference in preparing
`11 your declaration?
`12 A. I looked at it.
`13 Q. And do you have a specific memory about
`14 reviewing this reference?
`15 A. Yes.
`16 Q. What is that specific memory?
`17 A. I took a look at it. I didn't read it in
`18 depth, but I remember it.
`19 Q. I'm going to hand you Exhibit 2203.
`20 (Exhibit 2203, previously marked.)
`21 Q. Are you familiar with this reference,
`22 Doctor Shanfield?
`23 A. Yes.
`24 Q. In what context are you familiar with the
`
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`Taiwan Semiconductor Manufacturing Co., LTD v.
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` 1 reference?
` 2 A. Same context.
` 3 Q. Did you review this reference prior to
` 4 filing your declaration?
` 5 A. Yes.
` 6 Q. What claim construction standard did you
` 7 use in your analysis?
` 8 A. (Witness reviews document.) So as I
` 9 explain in paragraph 57 on page 29 of -- this is my
`10 declaration 1002, "I have applied the broadest
`11 reasonable interpretation standard."
`12 Q. What is your understanding of the broadest
`13 reasonable interpretation?
`14 A. Well, I want to point out, first of all,
`15 that my analysis actually is not even dependent on
`16 application of the broadest reasonable standard,
`17 because I believe the prior art teaches each claim
`18 limitation under any reasonable interpretation of
`19 the claim terms.
`20 Q. What do you mean when you say that your
`21 analysis is not even dependent on application of
`22 the broadest reasonable standard?
`23 A. It's the broadest reasonable
`24 interpretation, not standard, and the point being
`
`Stanley R. Shanfield, Ph.D. - Vol. II
`March 28, 2018
`Page 197
` 1 sentence, phrase, that is interpreted as -- you
` 2 know, and what does it mean?
` 3 Broadest reasonable interpretation is the
` 4 context of a document -- for example a '501 or a
` 5 set of claims -- of what's a reasonable
` 6 interpretation of those claims and kind of has the
` 7 collective interpretation requirement.
` 8 So I don't -- I can't convolve those --
` 9 those two meanings.
`10 Q. So a claim term can have a plain and
`11 ordinary meaning; is that correct?
`12 A. I think a claim term can have a plain and
`13 ordinary meaning or a claim phrase or -- yes.
`14 Q. Can the broadest reasonable interpretation
`15 of a claim term be narrower than the ordinary
`16 meaning of that claim term?
`17 MR. SMITH: Objection.
`18 A. Once again, there's two different concepts
`19 at play. So that isn't a sensible question, so I
`20 can't answer you.
`21 Q. Could you explain why you think it's not a
`22 sensible question.
`23 A. I think I already did. I'll repeat
`24 myself.
`
`Page 196
` 1 that the broadest reasonable interpretation, just
` 2 as it suggests, is what someone of skill in the art
` 3 would interpret a term in, you know, in the context
` 4 of this '501 patent, or whatever document we're
` 5 reviewing.
` 6 Q. So I'm still not clear what it means when
` 7 you say that -- in paragraph 57, "My analysis is,
` 8 therefore, not dependent on application of the
` 9 broadest reasonable interpretation standard."
`10 A. Well, it's essentially what it says; that
`11 I -- I've used the broadest reasonable
`12 interpretation standard, but I've noticed that I
`13 don't -- wouldn't even have needed to use it. I
`14 could have taken any reasonable interpretation of
`15 the claim terms and still come to the same
`16 conclusions.
`17 But, nevertheless, I use broadest
`18 reasonable interpretation standard in looking at
`19 the claim terms.
`20 Q. Can the broadest reasonable interpretation
`21 be narrower than the plain and ordinary meaning?
`22 MR. SMITH: Objection.
`23 A. I think you're comparing apples and
`24 oranges. Plain and ordinary meaning applies to a
`
`Page 198
`
` 1 Broadest reasonable interpretation
` 2 standard for the claim terms means I take it in the
` 3 context of the specifications, of my view of what a
` 4 person of ordinary skill in the art would interpret
` 5 the language in the claims. A plain -- the plain
` 6 and ordinary meaning I generally use in a phrase --
` 7 a -- some words that is specific to that phrase or
` 8 that -- those words that, as it -- you know, it
` 9 says it's the plain and ordinary meaning of those
`10 words.
`11 So it's -- it's not -- it's not the same
`12 as the broadest reasonable interpretation standard.
`13 Q. Does a claim term have a broadest
`14 reasonable interpretation?
`15 A. That's the standard I'm applying to the
`16 claim terms.
`17 Q. So did you identify what the broadest
`18 reasonable interpretation for the claim terms is?
`19 A. Could you repeat that question.
`20 Did I? -- say it again.
`21 Q. Does each claim term have a broadest
`22 reasonable interpretation?
`23 A. The broadest reasonable interpretation
`24 standard is a standard I apply to the claim terms
`
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`Taiwan Semiconductor Manufacturing Co., LTD v.
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`Page 199
` 1 based on the specification, what I think a person
` 2 of ordinary skill in the art at the time would have
` 3 viewed the -- or interpreted those claim terms. So
` 4 it's a standard that's being applied everywhere.
` 5 Q. So is there a broadest reasonable
` 6 interpretation for the claim terms?
` 7 A. Like I said, I'm applying the broadest
` 8 reasonable interpretation standard for the claim
` 9 terms. I'm maintaining that standard in my mind
`10 and applying it.
`11 Q. When you apply the broadest reasonable
`12 interpretation standard, can you have an
`13 interpretation that is broader than the ordinary
`14 meaning?
`15 MR. SMITH: Objection.
`16 A. Once again, I think you're asking a
`17 nonsensical question. I use the ordinary meaning
`18 of claim terms in applying the broadest reasonable
`19 interpretation standard. But I'm also reading the
`20 specification, for example, in applying the
`21 broadest reasonable interpretation standard.
`22 Q. In your opinion is there a broadest
`23 reasonable interpretation for the claim terms?
`24 A. Well, I would phrase it as in my opinion
`
`Stanley R. Shanfield, Ph.D. - Vol. II
`March 28, 2018
`Page 201
`
` 1 specification, for example.
` 2 Q. Do the usage of the terms in the
` 3 specification change the plain and ordinary meaning
` 4 of the claim terms?
` 5 MR. SMITH: Objection.
` 6 A. Could you repeat that question.
` 7 Q. Does the usage of the terms in the
` 8 specification -- let me rephrase.
` 9 Does the usage of the claim terms in the
`10 specification change the plain and ordinary meaning
`11 of the claim terms?
`12 MR. SMITH: Objection.
`13 Q. Doctor Shanfield?
`14 A. Uh-huh. I'm thinking about it.
`15 I think there's always a context.
`16 Obviously words can have more than one ordinary
`17 meaning, but in -- in general it was clear to me
`18 that -- what -- what the ordinary meaning was. In
`19 applying the broadest reasonable interpretation
`20 standard, however, I needed to understand the
`21 specification and what the -- the point was in
`22 the -- the teachings and what the context was that
`23 was being discussed.
`24 Q. Doctor Shanfield, I'm still not clear.
`
`Page 200
`
` 1 -- or essentially I've applied the broadest
` 2 reasonable interpretation standard to the claim
` 3 terms, and -- and my opinion about the -- the
` 4 challenge claims is based on that standard.
` 5 Q. In applying the broadest reasonable
` 6 interpretation standard, can you have a claim term
` 7 that is narrower than the plain and ordinary
` 8 meaning of the claim term?
` 9 MR. SMITH: Objection.
`10 A. That's a not -- not a sensical question.
`11 I'm using ordinary meaning of claim terms as part
`12 of applying broadest reasonable interpretation, but
`13 they're separate entities or separate acts. So
`14 ordinary meaning is part of how I apply the
`15 broadest reasonable interpretation.
`16 Q. What do you mean when you say that they
`17 are "separate entities or separate acts"?
`18 A. I'd -- I'll withdraw that characterization
`19 and simply say that I'm applying -- or using
`20 ordinary meaning of the claim terms as part of
`21 applying broadest -- the broadest reasonable
`22 interpretation standard.
`23 Broadest reasonable interpretation
`24 standard also requires that I read the
`
`Page 202
` 1 Does the usage of the claim terms in the
` 2 specification change the plain and ordinary meaning
` 3 of the claim terms?
` 4 MR. SMITH: Objection.
` 5 A. Once again, I think you're asking almost a
` 6 tautology. The plain and ordinary meaning is the
` 7 plain and ordinary meaning, and whether it was in
` 8 the specification or in the claims. So I applied
` 9 claim and ordinary -- plain and ordinary meaning to
`10 the -- the phrase or the sentence.
`11 So your question is a tautology.
`12 Q. When you say "my analysis is, therefore,
`13 not dependent on application of the broadest
`14 reasonable interpretation standard," is that based
`15 on the fact that you applied the plain and ordinary
`16 meaning?
`17 A. Once again, you seem to be confusing
`18 broadest reasonable interpretation standard and
`19 plain and ordinary meaning. So your question isn't
`20 meaningful to me.
`21 Q. What is --
`22 A. And I can re-explain the difference.
`23 Q. What is your understanding of the
`24 relationship between the broadest reasonable
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`Taiwan Semiconductor Manufacturing Co., LTD v.
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`Page 203
` 1 interpretation and the plain and ordinary meaning?
` 2 A. The relationship is simply that I use --
` 3 in reading the claim terms, I use the plain and
` 4 ordinary meaning in understanding them, but the
` 5 broadest reasonable interpretation requires more
` 6 than just understanding plain and ordinary
` 7 meanings. It means understanding the specification
` 8 and the -- the context of the invention.
` 9 Q. Did you review the file history when
`10 considering the broadest reasonable interpretation
`11 of the claims?
`12 A. Yes, I did.
`13 Q. Is the file history listed as something
`14 you reviewed in paragraph 57?
`15 A. It's not stated in paragraph 57, but I did
`16 review it.
`17 Q. Yesterday you testified that "thin films"
`18 referred to one or more multiple layers of coverage
`19 over a surface.
`20 MR. SMITH: Objection.
`21 Q. Where does that definition come from?
`22 MR. SMITH: Objection.
`23 A. Could you repeat that?
`24 Is that a direct quote that I had made
`
`Stanley R. Shanfield, Ph.D. - Vol. II
`March 28, 2018
`Page 205
`
` 1 MR. SMITH: Objection.
` 2 A. I didn't say that. I asked to just see
` 3 what the question was. You're asking me what
` 4 was -- why did I make that statement. I need to
` 5 understand what I was responding to.
` 6 Q. That wasn't the question, Doctor
` 7 Shanfield.
` 8 The question was where does that
` 9 interpretation of "thin film" come from?
`10 MR. SMITH: Objection.
`11 A. I need to see the context of the question
`12 I was responding to to answer that.
`13 Q. Does the definition of "thin film" depend
`14 on the context?
`15 MR. SMITH: Objection.
`16 A. I'm not presuming a -- a context until I
`17 see what the question was I responded to.
`18 Obviously if you're talking about a thin
`19 film of plastic that you're using to protect the
`20 floor from getting paint spattering, that's a
`21 different context.
`22 So that's why I need to see what the
`23 question was I was responding to and why I
`24 explained it that way.
`
`Page 204
`
`Page 206
`
` 1 yesterday?
` 2 Q. (Reviews screen.) "Thin films refer to
` 3 one or more multiple layers of coverage over a
` 4 surface."
` 5 A. I think I meant or multiple layers. I
` 6 think there's a missing word.
` 7 And you -- what's your question?
` 8 Q. The statement is "thin films refer to one
` 9 or more multiple layers of coverage over a
`10 surface."
`11 A. Yes, I did say that, yeah.
`12 Q. Where does that definition come from?
`13 MR. SMITH: Objection.
`14 A. I was responding to a question from you,
`15 that's why I said it.
`16 Q. You interpret "thin film" as referring to
`17 one or more multiple layers of coverage over a
`18 surface; correct?
`19 MR. SMITH: Objection.
`20 A. Could we go back to that discussion, and
`21 can I see what the question was that I was
`22 answering?
`23 Q. Do you not agree with your interpretation
`24 of thin film?
`
` 1 Q. The question was to describe at a high
` 2 level chemical vapor deposition.
` 3 Your response was "It's depositing a thin
` 4 film of something that -- of semiconductor material
` 5 that you're interested in covering a surface with.
` 6 It's done with plasma so that it can be done at low
` 7 temperature, lower temperature than if it was just
` 8 pure chemical reaction. The kinds of materials
` 9 that might be deposited on -- in thin film would
`10 be -- it's typically a dielectric like silicon
`11 nitride, silicon oxynitride, silicon oxide. Thin
`12 films refer to one or more multiple layers of
`13 coverage over a surface. It's widely used in
`14 semiconductor industry."
`15 MR. SMITH: Objection.
`16 A. And so repeat your question now that I
`17 understand that.
`18 Q. Where does your interpretation of "thin
`19 film" come from?
`20 A. The context in which I was making that
`21 characterization was plasma chemical vapor
`22 deposition, and it was the deposition of dielectric
`23 layers. So that's what I had in mind in explaining
`24 thin films.
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`Stanley R. Shanfield, Ph.D. - Vol. II
`March 28, 2018
`Page 209
`
` 1 There's other kinds of thin films.
` 2 There's metal, thin film metal.
` 3 There's thin films of organic materials,
` 4 photoresist.
` 5 There's residue thin films that might be
` 6 left from a plasma etch. There's a variety of thin
` 7 film within the -- just the semiconductor context.
` 8 So in this case, I was focused on plasma
` 9 CVD and what thin film meant in that context.
`10 Q. In chemical vapor deposition, does thin
`11 film refer to one or more multiple layers of
`12 coverage over a surface?
`13 MR. SMITH: Objection.
`14 A. Well, that was part of my response to your
`15 question, and depending on specific contexts, like
`16 geometry or material, it's going to affect the
`17 description or make it -- I can give you a more
`18 accurate answer if you give me more context.
`19 Q. Did you provide that interpretation of
`20 thin film in your declaration?
`21 A. I don't believe I did, no. It's such a
`22 simple concept that it would be understood by
`23 someone of ordinary skill in the art without any
`24 further description.
`
` 1 Q. Yes.
` 2 A. That's what I said, yeah.
` 3 Q. So obviously I'm not reading exactly. I'm
` 4 asking a question. So I can't read exactly what
` 5 you're saying. If I read your entire response, it
` 6 wouldn't be a question.
` 7 So the question is: Your interpretation
` 8 of "thin film" was not included in your declaration
` 9 because someone of ordinary skill in the art at the
`10 time of the '501 patent would have understood that
`11 definition -- strike that.
`12 Let me rephrase.
`13 Your interpretation of "thin film" was not
`14 included in your declaration because someone of
`15 ordinary skill in the art at the time of the '501
`16 patent would have understood that interpretation
`17 applied; is that correct?
`18 MR. SMITH: Objection.
`19 Q. Doctor Shanfield, there's a question
`20 pending.
`21 A. I understand that.
`22 In my declaration I applied the definition
`23 of a thin film as understood by someone of ordinary
`24 skill in the art. I was originally responding to
`
`Page 208
` 1 Q. Is that the reason it was not included in
` 2 your declaration?
` 3 MR. SMITH: Objection.
` 4 A. No.
` 5 Q. Was there a reason that interpretation was
` 6 not included in your declaration?
` 7 MR. SMITH: Objection.
` 8 A. My understanding is we are operating from
` 9 the point of view of someone of ordinary skill in
`10 the art, and my declaration text reflects that
`11 understanding already in place.
`12 The declaration would be much longer if I
`13 didn't include the context of what someone of
`14 ordinary skill in the art at the time of the '501
`15 patent understood.
`16 Q. I want to make sure that I understand your
`17 response.
`18 Your interpretation of "thin film" was not
`19 included in your declaration because someone of
`20 ordinary skill in the art at the time of the '501
`21 patent would have understood that definition; is
`22 that correct?
`23 MR. SMITH: Objection.
`24 A. Are you reading back what I said?
`
`Page 210
` 1 what I thought your question was, which is why
` 2 didn't I list that definition word for word in
` 3 every context, and my answer was, there's many
` 4 contexts that it was used in, and I simply applied
` 5 it as someone of ordinary skill in the art would
` 6 understand it.
` 7 So the statement that it wasn't used in my
` 8 declaration isn't correct. It was. It was
` 9 applied, where needed, as would be understood by
`10 someone of ordinary skill in the art.
`11 Q. The statement you're referring to is that
`12 thin film refers to one or more multiple layers
`13 of --"
`14 MR. SMITH: Objection.
`15 Q. Excuse me. Let me rephrase that.
`16 The statement that you're referring to is
`17 "thin films refer to one or multiple layers of
`18 coverage over a surface."
`19 MR. SMITH: Objection.
`20 A. No.
`21 Q. Which statement wasn't used in your
`22 declaration?
`23 MR. SMITH: Objection.
`24 A. You're not representing what I said
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`Stanley R. Shanfield, Ph.D. - Vol. II
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`Page 213
`
` 1 correctly.
` 2 What I said was, that, a person of
` 3 ordinary skill's understanding of a thin film and
` 4 what it meant in various contexts was applied in my
` 5 declaration.
` 6 Q. In the '501 patent, what would a person of
` 7 ordinary skill understand "thin film" to mean?
` 8 MR. SMITH: Objection.
` 9 A. I need more specific context.
`10 Are you talking about the photoresist
`11 step?
`12 Are you talking about a thin film metal at
`13 the gate step?
`14 Are you talking about polysilicon
`15 deposition?
`16 Are you talking about the dielectric with
`17 low pressure CVD, or is there another step?
`18 Is there residue in thin film that you're
`19 talking about?
`20 I need the context to give you a good
`21 answer.
`22 Q. Is your testimony that you may or may not
`23 have used that interpretation of "film" in your
`24 declaration --
`
` 1 where it applies.
` 2 And as I've explained now several times,
` 3 it -- the context is what someone of ordinary skill
` 4 in the art would view was, you know, a different
` 5 meaning, like a photoresist layer, or a metal
` 6 layer, or two different dielectric layers, or two
` 7 different deposition steps than -- it's -- it's a
` 8 different explanation appropriate to that context.
` 9 Q. So I'd like to discuss the context of film
`10 in the '501 patent in claim 1.
`11 A. Okay.
`12 Q. To do so, I want to confirm that we're
`13 discussing the same interpretation of "film."
`14 A. Which film?
`15 Q. Can we make sure that we have the same
`16 interpretation of film in mind, and then I'll ask
`17 whether it applies to each film in claim 1.
`18 MR. SMITH: Objection.
`19 A. No.
`20 Q. No -- no, you can't tell me whether that
`21 definition -- interpretation -- strike that.
`22 A. There are several films discussed in claim
`23 1.
`24 Q. Can we discuss each film and whether that
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`Page 212
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`Page 214
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` 1 MR. SMITH: Objection.
` 2 Q. -- depending on the context?
` 3 A. No.
` 4 Q. Did you use that definition of "thin film"
` 5 throughout your declaration?
` 6 MR. SMITH: Objection.
` 7 A. I think I've explained that I used what
` 8 person of ordinary skill would understand is a thin
` 9 film within each relevant context in the '501
`10 patent.
`11 Q. Could you look at claim 1 of the '501
`12 patent.
`13 We've been discussing the interpretation
`14 of "thin film" that a "thin film" refers to one or
`15 more -- let me rephrase.
`16 A "thin film refers to one or multiple
`17 layers of coverage over a surface."
`18 MR. SMITH: Objection.
`19 Q. Is that the interpretation that we've been
`20 discussing?
`21 MR. SMITH: Objection.
`22 A. It's -- it's not necessarily applicable.
`23 It was in response to a question about a specific
`24 kind of deposition. And in that context, that's
`
` 1 interpretation applies to that film?
` 2 MR. SMITH: Objection.
` 3 A. Like I've said, I will provide you with
` 4 what I believe a person of skill in the art would
` 5 understand is a thin film in each context.
` 6 Q. Do you see the limitation "a gate
` 7 insulating film formed on the active region"?
` 8 A. Yes.
` 9 Q. Would a person of ordinary skill in the
`10 art understand that that film refers to one or
`11 multiple layers of coverage?
`12 A. (Witness reviews document.)
`13 MR. SMITH: Objection.
`14 A. So you're -- you're taking my explanation
`15 for a plasma CVD-deposited film and trying to apply
`16 it to a different kind of thin film.
`17 I'd appreciate it if you would not
`18 misinterpret me that way. It's not deposited in
`19 CVD, a gate insulating film in general. It's a
`20 different context.
`21 So I'd ask you to please stop repeating an
`22 interpretation or a discussion of a film regarding
`23 plasma CVD deposition in the context of a gate
`24 insulator.
`
`Min-U-Script®
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`Taiwan Semiconductor Manufacturing Co., LTD v.
`GODO Kaisha IP Bridge 1
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`Page 215
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` 1 Q. Is it your testimony that a person of
` 2 ordinary skill in the art would not understand that
` 3 a gate insulating film may be one or multiple
` 4 layers of coverage?
` 5 MR. SMITH: Objection.
` 6 A. I think I've made myself clear. You keep
` 7 repeating an explanation I offered for plasma
` 8 enhanced CVD deposited dielectric film.
` 9 The gate oxide film in the '501 patent is
`10 not deposited by plasma enhanced CVD. And like I
`11 explained, when the context changes -- and now
`12 you're talking about a gate insulating film -- my
`13 attempt to provide an explanation for a plasma
`14 enhanced CVD film is just not applicable.
`15 Q. Doctor Shanfield, my question is whether
`16 that definition describes a gate insulating film.
`17 A. No.
`18 MR. SMITH: Objection.
`19 A. No.
`20 Q. So a gate insulating film cannot be one or
`21 multiple layers of coverage.
`22 MR. SMITH: Objection.
`23 A. No, not true.
`24 Q. A gate insulating film can be one or
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`Stanley R. Shanfield, Ph.D. - Vol. II
`March 28, 2018
`Page 217
` 1 temperature, and typically water vapor or other
` 2 kinds of gases, and it's oxidized. That process is
` 3 very different from plasma CVD process. And it
` 4 grows one kind of film, oxide film, that will
` 5 use -- consume some of the silicon in the active
` 6 layer, and -- and you'll end up with a layer that's
` 7 on the active element region -- or on the active
` 8 region.
` 9 And Igarashi describes it very well.
`10 It's also very much a routine process.
`11 And part of the key of why MOSFETS work so well,
`12 that growth of the oxide on silicon was originally
`13 how devices with low