`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 IPR2017-018431
`
`
`PETITIONER’S RESPONSE PURSUANT TO JULY 20, 2018 ORDER
`
`
`1 Case IPR2017-01844 has been consolidated with this proceeding.
`
`
`
`
`
`
`
`1. The Reply at 2-3 and 4-6 does not raise a new argument. Rather, it points out
`
`the failure of the Patent Owner’s response to address Dr. Shanfield’s responses to
`
`Patent Owner’s questions about what materials Misra uses for the sidewalls. The
`
`Reply points out on page 2 and again on page 4 where the Petition showed the gate
`
`protrudes above the silicon nitride (“SiN”) film, and where the Petition
`
`additionally showed that this is true even if the spacers are made of SiN. The
`
`Reply at 4-6 identifies Patent Owner’s questioning Dr. Shanfield on this disclosure
`
`during cross-examination. The Reply identifies where in the transcript Patent
`
`Owner asked Dr. Shanfield about Misra’s embodiments where the spacers are
`
`made of other materials and where Dr. Shanfield confirmed that Misra discloses
`
`the sidewalls may be made of other materials like a thermally grown silicon oxide.
`
`The Reply explains that Patent Owner ignores this testimony and only addresses
`
`the embodiments where the sidewalls are SiN. This position is also anchored in
`
`the Petition at 40-42 and Dr. Shanfield’s testimony regarding the sidewalls. The
`
`Reply also confirms in response to PO’s arguments and as set forth in the Petition
`
`that Misra discloses the protruding gate regardless of whether spacers 23 are
`
`constructed out of silicon nitride. Pet. at 42-43; Reply at 3-4, 6-29.
`
`2. The citation to Misra at Ex. 1204, 6:54-58, is also responsive to Patent Owner’s
`
`questioning of Dr. Shanfield and anchored in the Petition and testimony of record,
`
`for the same reasons as described in Item 1., above.
`
`1
`
`
`
`U.S. Patent 7,893,501
`IPR2017-01843
`Petitioner’s Response Pursuant to July 20, 2018 Order
`
`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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