`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
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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 COMPANY LTD.
`Petitioner
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`v.
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`GODO KAISHA IP BRIDGE 1
`Patent Owner.
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`Case IPR2017-018431
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`PETITIONER’S RESPONSE PURSUANT TO JULY 20, 2018 ORDER
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`1 Case IPR2017-01844 has been consolidated with this proceeding.
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`1. The Reply at 2-3 and 4-6 does not raise a new argument. Rather, it points out
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`the failure of the Patent Owner’s response to address Dr. Shanfield’s responses to
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`Patent Owner’s questions about what materials Misra uses for the sidewalls. The
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`Reply points out on page 2 and again on page 4 where the Petition showed the gate
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`protrudes above the silicon nitride (“SiN”) film, and where the Petition
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`additionally showed that this is true even if the spacers are made of SiN. The
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`Reply at 4-6 identifies Patent Owner’s questioning Dr. Shanfield on this disclosure
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`during cross-examination. The Reply identifies where in the transcript Patent
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`Owner asked Dr. Shanfield about Misra’s embodiments where the spacers are
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`made of other materials and where Dr. Shanfield confirmed that Misra discloses
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`the sidewalls may be made of other materials like a thermally grown silicon oxide.
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`The Reply explains that Patent Owner ignores this testimony and only addresses
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`the embodiments where the sidewalls are SiN. This position is also anchored in
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`the Petition at 40-42 and Dr. Shanfield’s testimony regarding the sidewalls. The
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`Reply also confirms in response to PO’s arguments and as set forth in the Petition
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`that Misra discloses the protruding gate regardless of whether spacers 23 are
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`constructed out of silicon nitride. Pet. at 42-43; Reply at 3-4, 6-29.
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`2. The citation to Misra at Ex. 1204, 6:54-58, is also responsive to Patent Owner’s
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`questioning of Dr. Shanfield and anchored in the Petition and testimony of record,
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`for the same reasons as described in Item 1., above.
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`1
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`U.S. Patent 7,893,501
`IPR2017-01843
`Petitioner’s Response Pursuant to July 20, 2018 Order
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`Dated: July 27, 2018 Respectfully Submitted,
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`/Michael Smith/
`_______________________________
`Michael H. Smith, Reg. No. 71,190
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` 2
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`CERTIFICATE OF SERVICE
`I hereby certify that, on July 27, 2018, I caused a true and correct copy of the
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`foregoing materials:
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` Petitioner’s Response Pursuant to July 20, 2018 Order
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`to be served via email on the following counsel of record as listed in Patent
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`Owner’s Mandatory Notices:
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`Gerald B. Hrycyszyn, Registration No. 50,474
`GHrycyszyn-PTAB@wolfgreenfield.com
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`Richard F. Giunta, Registration No. 36,149
`RGiunta-PTAB@wolfgreenfield.com
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`Edmund J. Walsh, Registration No. 32,950
`EWalsh-PTAB@wolfgreenfield.com
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`Joshua Miller, pro hac vice
`Joshua.Miller@WolfGreenfield.com
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`Wolf, Greenfield & Sacks, P.C.
`600 Atlantic Avenue
`Boston, Ma 02210
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`Respectfully Submitted,
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`___/Michael Smith/_________
`Michael H. Smith
`Registration No. 71,190
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`3
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