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` Paper No. __
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`TAIWAN SEMICONDUCTOR MANUFACTURING CO., LTD,
`Petitioner,
`
`v.
`
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`____________
`
`Case IPR2017-018431
`Patent 7,893,501
`____________
`
`PATENT OWNER’S MOTION FOR
`OBSERVATIONS ON CROSS-EXAMINATION
`
`
`1 Case IPR2017-01844 has been consolidated with this proceeding. See Paper 10
`at 3.
`
`
`
`

`

`
`
`Godo Kaisha IP Bridge 1 (“Patent Owner”) submits this motion for
`
`observations regarding the cross-examination of Petitioner’s expert (“Shanfield”).
`
`I.
`
`SHANFIELD’S CHANGED TESTIMONY REGARDING CLAIM 1
`REQUIRING STRESS
`
`Observation #1: In Ex. 2232 at 56:17-58:2 and 160:20-23, Shanfield testified that
`
`it was his opinion that claim 1 requires that the silicon nitride film induce stress in
`
`the substrate; at 167:14-18 Petitioner’s counsel instructed Shanfield that
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`limitations in a dependent claim are not present in the independent claim; at 172:8-
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`14 Shanfield stated that “now that I understand the legal issue, Claim 1 does not …
`
`have any language in it that requires the film to have stress, as I said before;” 2 at
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`175:22-24 Shanfield testified that the instruction from counsel “changed what I
`
`knew about the relationship between dependent and independent claims;” and at
`
`176:4-16 Shanfield stated that he “mistakenly … thought legally there was a
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`requirement that the … dependent claims read back into the independent claim
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`the limitations in the dependent claims.” This is relevant to Shanfield’s Reply
`
`Declaration (Exhibit 1232) at ¶20 where Shanfield testified that it was his opinion
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`that a silicon nitride film as claimed can include multiple layers only if those layers
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`were vertically stacked and “can apply a stress to the substrate as a whole” and
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`Petitioner’s Reply at 8-9 that relies upon that testimony. This testimony is relevant
`
`
`2 Emphasis added unless noted otherwise.
`
`
`
`1
`
`

`

`
`
`because it demonstrates that Shanfield’s opinion that multiple layers can only form
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`a film as claimed in the ’501 patent if they “apply a stress to the substrate as a
`
`whole” was offered because he was under the mistaken belief that claim 1 requires
`
`that the film impart stress.
`
`II.
`
`SHANFIELD’S TESTIMONY ABOUT WHAT CONSTITUTES A
`FILM
`Observation #2: In Ex. 2232 at 40:11-41:3, Shanfield testified that the ’501
`
`patent’s gate electrode is a film (i.e., one of “two films”). This testimony is
`
`relevant to Ex. 2210 at 311:14-312:8 where Shanfield testified exactly the opposite
`
`stating that the ’501 patent’s gate electrode is not a film “[a]s simple as that.” This
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`testimony is relevant because Shanfield offered directly contradictory testimony
`
`about the meaning of “film” as used in the ’501 patent, demonstrating that his
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`testimony on this key issue is unreliable.
`
`III. SHANFIELD’S TESTIMONY ABOUT MULTIPLE LAYERS OF
`DIFFERENT MATERIALS FORMING A FILM
`
`Observation #3: In Ex. 2232 at 7:24-8:8, Shanfield testified that his “working
`
`understanding of the term ‘film’ that [he] applied in opining on the claims” was
`
`“It’s a layer or layers of material.” This testimony is relevant to Exhibit 1232, ¶20
`
`where Shanfield testified that a silicon nitride film as used in the ’501 can only
`
`include multiple layers if those layers are vertically stacked and “can apply a stress
`
`to the substrate as a whole” because, according to Shanfield, “[n]owhere does the
`
`
`
`2
`
`

`

`
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`’501 patent state that two adjacent films … would be considered ‘layers’ of a
`
`single film.” This testimony is relevant because it demonstrates that Shanfield’s
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`“working understanding of the term ‘film’” is far broader than the narrow
`
`interpretation (i.e., limited to layers that are vertically stacked and that apply
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`stress) that Shanfield applied in justifying his opinion that Misra’s silicon nitride
`
`layers 20 and 23 are somehow not multiple layers of a single film, and reveals that
`
`Shanfield’s “analysis” for limiting the broad “working understanding of film” to
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`vertical layers (i.e., because the ’501 patent does not expressly describe adjacent
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`layers) fails because the ’501 patent’s disclosure of multiple layers at 5:60-64 is,
`
`like Shanfield’s broad “working understanding of film,” broad and generic and
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`also does not limit the layers to being vertically stacked the way Shanfield’s
`
`Exhibit 1232, ¶20 testimony does.
`
`Observation #4: The same testimony cited in Observation #3 (Ex. 2232 at 7:24-
`
`8:8, Shanfield testified that his “working understanding of the term ‘film’ that [he]
`
`applied in opining on the claims” was “It’s a layer or layers of material”) also is
`
`relevant to Ex. 2210 at 306:14-20 where Shanfield admitted “a silicon nitride
`
`film,” as used in claim 1 may include multiple “layers” (plural). This testimony is
`
`relevant because it reinforces Shanfield’s earlier testimony that “film” is a broad
`
`term that can include multiple layers and refutes Shanfield’s Exhibit 1232, ¶20
`
`
`
`3
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`

`

`
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`testimony that “film” is instead a narrow term limited to layers that are vertically
`
`stacked and apply stress.
`
`Observation #5: The same testimony cited in Observation #3 (Ex. 2232 at 7:24-
`
`8:8, Shanfield testified that his “working understanding of the term ‘film’ that [he]
`
`applied in opining on the claims” was “It’s a layer or layers of material”) also is
`
`relevant to pages 46-48 of the POR where Patent Owner pointed out that Shanfield,
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`in his prior deposition, admitted that layers 20 and 23 in Misra are both formed
`
`through a PECVD process which is a film formation process that forms “one or
`
`multiple layers of coverage over a surface.” This testimony is relevant because it
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`reinforces Shanfield’s earlier testimony that “film” is a broad term that can include
`
`multiple layers and refutes Shanfield’s Exhibit 1232, ¶20 testimony that “film” is
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`instead a narrow term limited to layers that are vertically stacked and apply stress.
`
`Observation #6: In Ex. 2232 at 26:23-27:10, Shanfield testified that if a “plasma-
`
`deposited silicon nitride is put down and then another layer of silicon nitride on top
`
`of that is put down … that’s still a film” even if the deposited layers are “separated
`
`in time.” This testimony is relevant to (1) page 42 of the Petition where Petitioner
`
`asserts that Misra’s elements 20 and 23 are not a single film because “they are
`
`formed through different process steps” and (2) pages 46-48 of the POR where
`
`Patent Owner pointed out that Shanfield, in his prior deposition, admitted that
`
`layers 20 and 23 in Misra are both formed through the same PECVD process,
`
`
`
`4
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`

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`
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`which is a process by which thin films are formed as “one or multiple layers of
`
`coverage over a surface.” This testimony is relevant because Shanfield’s
`
`admission that two silicon nitride layers formed by the same process “separated in
`
`time” (like layers like 20 and 23 in Misra which Shanfield previously admitted are
`
`formed via the same PECVD process) are “still a film,” directly contradicts the
`
`assertion in the Petition that Misra’s layers 20 and 23 cannot be considered to form
`
`a film because “they are formed through different process steps” because,
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`according to Shanfield, they are formed at different times.
`
`Observation #7: In Ex. 2232 at 26:8-22, Shanfield testified that it is not “an
`
`absolute rule” that “if the same manufacturing step is performed twice, but it is
`
`separated by some time, that it would be a different process step.” This testimony
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`is relevant to (1) page 42 of the Petition where Petitioner asserts that Misra’s
`
`elements 20 and 23 are not a single film because “they are formed through
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`different process steps” and (2) pages 46-48 of the POR where Patent Owner
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`pointed out that Shanfield, in his prior deposition, admitted that layers 20 and 23 in
`
`Misra are both formed through the same PECVD process, which is a process by
`
`which thin films are formed as “one or multiple layers of coverage over a surface.”
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`This testimony is relevant because Shanfield’s admission that there is no absolute
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`rule that layers like 20 and 23 in Misra that are formed, as Shanfield previously
`
`admitted by the same process steps, but at different times contradicts the assertion
`
`
`
`5
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`

`

`
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`in the Petition that Misra’s layers 20 and 23 cannot be considered to form a film
`
`because “they are formed through different process steps.”
`
`Observation #8: In Ex. 2232 at 78:20-80:5, Shanfield testified that “this film in
`
`Xiang”—the silicon nitride film made up of layers 80 and 82—“could be made up
`
`of multiple layers which include silicon nitride and silicon oxide” where “it has a
`
`layer of silicon nitride and silicon dioxide.” This testimony is relevant to page 42
`
`of the Petition where Petitioner asserts that Misra’s elements 20 and 23 are not one
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`film because they “are separate structures … formed through different process
`
`steps and serve separate functions.” This testimony is relevant because Shanfield’s
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`admission that a “film” (like that in Xiang) can be made up of layers of different
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`materials contradicts the assertion in the Petition at 42 that Misra’s layers 20 and
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`23 cannot form a film because they are separate structures formed through
`
`different process steps and serve separate functions, because the layers 80 and 82
`
`in Xiang that Shanfield admits form a “film” are formed of different materials and
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`are therefore necessarily separate structures formed through different process steps
`
`and serve separate functions.
`
`IV. SHANFIELD’S TESTIMONY ABOUT WHETHER CLAIM 1 OF
`THE ’501 PATENT REQUIRES THAT “A SILICON NITRIDE
`FILM” IMPART STRESS TO THE SUBSTRATE
`Observation #9: In Ex. 2232 at 56:17-58:2 and 160:20-23, Shanfield testified that
`
`claim 1 requires that the silicon nitride film induce stress in the substrate and, at
`
`
`
`6
`
`

`

`
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`45:3-18, testified that an etch stop layer cannot induce stress. This testimony is
`
`relevant to Ex. 1202 at paragraph 90 where Shanfield testified that element 20 in
`
`Misra is “an etch stop layer” (emphasis original) and that element 20 meets the
`
`requirements of the silicon nitride film limitation. This testimony is relevant
`
`because Shanfield’s testimony that claim 1 requires that the silicon nitride film
`
`induce stress directly contradicts the Petition’s assertion that the silicon nitride film
`
`is met by Misra’s etch stop layer 20, because Shanfield concedes that Misra’s etch
`
`stop layer 20 does not induce stress.
`
` Observation #10: In Ex. 2232 at 160:20-23, Shanfield reverted to his testimony
`
`that claim 1 “requires that the silicon nitride film induce stress” in the substrate
`
`(Ex. 2026 at 56:17-58:2). This testimony is relevant to Ex. 2232 at 144:1-12 and
`
`145:1-147:8, where, in response to improper leading questions from Petitioner’s
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`counsel, Shanfield testified that claim 1 did not require that the silicon nitride film
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`induce stress in the substrate. This testimony is relevant because it reveals that
`
`once Petitioner’s counsel stopped asking improper leading questions, Shanfield
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`reverted to his own (albeit incorrect) testimony that claim 1 requires that the silicon
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`nitride film induce stress in the substrate, and demonstrates that Shanfield’s
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`testimony is unreliable because he freely changed his testimony to conform with
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`the answers Petitioner’s counsel sought even though he had not changed what he
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`believed was the correct answer.
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`
`
`7
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`

`

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`Observation #11: In Ex. 2232 at 167:14-173:3, 173:10-178:4, Shanfield testified
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`that claim 1 does not require that the silicon nitride film induce stress in the
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`substrate. This testimony is relevant to Ex. 2232 at 56:17-58:2 and 160:20-23
`
`where Shanfield repeatedly and consistently testified that claim 1 requires that the
`
`silicon nitride film induce stress in the substrate. This testimony is relevant
`
`because it demonstrates that Shanfield’s testimony is unreliable and that he
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`changed it only in response to Petitioner’s counsel’s improper leading questions,
`
`instructions, and coaching.
`
`Observation #12: In Ex. 2232 at 144:1-12 and 145:1-147:8, Shanfield testified
`
`that claim 1 did not require that the silicon nitride film induce stress in the
`
`substrate and therefore, an etch stop layer could satisfy the silicon nitride film
`
`limitation. This testimony is relevant to Ex. 2232 at 45:3-18 where Shanfield
`
`testified that an etch stop layer cannot induce stress and thus cannot satisfy the
`
`silicon nitride film limitation (Ex. 2232 56:17-58:2 and 160:20-23). This
`
`testimony is relevant because it demonstrates that Shanfield’s testimony is
`
`unreliable and that he changed it only in response to Petitioner’s counsel’s
`
`improper leading questions, instructions, and coaching.
`
`V.
`
`SHANFIELD’S TESTIMONY ABOUT 5:60-64 IN THE ’501 PATENT
`REFERENCING STRESS FILMS
`Observation #13: In Ex. 2232 at 42:20-24, 47:15-20, and 50:6-12, respectively,
`
`Shanfield testified that it was not his opinion that “a silicon nitride film can only be
`
`
`
`8
`
`

`

`
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`made of multiple layers if it applies stress to the substrate as a whole,” that he
`
`“wouldn’t be prepared to make that general statement,” and that “No, [a POSA
`
`would] not necessarily” have that understanding. This testimony is relevant to
`
`paragraph 20 of Exhibit 1232 where Shanfield testified that his interpretation of a
`
`silicon nitride film in the ’501 patent included multiple layers only if those layers
`
`were vertically stacked and “can apply a stress to the substrate as a whole”
`
`because, according to Shanfield, “[n]owhere does the ’501 patent state that two
`
`adjacent films … would be considered ‘layers’ of a single film.” This testimony is
`
`relevant because Shanfield admitted that a POSA would not have understood that
`
`the claimed silicon nitride film can only be made of multiple layers where it
`
`applies stress to the substrate as a whole.
`
`Observation #14: In Ex. 2232 at 26:23-27:10, Shanfield testified that if a “plasma-
`
`deposited silicon nitride is put down and then another layer of silicon nitride on top
`
`of that is put down … that’s still a film” even if the depositions are “separated in
`
`time.” This testimony is relevant to Ex. 2232 at 47:15-48:13 (where Shanfield
`
`testified that a “silicon nitride film that’s applying stress and an etch stop layer on
`
`top of it wouldn’t qualify” as one film in the “context of the ’501 patent claims”);
`
`Ex. 2232 at 44:10-19 (multilayer silicon nitride etch stop wouldn’t qualify); 45:3-
`
`46:5 (same) and 54:10-55:10 (same). This testimony is relevant because Shanfield
`
`inconsistently references stress when identifying whether two layers of silicon
`
`
`
`9
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`

`

`
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`nitride located on top of each other are one film with respect to the ’501 patent
`
`claims—in other words, whether Shanfield considers two layers of silicon nitride
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`on top of each other one film varies arbitrarily depending on whether Shanfield at
`
`that time considers whether the silicon nitride film imparts stress to the substrate.
`
`Observation #15: In Ex. 2232 at 48:14-50:5 and 50:13-20, Shanfield testified that
`
`he “hadn’t given thought to films” that are multilayer and do not apply stress
`
`because “stress films” are the “concern in the ’501 patent” and non-stress films
`
`aren’t “relevant to it.” This testimony is relevant to Ex. 2232 at 31:7-21 and 45:22-
`
`46:5 where Shanfield testified that side-by-side layers and overlapping layers are
`
`not a silicon nitride film in the ’501 patent because they do not apply stress to the
`
`substrate as a whole. See also Ex. 2232 at 46:20-47:14. This testimony is relevant
`
`because Shanfield did not consider when a multilayer non-stress film would meet
`
`the silicon nitride film limitation and only opined that side-by-side layers and
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`overlapping layers do not meet his narrow interpretation of the statement regarding
`
`multilayer stress films at 5:60-64 even though a POSA would have understood that
`
`a film can be made of multiple layers irrespective of whether it can apply a stress
`
`to the substrate as a whole. Observations Nos. 1-6.
`
`Observation #16: The same testimony cited in Observation #15 (Ex. 2232 at
`
`48:14-50:5 and 50:13-20, Shanfield testified that he “hadn’t given thought to
`
`films” that are multilayer and do not apply stress because “stress films” are the
`
`
`
`10
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`

`

`
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`“concern in the ’501 patent” and non-stress films aren’t “relevant to it”) also is
`
`relevant to Ex. 2232 at 33:15-35:14 and 161:10-162:15 where Shanfield testified
`
`that in the context of the ’501 patent “it doesn’t matter if [the layers of a multi-
`
`layer structure are] created by the same process” because if the layers “are on top
`
`of each other and appl[y] stress to the substrate as a whole” they are one film “for
`
`that specific context” but not in general. This testimony is relevant because
`
`Shanfield did not consider when a multilayer non-stress film would meet the
`
`silicon nitride film limitation and thus, his opinion that multilayer stress films do
`
`not need to be formed by the same process would also be applicable to non-stress
`
`films because a POSA would have understood that a film can be made of multiple
`
`layers irrespective of whether it can apply a stress to the substrate as a whole.
`
`Observations Nos. 1, 3-8.
`
`VI. SHANFIELD’S TESTIMONY REGARDING WHETHER MISRA
`DISCLOSES USING MATERIALS OTHER THAN SILICON
`NITRIDE FOR ELEMENT 23 AND WHETHER HIS OPENING
`DECLARATION CITED TO MISRA AT 6:54-58
`Observation #17: In Ex. 2232 at 36:18-37:7, Shanfield admitted that his opening
`
`declaration did not cite Misra at 6:54-58. This testimony is relevant to pages 2, 4-6
`
`of the Reply where Petitioner cites Misra at 6:54-58 and Shanfield’s reply
`
`declaration, to raise an improper new argument, for the first time in its Reply, that
`
`Misra discloses using materials other than silicon nitride for element 23. This
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`testimony is relevant because it confirms that Misra at 6:54-58, which was cited in
`
`
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`11
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`

`

`
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`the Reply, was not cited in Shanfield’s opening declaration and thus, is an
`
`improper reply argument.
`
`Observation #18: In Ex. 2232 at 38:3-8, Shanfield admitted that in his opening
`
`declaration he did not opine that Misra discloses using material other than silicon
`
`nitride for element 23. This testimony is relevant to pages 2, 4-6 of the Reply
`
`where Petitioner cites Shanfield’s reply declaration to raise an improper new
`
`argument, for the first time in its Reply, that Misra discloses using materials other
`
`than silicon nitride for element 23. This testimony is relevant because it confirms
`
`that the argument raised in the Reply that Misra discloses using materials other
`
`than silicon nitride for element 23 relies on Shanfield for a new argument that
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`Shanfield did not make or support in his opening declaration.
`
`VII. DR. GLEW’S EXPLANATION REGARDING THE XIANG FILM
`(DISTINGUISHED DURING PROSECUTION) AND SHANFIELD’S
`ALTERNATIVE EXPLANATION
`Observation #19: In Ex. 2232 at 81:4-82:6, Shanfield admitted that between
`
`figures 9 and 10 of Xiang that the spacers 196 and 198 change shape and that Dr.
`
`Glew explained why (at Ex. 1231 at 125:22-129:20) this change in the shape of the
`
`spacers requires that the film formed by layers 208 and 210 consist of a vertical
`
`layer and a horizontal layer. This testimony is relevant to pages 68-70 of the POR
`
`where Patent Owner explained that Misra’s horizontal layer (element 20) and
`
`Misra’s vertical layer (element 23) are the same as the film in Xiang which was
`
`
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`12
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`

`

`
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`distinguished during prosecution and consists of a horizontal layer and vertical
`
`layer (i.e., layers 208 and 210). This testimony is relevant because Shanfield
`
`acknowledges that he reviewed Dr. Glew’s opinion which explains that the change
`
`in the upper surface and side surfaces of the spacers 196 and 198 (between figures
`
`9 and 10) in Xiang requires that the film formed by layers 208 and 210 consist of a
`
`vertical layer and a horizontal layer.
`
`Observation #20: In Ex. 2232 at 153:7-154:19 and 164:2-165:2, Shanfield
`
`testified that, in his opinion, figures 9 and 10 in Xiang show a simpler process than
`
`proposed by Dr. Glew because, according to Shanfield “It’s actually a couple of
`
`depositions [where f]irst the layer 208, 210, and then layer 216, 218 [are deposited]
`
`and then [chemical mechanical polishing or] CMP” where CMP only reduces the
`
`height of the spacers 196 and 198 because the layers 208 and 210 were deposited
`
`and covered the side surfaces of spacers 196 and 198 prior to the CMP. This
`
`testimony is relevant to Ex. 1231 at 125:22-129:20 and paragraphs 146-47 of Ex.
`
`2208 where Dr. Glew explained that the film in Xiang must consist of a horizontal
`
`layer and vertical layer (i.e., layers 208 and 210) in order to accommodate the
`
`change in height and the change in shape to the side surfaces of the spacers 196
`
`and 198 between figures 9 and 10 in Xiang. This testimony is relevant because the
`
`process proposed by Shanfield would not change the shape of the side surfaces of
`
`spacers 196 and 198 shown between figures 9 and 10, whereas Dr. Glew’s
`
`
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`13
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`
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`explanation of Xiang’s film consisting of a vertical layer and a horizontal layer
`
`explains how the height and the shape of the side surfaces of spacers 196 and 198
`
`are changed between figures 9 and 10, which demonstrates that Dr. Glew
`
`accurately identified that Xiang’s film, which was distinguished in prosecution,
`
`consists of a horizontal layer and vertical layer just as Misra’s horizontal layer
`
`(element 20) and vertical layer (element 23) form a film.
`
`VIII. SHANFIELD’S OPINION THAT THERE IS NEAR-ZERO STRESS
`BETWEEN THE EDGES OF ADJACENT SAME-TYPE STRESS
`FILMS
`Observation #21: In Ex. 2232 at 61:19-63:24 and 65:23-68:1, Shanfield testified
`
`that paragraph 40 of exhibit 1232 shows that there is near-zero stress in the
`
`substrate at the interface between two adjacent, same-type stress films and that the
`
`interface of element 8a and sidewall 7 on the left hand side of Figure 1 will have
`
`“the qualities of the discontinuity in stress [i.e., near-zero]… depicted” in
`
`paragraph 40. This is relevant to the ’501 patent (1) at 4:56-5:10 which describes
`
`that in Figure 1 (where sidewall 7 is present) that compressive film 8a creates a
`
`tensile stress in the substrate between the two edges of film 8a located on either
`
`side of gate electrode 6a where the substrate stress is increased by bringing the two
`
`edges of film 8a closer together and (2) at 7:62-8:8 which confirms that removing
`
`sidewall 7 in Figure 4A increased the tensile stress in the substrate between the
`
`two edges of film 8a over that of Figure 1 because the edges of film 8a were
`
`
`
`14
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`

`

`
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`brought closer together. This testimony is relevant because Shanfield’s testimony
`
`that there is non-zero stress between the edges of same-type stress films is
`
`contradicted by the ’501 patent which expressly discloses that decreasing the
`
`distance between the edges of same-type stress films increases the stress in the
`
`substrate between the edges of the films and that in Figure 1, contrary to
`
`Shanfield’s testimony of near-zero stress, that there is .3 GPa tensile stress in the
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`substrate at the interface of film 8a and sidewall 7.
`
`Dated: August 9, 2018
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`Respectfully submitted,
`Godo Kaisha IP Bridge 1
`
`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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`15
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
`
`I certify that on August 9, 2018 I will cause a copy of the foregoing
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`document, including any exhibits referred to therein, to be served via electronic
`
`mail, as previously consented to by Petitioner, upon the following:
`
`
`
`David L. Cavanaugh
`
`Dominic E. Massa
`
`Michael H. Smith
`
`David.Cavanaugh@wilmerhale.com
`
`Dominic.Massa@wilmerhale.com
`
`MichaelH.Smith@wilmerhale.com
`
`
`
`
`
`
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`
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`
`
`/MacAulay Rush/
`MacAulay Rush
`Patent Paralegal
`WOLF GREENFIELD & SACKS, P.C.
`
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`Date: August 9, 2018
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