`
`1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
`
`APPLIED MATERIALS, INC.
`Petitioner
`
`v.
`
`OCEAN SEMICONDUCTOR LLC,
`Patent Owner
`
`‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
`
`IPR2021‐01342
`U.S. Patent No. 6,968.248
`
`‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
`
`‐ ‐ ‐
`
`June 7, 2022
`
`‐ ‐ ‐
`
`Oral deposition of DR. STANLEY
`
`SHANFIELD, taken pursuant to Notice, held
`
`via Zoom, beginning at approximately 10:00
`
`a.m., before mary Hammond, a Registered
`
`Page 1
`
` IPR2021-01342
`Ocean Semi EXHIBIT 2044
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6 7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`
`
`23
`
`24
`
`DrStanleyShanfield_Rough
`Professional Reporter and Notary Public in
`
`the state of Pennsylvania.
`
`2
`
`1 A‐P‐P‐E‐A‐R‐A‐N‐C‐E‐S
`
`2
`
`AXINN, VELTROP & HARKRIDER, LLP
`3 BY: DON ZHE NAN WANG, ESQUIRE
`BY: ERIC A. KRAUSE, ESQUIRE
`4 560 Mission Street
`San Francisco, California 94105
`5 (415) 490‐1499
`dwang@axinn.com
`6 ekrause@axinn.com
`Counsel for Petitioner
`
`7 8
`
` DEVLIN LAW FIRM
`BY: JOSEPH ZITO, ESQUIRE
`9 1526 Gilpin Avenue
`Wilmington, Delaware 19806
`10 (610) 240‐9180
`jzito@devlinlawfirm.com
`11 Counsel for Patent Owner
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`Page 2
`
`
`
`DrStanleyShanfield_Rough
`
` 22
`
` 23
`
` 24
`
`
` 1 ‐ ‐ ‐
`
` 2 I‐N‐D‐E‐X
`
` 3 ‐ ‐ ‐
`
` 4 WITNESS:
`
` 5 DR. STANLEY SHANFIELD
`
` 6 PAGE
`
` 7 BY MR. ZITO 4
`
` 8 BY MR. WANT ‐‐
`
` 9 BY MR. KRAUSE ‐‐
`
` 10
`
` 11
`
` 12 ‐ ‐ ‐
`
` 13 E‐X‐H‐I‐B‐I‐T‐S
`
` 14 ‐ ‐ ‐
`
` 15
` NAME DESCRIPTION PAGE
` 16
`
` 17 (Whereupon, there were no exhibits
`
` 18 marked at this time.)
`
` 19
`
`Page 3
`
`
`
`DrStanleyShanfield_Rough
`
` 20
`
` 21
`
` 22
`
` 23
`
` 24
`
`
`00:00:20 1 ‐ ‐ ‐
`
` 2 P‐R‐O‐C‐E‐E‐D‐I‐N‐G‐S
`
` 3 ‐ ‐ ‐
`
` 4 (By agreement of counsel, the
`
` 5 sealing, certification and filing are
`
` 6 waived, and all objections as to the form
`
` 7 of the question, are reserved until the
`
` 8 time of trial.)
`
` 9 ‐ ‐ ‐
`
`00:13:59 10 DIRECT EXAMINATION
`
` 11 ‐ ‐ ‐
`
` 12 BY MR. ZITO:
`
` 13 Q. Good morning Dr. Shanfield.
`
` 14 A. Good morning.
`
`00:14:34 15 MR. WANG: Before ‐‐ sorry. I
`
` 16 didn't realize we weren't making
`
` 17 appearances. This is Don Wang. I'm here
`
` 18 from Axinn, Veltrop & Harkrider. We are
`Page 4
`
`
`
`DrStanleyShanfield_Rough
`
` 19 here on behalf of the Ocean Semiconductor
`
`00:14:43 20 LLC, and also here with me is Ed Krause.
`
` 21 We just want to make an objection on the
`
` 22 record that Mr. Zito has not appeared in
`
` 23 the two matters before ‐‐ before what
`
` 24 we're doing today which is IPR2021‐01342
`
`
`00:15:03 1 and IPR‐01344. My understanding is the
`
` 2 Mr. Zito will file an appearance by the
`
` 3 end to the day. Thank you. Sorry for the
`
` 4 interpretation.
`
`00:15:15 5 MR. ZITO: No problem. That's our
`
` 6 understanding today, too. I will file my
`
` 7 appearance by the end of the day.
`
` 8 BY MR. ZITO:
`
` 9 Q. Good morning, again, Dr. Shanfield.
`
`00:15:24 10 A. Yes.
`
` 11 Q. Good to see you.
`
` 12 A. Likewise.
`
` 13 Q. You understand we're here on two patents
`
` 14 today?
`
`00:15:33 15 A. Yes.
`
` 16 Q. Okay. The 248 and the 305 patent,
`
`Page 5
`
`
`
` 17 correct?
`
`DrStanleyShanfield_Rough
`
` 18 A. Correct, yes.
`
` 19 Q. All right. And my understanding we're
`
`00:15:44 20 doing this as a combined deposition where I'm going
`
` 21 to you questions in this one deposition can be used
`
` 22 in both of those IPRs.
`
` 23 MR. ZITO: Is that also Counsel's
`
` 24 understanding?
`
`
`00:15:59 1 MR. WANG: That's fine with us.
`
` 2 MR. ZITO: We're not going to split
`
` 3 it up into one patent versus the other,
`
` 4 okay.
`
`00:16:04 5 BY MR. ZITO:
`
` 6 Q. Looking at the ‐‐ let's look first at the
`
` 7 6,968.248 patent. Can you briefly summarize what
`
` 8 your understanding is of the teacher teachings of
`
` 9 the 248 patent?
`
`00:16:20 10 A. I think the abstract is a good
`
` 11 description. It a method and apparatus for
`
` 12 scheduling in an automated manufacturing
`
` 13 environment.
`
` 14 Q. And would that be the same description for
`
`00:16:40 15 the 305 patent?
`
`Page 6
`
`
`
`DrStanleyShanfield_Rough
`
` 16 A. Yes.
`
` 17 Q. And can you tell me what in the timeframe
`
` 18 of the filing or the priority date of 2002 what was
`
` 19 met by scheduling in a manufacturing environment?
`
`00:17:06 20 MR. WANG: Objection, scope and
`
` 21 form.
`
` 22 BY MR. ZITO:
`
` 23 Q. From a perspective of one of ordinary
`
` 24 skill in the art?
`
`
`00:18:28 1 A. So I take this question up to some extent
`
` 2 in my declaration paragraph 131 where the preamble
`
` 3 says a method for scheduling in an automated
`
` 4 manufacturing environment and as I explained there,
`
`00:18:51 5 Schulze discloses such a manufacturing environment.
`
` 6 He's describing a semiconductor fabrication facility
`
` 7 within an automated monitoring an assessment system.
`
` 8 So that would be my understanding of one version of
`
` 9 an automated manufacturing environment.
`
`00:19:18 10 Q. Scrolling ‐‐ I'm scrolling down to
`
` 11 paragraph 101. Give me a second.
`
` 12 A. 101 in where?
`
` 13 Q. Right. In your declaration?
`
`Page 7
`
`
`
`DrStanleyShanfield_Rough
` 14 A. Okay.
`
`00:19:32 15 Q. Okay. Where you talk about Gupta
`
` 16 teachings, is that the paragraph you're looking at?
`
` 17 A. No. No. 131.
`
` 18 Q. 131. My mistake. All right. So you use
`
` 19 Schulze as the reference ‐‐ that's Schulze 083,
`
`00:20:08 20 which is the Schulze patent application publication,
`
` 21 correct, that you're referring to?
`
` 22 A. Yes, that's correct, Exhibit‐1007.
`
` 23 Q. And you use that for as an example of your
`
` 24 understanding of person of ordinary skill in the art
`
`
`00:20:28 1 for an automated manufacturer environment in the
`
` 2 2002 timeframe?
`
` 3 A. That's correct.
`
` 4 Q. You go on to say that a person of ordinary
`
`00:20:56 5 skill in the art would be automated to combine the
`
` 6 teachings of Schulze and Gupta. What does Gupta add
`
` 7 to Schulze?
`
` 8 A. What Gupta and Schulze combined it
`
` 9 discloses a photo for scheduling the operation of
`
`00:21:17 10 interrelated machines which perform on process flow
`
` 11 on a highly automated in this case front end
`
` 12 manufacturing facility for integrated circumstances
`Page 8
`
`
`
`DrStanleyShanfield_Rough
`
` 13 and that comes from circuits and that comes from
`
` 14 Gupta's abstract.
`
`00:21:43 15 Q. Okay. And that would make ‐‐ combining
`
` 16 these two would make a system for automatic
`
` 17 scheduling or just Gupta has the system for
`
` 18 automated scheduling?
`
` 19 MR. WANG: Objection. Form.
`
`00:22:00 20 THE WITNESS: So, what I am saying
`
` 21 is that a person of skill in the art would
`
` 22 have in motivated to combine Schulze and
`
` 23 Gupta in that combination discloses a
`
` 24 method for scheduling the operation of
`
`
`00:22:20 1 interrelated machines, which perform a
`
` 2 process flow in a highly automated front
`
` 3 end manufacturing facility for integrated
`
` 4 circuits.
`
`00:22:32 5 BY MR. ZITO:
`
` 6 Q. But neither of them alone keeps that; is
`
` 7 that correct?
`
` 8 A. No. I don't know which ‐‐ what part of it
`
` 9 you're referring to but ‐‐
`
`00:22:44 10 Q. Okay.
`
`Page 9
`
`
`
`DrStanleyShanfield_Rough
` 11 A. I don't agree with that statement.
`
` 12 Q. Well then why come ‐‐ if either Gupta or
`
` 13 Schulze alone taught a method for scheduling in an
`
` 14 automated manufacturing environment what would be
`
`00:23:00 15 the need to combine them?
`
` 16 MR. WANG: Objection to form.
`
` 17 THE WITNESS: You had started off
`
` 18 by asking me what an automated
`
` 19 manufacturing was and ‐‐
`
`00:23:25 20 BY MR. ZITO:
`
` 21 Q. Right.
`
` 22 A. And I said that Schulze disclosed that.
`
` 23 Q. Correct. But in shelters there isn't any
`
` 24 scheduling of anything in that environment, correct?
`
`
`00:23:39 1 MR. WANG: Objection, form.
`
` 2 THE WITNESS: No, it's not correct.
`
` 3 BY MR. ZITO:
`
` 4 Q. Okay where does Schulze talk about
`
`00:23:44 5 scheduling things in an automated manufacturing
`
` 6 environment?
`
` 7 A. So Schulze uses or describes a system and
`
` 8 method for automated monitoring assessment of a
`
` 9 fabrication facility. One of the aspects that you
`Page 10
`
`
`
`DrStanleyShanfield_Rough
`
`00:24:53 10 read about in Schulze in paragraph 15 at the bottom
`
` 11 is what he says during operation, the state models
`
` 12 are updated for each tool affected by one of the
`
` 13 triggers and transitions within the state model are
`
` 14 recorded in a track tracking database. So there
`
`00:25:21 15 they're state of equipment whether ‐‐ and I think he
`
` 16 gives a number of examples, unscheduled downtime,
`
` 17 that's in Paragraph 8 in about the middle, scheduled
`
` 18 downtime, engineering time, stand by time,
`
` 19 productive time, all of those are inputs to a
`
`00:25:46 20 scheduling activity and so Schulze is ‐‐ relates,
`
` 21 you know, intimately with what is required to
`
` 22 perform scheduling and provides that information to
`
` 23 be able to accomplish scheduling Schulze.
`
` 24 Q. Is there any place else that you believe
`
`
`00:26:28 1 Schulze discusses scheduling?
`
` 2 A. That ‐‐ those aspects of states is
`
` 3 discussed all the way through Schulze. It would
`
` 4 probably take me 20 minutes to go through all the
`
`00:26:49 5 places where this equipment state concept is
`
` 6 discussed, so your question would take a while to
`
` 7 answer.
`
`Page 11
`
`
`
`DrStanleyShanfield_Rough
` 8 Q. All right. And does Schulze talk about
`
` 9 changing scheduling based upon it's monitoring of
`
`00:27:09 10 any of these state models?
`
` 11 A. Could you repeat your question.
`
` 12 Q. Sure. Does Schulze has as you said for
`
` 13 monitoring equipment, correct?
`
` 14 A. No, I didn't say that.
`
`00:28:24 15 Q. Okay. Then you read from about missing
`
` 16 semiconductor fabrication facility?
`
` 17 A. Right.
`
` 18 Q. And does that through not directly
`
` 19 monitoring the single time equipment but
`
`00:28:41 20 receiving ‐‐ Mary ‐‐ state signals amongst other
`
` 21 things regarding each piece of equipment; is that
`
` 22 correct?
`
` 23 A. That's one aspect, yes.
`
` 24 Q. Does Schulze provide any of the
`
`
`00:29:08 1 information it receives or monitoring to a scheduler
`
` 2 does it talk about that anywhere?
`
` 3 MR. WANG: Objection. Form.
`
` 4 THE WITNESS: Well, let me direct
`
`00:29:24 5 you to paragraph 17 about the middle of
`
` 6 the paragraph where it talks about a state
`Page 12
`
`
`
`DrStanleyShanfield_Rough
`
` 7 model logic receives the tracking
`
` 8 operation information for each fabrication
`
` 9 tool having define states in a state
`
`00:29:45 10 transition logic defining triggering
`
` 11 events and a state transitions related to
`
` 12 the trigger ‐‐ the triggering of that ‐‐
`
` 13 of events. Schulze also talks about
`
` 14 triggering events and essentially that
`
`00:30:03 15 change of state is the input a scheduler
`
` 16 is going to take, is going to need and
`
` 17 therefore it's more than just passive
`
` 18 information. There is triggering events
`
` 19 and a specific information needed that
`
`00:30:29 20 gets ‐‐ ends up as input to any scheduling
`
` 21 that might be done.
`
` 22 BY MR. ZITO:
`
` 23 Q. So a state change transition logger is
`
` 24 part of the Schulze system?
`
`
`00:31:20 1 MR. WANG: Objection, form.
`
` 2 THE WITNESS: I didn't say anything
`
` 3 about a logger. I said that Schulze
`
` 4 establishes the state model logic from the
`
`Page 13
`
`
`
`DrStanleyShanfield_Rough
`00:31:35 5 tracking operation information and at and
`
` 6 that some of this logic results in
`
` 7 triggering events. Triggering events will
`
` 8 end up being and are required for
`
` 9 scheduling material in the ‐‐ in the
`
`00:31:54 10 semiconductor scheduling waivers within
`
` 11 semiconductor facility. So it very
`
` 12 directly and intimately involved with
`
` 13 the ‐‐ how the scheduling changes and how
`
` 14 it evolves in the fab.
`
`00:32:23 15 BY MR. ZITO:
`
` 16 Q. Does Schulze state that, what you just
`
` 17 said that these triggering events are important for
`
` 18 scheduling?
`
` 19 MR. WANG: Objection to form.
`
`00:34:15 20 THE WITNESS: Maybe I'm not explain
`
` 21 myself well enough. Let me give you an
`
` 22 example. Paragraph 75 in Schulze talking
`
` 23 about a particular state transition and he
`
` 24 describes that as defined as an automatic
`
`
`00:34:39 1 transition from a productive state to an
`
` 2 unscheduled down state. So it's apparent
`
` 3 in that state transition how relevant
`Page 14
`
`
`
`DrStanleyShanfield_Rough
`
` 4 it ‐‐ apparent to a part to scheduling, I
`
`00:35:00 5 think. Reading, you know, or in
`
` 6 understanding that I and this would be a
`
` 7 person of any skill in the art really will
`
` 8 understand that going from productive
`
` 9 state to an unscheduled down date has to
`
`00:35:16 10 be part of the input to a scheduling
`
` 11 system. I don't know that it could be
`
` 12 anymore clear than that.
`
` 13 BY MR. ZITO:
`
` 14 Q. So am I correct that your testimony is
`
`00:35:28 15 that one or ordinary skill in the art recognize the
`
` 16 relevance of these states to scheduling? It is not
`
` 17 that Schulze specifically says these states are
`
` 18 relevant to scheduling; is that correct?
`
` 19 MR. WANG: Objection, form,
`
`00:35:48 20 compound.
`
` 21 THE WITNESS: No.
`
` 22 BY MR. ZITO:
`
` 23 Q. Okay. Then where does Schulze
`
` 24 specifically directly state that understand where it
`
`
`00:36:04 1 directly state that these ‐‐ that the states that
`
`Page 15
`
`
`
`DrStanleyShanfield_Rough
` 2 are monitored in paragraph 17 would be useful for or
`
` 3 directly relate to a scheduler?
`
` 4 MR. WANG: Objection to form.
`
`00:36:54 5 THE WITNESS: Well the example I
`
` 6 gave you is one place where Schulze refers
`
` 7 to unscheduled down state. He's clearly
`
` 8 thinking about schedule versus unscheduled
`
` 9 downtime being irrelevant difference in
`
`00:37:18 10 it's state and it's only going to be
`
` 11 useful for scheduling. So it's a you
`
` 12 know, a fact of the description that
`
` 13 Schulze is providing that scheduling is
`
` 14 intimately involved in or rather the
`
`00:37:43 15 states that Schulze is providing are
`
` 16 required during scheduling. You know,
`
` 17 the ‐‐ I don't know that I can explain it
`
` 18 anymore thoroughly then that.
`
` 19 BY MR. ZITO:
`
`00:37:58 20 Q. Right. And what I'm not asking for ‐‐ I
`
` 21 understand your opinion on what Schulze is thinking.
`
` 22 And I ask your opinion of what you believe one
`
` 23 ordinary skilled in the art and I'm not asking you
`
` 24 for an explanation I'm asking you to where you can
`
`
`Page 16
`
`
`
`DrStanleyShanfield_Rough
`
`00:38:15 1 point to where Schulze specifically states where
`
` 2 Schulze was thinking that unscheduled downtime would
`
` 3 be important to scheduling where he specifically
`
` 4 makes that statement not what you are giving an
`
`00:38:29 5 opinion on his thinking?
`
` 6 MR. WANG: Objection, form.
`
` 7 THE WITNESS: Well, it may take me
`
` 8 a while to determine whether that
`
` 9 specifically said but I think it ‐‐ it's
`
`00:39:19 10 apparent, for example, in Paragraph 81
`
` 11 when a trigger message causes an automatic
`
` 12 transition from an unscheduled down state
`
` 13 to a productive state, there isn't
`
` 14 anything more relevant to a scheduler then
`
`00:39:39 15 when equipment is in a scheduled down
`
` 16 state and then makes the transition back
`
` 17 to a productive state. That's obviously
`
` 18 something that would be required in order
`
` 19 to perform scheduling. So once again,
`
`00:39:58 20 there's statements all over shut Schulze
`
` 21 about the nature of the system that he's
`
` 22 describing and the method and the mention
`
` 23 of scheduling and a sense of unscheduled
`
` 24 or scheduled downtime is in there as as
`Page 17
`
`
`
`DrStanleyShanfield_Rough
`
`
`00:40:25 1 well. So that's the best I can give you.
`
` 2 BY MR. ZITO:
`
` 3 Q. And Schulze receives all of these
`
` 4 triggers, correct, or receives open messages about?
`
`00:40:40 5 MR. WANG: Objection.
`
` 6 BY MR. ZITO:
`
` 7 Q. Transition from unscheduled down to
`
` 8 productive state; is that correct, my correct
`
` 9 understanding?
`
`00:40:49 10 MR. WANG: Objection, form.
`
` 11 THE WITNESS: No.
`
` 12 BY MR. ZITO:
`
` 13 Q. Okay. How does ‐‐ does Schulze create the
`
` 14 triggering?
`
`00:40:59 15 A. In some cases.
`
` 16 Q. Does Schulze receive the trigger in other
`
` 17 cases?
`
` 18 MR. WANG: Objection, form.
`
` 19 BY MR. ZITO:
`
`00:41:20 20 Q. Let me take you back to paragraph 17.
`
` 21 Roughly where you left off. It says ‐‐ roughly in
`
` 22 the middle of the paragraph and a state transition
`
`Page 18
`
`
`
`DrStanleyShanfield_Rough
` 23 logic defining triggering events and a state trans
`
` 24 later to the trigger event. Is that logic part of
`
`
`00:41:52 1 the Schulze system?
`
` 2 A. I'm sorry. Where were you reading in 17?
`
` 3 Q. 17 ‐‐ one, two, three, four, five, six,
`
` 4 seven, eight lines down at the end of that line the
`
`00:42:07 5 sentence starts with a state model logic.
`
` 6 A. Okay. A state model logic receives the
`
` 7 tracking operation information for each fabrication
`
` 8 tool having defined states and a state transition
`
` 9 log defining trigger events and the state
`
`00:42:33 10 transitions related to the triggering events. So
`
` 11 he's describing there the state model logic of his
`
` 12 method, receives tracking operation information and
`
` 13 then determines a state and a state transition.
`
` 14 Q. Okay. So the tracking operation
`
`00:43:01 15 information could be in the two examples you picked
`
` 16 out productive or unscheduled downtime is that a
`
` 17 correct understanding?
`
` 18 A. No.
`
` 19 MR. WANG: Objection to form.
`
`00:43:14 20 BY MR. ZITO:
`
` 21 Q. So what would be the tracking operation
`Page 19
`
`
`
` 22 information that's received?
`
`DrStanleyShanfield_Rough
`
` 23 A. That would be what, for example, I mean,
`
` 24 and he shows us in his diagram, Figure 1, the MES,
`
`
`00:43:33 1 manufacturing execution system provides tracking
`
` 2 operation information and then Schulze has another
`
` 3 box, let me go up to that diagram, Figure 1, calls
`
` 4 monitoring and assessment system and that ‐‐ that
`
`00:44:00 5 determines the state and has a high did of state
`
` 6 transitions designed in to it.
`
` 7 Q. And that state transition logic would then
`
` 8 define it's triggering event as productive or
`
` 9 unscheduled downtime, for example?
`
`00:45:34 10 A. Schulze actually goes into a lot of detail
`
` 11 in Paragraph 8 on that point. He starts with a
`
` 12 description of this E ten standard, semi standard,
`
` 13 which defines six basic equipment states, total time
`
` 14 for each tools is divided into operations time and
`
`00:45:56 15 non scheduled time and then in about the middle the
`
` 16 paragraph operations time is divided into five
`
` 17 different categories, unscheduled downtime,
`
` 18 scheduled downtime, engineering time, stand by time,
`
` 19 productive time. So those are examples of the
`
`Page 20
`
`
`
`DrStanleyShanfield_Rough
`00:46:13 20 states that ‐‐ in Schulze's method that are can be
`
` 21 assumed and then there are hierarchies of states.
`
` 22 So the ‐‐ he's following the semi standard
`
` 23 definition of the six basic equipment states.
`
` 24 Q. So operations time is a state?
`
`
`00:46:51 1 A. No. Total time for each tool is divided
`
` 2 into operations time and non scheduled time and then
`
` 3 operations time is divided into these categories of
`
` 4 states, unscheduled downtime, scheduled downtime,
`
`00:47:06 5 engineering time, stand by time and productive time.
`
` 6 Q. All right. So ‐‐ around or?
`
` 7 A. And this comprises the six basic equipment
`
` 8 states.
`
` 9 BY MR. ZITO:
`
`00:47:16 10 Q. So unscheduled downtime is a state?
`
` 11 A. Yes.
`
` 12 Q. Okay. Good that's what I thought you said
`
` 13 in 75 and 81 and I was trying to relate that to
`
` 14 paragraph 17. It says a state model logic receives
`
`00:47:30 15 a tracking operation for each fabrication tool
`
` 16 having defined states, okay. So does ‐‐ is that
`
` 17 where ‐‐ where the model logic receives unscheduled
`
` 18 downtime state?
`
`Page 21
`
`
`
`DrStanleyShanfield_Rough
`
` 19 A. No. The box in Schulze's Figure 1
`
`00:47:53 20 receives tracking operation information from MES for
`
` 21 each fabrication tool.
`
` 22 Q. Okay.
`
` 23 A. And then that box defines trigger event,
`
` 24 state transitions related to the triggering event
`
`
`00:48:12 1 and so on.
`
` 2 Q. Okay. Then the next sentence says if the
`
` 3 fabrication tool has a state change, that would be
`
` 4 like from unscheduled downtime to productive time
`
`00:48:25 5 would that be a state change?
`
` 6 A. Yes.
`
` 7 Q. Okay. A state change transition logger
`
` 8 inputs this information to a tracking database
`
` 9 recording transition information. So that's also
`
`00:48:43 10 part of the Schulze system?
`
` 11 A. That's what he describes, yes.
`
` 12 Q. Okay. Then he describes a report
`
` 13 generator that may generate performance matrix for
`
` 14 the fabrication tools, that's also part of the
`
`00:49:00 15 Schulze system?
`
` 16 MR. WANG: Objection, scope.
`
`Page 22
`
`
`
`DrStanleyShanfield_Rough
` 17 THE WITNESS: That's what he's
`
` 18 written in his paragraph 17, yes.
`
` 19 BY MR. ZITO:
`
`00:49:21 20 Q. So is it accurate to say that Schulze
`
` 21 teaches tracking operations looking at states and
`
` 22 trigger events to assess the overall equipment
`
` 23 effectiveness and overall fabrication of
`
` 24 effectiveness of the fabrication tools?
`
`
`00:49:43 1 MR. WANG: Objection, form.
`
` 2 THE WITNESS: No.
`
` 3 BY MR. ZITO:
`
` 4 Q. Okay. Why ‐‐ that's what it says in
`
`00:49:48 5 paragraph 17. Why is that not an accurate
`
` 6 description?
`
` 7 A. That's one of the uses in Schulze. The
`
` 8 state ‐‐ the conditions of the state of equipment
`
` 9 would be I can put to a scheduler. It could be
`
`00:50:11 10 would be essential to any effort to schedule
`
` 11 material that's running through the semiconductor
`
` 12 line and that's I believe what is relevant to the
`
` 13 claims that we're discussing in the 248.
`
` 14 Q. Okay. But my question is does Schulze
`
`00:50:37 15 specifically state that or are you inferring or
`Page 23
`
`
`
`DrStanleyShanfield_Rough
`
` 16 understanding that from Schulze?
`
` 17 MR. WANG: Objection, form.
`
` 18 THE WITNESS: If you're asking does
`
` 19 he use some specific words, why don't you
`
`00:51:06 20 tell me what specific words you ‐‐ you
`
` 21 think are ‐‐ are ‐‐ you're asking me
`
` 22 about. What are the words that I should
`
` 23 look for in your question?
`
` 24
`
`
`00:51:18 1 BY MR. ZITO:
`
` 2 Q. The exact words you use, that this
`
` 3 information is essential to proper scheduling, your
`
` 4 testimony, does he say that in there?
`
`00:51:28 5 A. Yes.
`
` 6 MR. WANG: Objection to form.
`
` 7 THE WITNESS: It's understand that
`
` 8 and that's the nature of scheduling.
`
` 9 Unscheduled downtime means it's not
`
`00:51:39 10 accounted a count for in the schedule.
`
` 11 The term unscheduled got the word schedule
`
` 12 in it. How much more specific can it be?
`
` 13 BY MR. ZITO:
`
`Page 24
`
`
`
`DrStanleyShanfield_Rough
` 14 Q. Well, I'm asking do you find it to be more
`
`00:51:55 15 specific, do you find him to say what you said, that
`
` 16 unscheduled downtime is important to scheduling,
`
` 17 does he say those words?
`
` 18 MR. WANG: Objection, form.
`
` 19 THE WITNESS: Well, I would need to
`
`00:52:14 20 look through the patent to see, but my
`
` 21 guess is no. That is something that is
`
` 22 understood by you know a person of skill
`
` 23 in the art or basically any casual reader
`
` 24 that when you talk about something
`
`
`00:52:34 1