UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`GLOBALFOUNDRIES INC., GLOBALFOUNDRIES U.S. INC.,
`AND GLOBALFOUNDRIES U.S. 2 LLC,
`
`Petitioner
`
`———————
`
`U.S. Patent No. 7,402,903
`
`DECLARATION OF INGRID HSIEH-YEE, PHD, UNDER 37 C.F.R. § 1.68
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` Declaration of Ingrid Hsieh-Yee, Ph.D.
`
`U.S. Patent 7,402,903
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`Table of Contents
`
`
`Introduction ................................................................................................. 1
`I.
`Qualifications and Professional Experience ................................................. 1
`II.
`III. Background of Library Cataloging ............................................................... 3
`A. Machine-Readable Cataloging (“MARC”) ................................................... 3
`B. WorldCat Web Portal ................................................................................... 5
`C. Library Online Catalogs ............................................................................... 6
`D. Cataloging New Works ................................................................................ 7
`IV. Scope of The Work .................................................................................... 10
`A. Evidence Considered in Forming My Opinions ......................................... 12
`V. Authentication and Public Availability of Tuinhout (Ex.1011) ................... 16
`A. Authentication ........................................................................................... 16
`B. IEEE Metadata Record............................................................................... 18
`C. Internet Archive Record ............................................................................. 19
`D. Linda Hall Library Copy ............................................................................ 21
`E. Linda Hall Library Records........................................................................ 23
`F. Usage Record ............................................................................................. 27
`G. Summary of My Opinion on Tuinhout ....................................................... 27
`VI. Authentication and Public Availability of Ren (Ex.1026) ........................... 28
`A. Authentication ........................................................................................... 28
`B. AIP Webpage ............................................................................................. 30
`C. Linda Hall Library Copy ............................................................................ 30
`D. Linda Hall Library Records........................................................................ 32
`E. Copyright Record ....................................................................................... 36
`F. Usage Record ............................................................................................. 37
`G. Summary of My Opinion on Ren ............................................................... 37
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`
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`ii
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` Declaration of Ingrid Hsieh-Yee, Ph.D.
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`U.S. Patent 7,402,903
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`
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`VII. Authentication and Public Availability of The National Technology
`Roadmap for Semiconductors, 1994 Edition (Ex.1045) ....................................... 38
`A. Authentication ........................................................................................... 38
`B. Internet Archive Records ........................................................................... 40
`C. Record of Holding Libraries ...................................................................... 44
`D. Usage Record ............................................................................................. 46
`E. Summary of My Opinion on The National Technology Roadmap for
`Semiconductors, 1994 Edition .......................................................................... 47
`VIII. Conclusion ................................................................................................. 48
`
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`
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`I.
`
`INTRODUCTION
`
` Declaration of Ingrid Hsieh-Yee, Ph.D.
`
`U.S. Patent 7,402,903
`
`I, Ingrid Hsieh-Yee, Ph.D., do hereby declare as follows:
`
`1.
`
`I have been retained as an independent expert witness on behalf of
`
`GlobalFoundries Inc., GlobalFoundries U.S. Inc., and GlobalFoundries U.S. 2 LLC
`
`(collectively “GlobalFoundries” “Petitioner”) for Inter Partes Review (“IPR”)
`
`proceedings before the United States Patent and Trademark Office regarding U.S.
`
`Patent No. 7,402,903.
`
`2.
`
`I am being compensated for my work in this matter at my customary
`
`hourly rate. I am also being reimbursed for any reasonable expenses associated with
`
`my work and testimony in this investigation. My compensation is not contingent on
`
`the results of my study, the substance of my opinions, or the outcome of this matter.
`
`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`
`3. My complete qualifications and professional experience are described
`
`in my academic curriculum vitae (Appendix 1). The following is a brief summary
`
`of my relevant qualifications and professional experience.
`
`4.
`
`I am currently a Professor in the Department of Library and Information
`
`Science at the Catholic University of America. I have experience working in an
`
`academic library, a medical library, and a legislative library and have been a
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`professor for more than 30 years. I hold a Ph.D. in Library and Information Studies
`
`
`
`1
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`
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`from the University of Wisconsin-Madison and a Masters in Library and Information
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` Declaration of Ingrid Hsieh-Yee, Ph.D.
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`U.S. Patent 7,402,903
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`Studies from the University of Wisconsin-Madison.
`
`5.
`
`I am an expert on library cataloging and classification and have
`
`published two editions on this subject, Organizing Audiovisual and Electronic
`
`Resources for Access: A Cataloging Guide (2000 and 2006). I teach a variety of
`
`courses, including Cataloging and Classification, Advanced Cataloging and
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`Classification, Organization of Internet Resources, Organization of Information,
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`Digital Content Creation and Management, Metadata, Internet Searches and Web
`
`Design, Information Literacy Instruction, Advanced Information Retrieval and
`
`Analysis Strategies, and The Information Professions in Society. I am familiar with
`
`metadata schema design and implementation. In my teaching I have covered the
`
`design and implementation of metadata in libraries, databases, search engines,
`
`digital repositories, digital libraries, and digital archives. I have also covered how
`
`information organization affects the discovery and access to digital resources on the
`
`Internet. My research interests cover cataloging and classification, information
`
`organization, metadata, information retrieval, information architecture, digital
`
`collections, scholarly communication, social media, user
`
`interaction with
`
`information systems, and others.
`
`
`
`2
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`III. BACKGROUND OF LIBRARY CATALOGING
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` Declaration of Ingrid Hsieh-Yee, Ph.D.
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`U.S. Patent 7,402,903
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`A. Machine-Readable Cataloging (“MARC”)
`
`6.
`
`The “Machine-Readable Cataloging” standard, also known as
`
`“MARC,” became the national standard for sharing bibliographic data in the United
`
`States by 1971 and the international standard by 1973. MARC is the primary
`
`communications protocol for the transfer and storage of bibliographic metadata in
`
`libraries. Experts in my field reasonably rely upon MARC records when forming
`
`their opinions. In my professional and academic careers I have become very familiar
`
`with the MARC standard.
`
`7.
`
`A MARC record consists of several fields, each of which contains
`
`specific data about a work. Each field is identified by a standardized, unique, three-
`
`digit code corresponding to the type of data that follows. Appendix 2 is a true and
`
`correct copy of Parts VII to X of Understanding MARC Bibliographic: Machine-
`
`Readable Cataloging (http://www.loc.gov/marc/umb/um07to10.html) from the
`
`Library of Congress. Understanding MARC Bibliographic was originally published
`
`by the Follett Software Co. and copyrighted in 1988. Editions in 1989, 1990, 1994,
`
`1998, 2000, 2003 and 2009 include changes. The latest edition was copyrighted in
`
`2009. This document explains commonly-used MARC fields. For example, the
`
`personal author of the work is recorded in Field 100, the title is recorded in Field
`
`
`
`3
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`245, publisher information is recorded in Field 260, the physical volume and
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` Declaration of Ingrid Hsieh-Yee, Ph.D.
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`U.S. Patent 7,402,903
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`characteristics of a publication are recorded in Field 300, and topical subjects are
`
`recorded in the 650 fields.
`
`8.
`
`The Online Computer Library Center (OCLC)
`
`is
`
`the
`
`largest
`
`bibliographic network of the world, with more than 517 million records (as of July
`
`2021) and thousands of member institutions (many of which are libraries of some
`
`type) in more than 100 countries. OCLC was founded in 1967 to promote and
`
`support library cooperation. According to the “Third Article, Amended Articles of
`
`Incorporation of OCLC Online Computer Library Center, Inc.,” OCLC was created
`
`“to establish, maintain and operate a computerized library network and to promote
`
`the evolution of library use, of libraries themselves, and of librarianship, and to
`
`provide processes and products for the benefit of library users and libraries,
`
`including such objectives as increasing availability of library resources to individual
`
`library patrons and reducing the rate of rise of library per-unit costs, all for the
`
`fundamental public purpose of furthering ease of access to and use of the ever-
`
`expanding body of worldwide scientific, literary and educational knowledge and
`
`information” (source: https://www.oclc.org/content/dam/oclc/membership/articles-
`
`of-incorporation.pdf).
`
`9.
`
`OCLC members can contribute original cataloging records in MARC
`
`
`
`4
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`to the system or derive cataloging records from existing records, an activity referred
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` Declaration of Ingrid Hsieh-Yee, Ph.D.
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`U.S. Patent 7,402,903
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`to as “copy cataloging.” When an OCLC participating institution acquires a work, it
`
`can create an original MARC record for the work in OCLC’s Connexion system (a
`
`system for catalogers to create and share MARC records), and the system will
`
`automatically generate a code for the date of record creation in the yymmdd format,
`
`and the creating library’s OCLC symbol is recorded in subfield “a” of the 040 field.
`
`Once the MARC record is in Connexion, it becomes available to other OCLC
`
`members for adoption to their local online catalogs (i.e., copy cataloging).
`
`B. WorldCat Web Portal
`
`10. After a MARC record is created in Connexion, it also becomes
`
`searchable and viewable on WorldCat, which is a free web portal for users to explore
`
`the collections of more than 10,000 libraries worldwide. The record in WorldCat,
`
`however, is not presented in MARC fields. Instead, the data elements are labeled to
`
`help users interpret the record. Thus, the information stored in MARC records in
`
`Connexion is available to the interested public through the user-friendly WorldCat
`
`web portal.
`
`11. WorldCat (http://www.worldcat.org) is “the world’s largest network of
`
`library content and services” and its features are summarized in “What is WorldCat”
`
`(http://www.worldcat.org/whatis/default.jsp). WorldCat began operation in January
`
`1998 as a free web portal to more than 10,000 library collections worldwide.
`
`
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`5
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`Through WorldCat, users can search for information resources in their local libraries
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` Declaration of Ingrid Hsieh-Yee, Ph.D.
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`U.S. Patent 7,402,903
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`and libraries around the world. WorldCat allows users to search for books, CDs,
`
`videos, and many new types of digital content, such as audiobooks, in many
`
`languages. Users can also retrieve research materials and article citations with links
`
`to their full text. After an item is retrieved, WorldCat helps users identify a library
`
`nearby that holds the item or all the libraries that hold the item. WorldCat is an
`
`efficient way to explore the content held by more than 10,000 libraries around the
`
`world. WorldCat is publicly accessible, and there is no fee to perform a search on
`
`WorldCat.
`
`C.
`
`Library Online Catalogs
`
`12. Library online catalogs gained acceptance in the early 1980s and many
`
`libraries migrated their systems to the World Wide Web in the mid-1990s. Library
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`online catalogs are based on MARC records that represent their collections in order
`
`to help the public understand what materials are publicly accessible in those
`
`libraries. Most libraries with online catalogs have made their catalogs freely
`
`available on the Web. These online catalogs offer user-friendly search interfaces.
`
`Strong user interest in keyword searches and the popularity of Google have led to
`
`the “googlization” of library search systems. As a result, many library catalogs now
`
`provide a single search box for users to conduct keyword searches, with additional
`
`support for searches by author, title, subject terms, and other data elements such as
`
`
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`ISBN (International Standard Book Number). Library catalogs these days also offer
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` Declaration of Ingrid Hsieh-Yee, Ph.D.
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`U.S. Patent 7,402,903
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`features for users to narrow their search results by language, year, format, and other
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`elements. Many libraries display MARC records on their online catalogs with labels
`
`for the data elements to help the public interpret MARC records. Many libraries also
`
`offer the option to display MARC records in MARC fields.
`
`13.
`
`I am personally familiar with many online catalogs, databases, and
`
`search engines. In preparing for this Report, I used the following authoritative
`
`information systems to search for records:
`
`• Google Scholar (https://scholar.google.com)
`
`• IEEE Xplore (https://ieeexplore.ieee.org/)
`
`• Online catalog of the Linda Hall Library (https://catalog.lindahall.org/ )
`
`• Public Catalog
`
`of
`
`the United
`
`States Copyright Office
`
`(https://cocatalog.loc.gov)
`
`• WorldCat (free web portal) (https://www.worldcat.org)
`
`• WorldCat on OCLC FirstSearch (subscription required for access)
`
`(https://firstsearch.oclc.org)
`
`D. Cataloging New Works
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`14. Libraries create MARC records for works they acquire, including
`
`books, serials, motion pictures, and publications in other formats. Monograph
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`
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`cataloging is fairly common in libraries, and most libraries make a newly cataloged
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` Declaration of Ingrid Hsieh-Yee, Ph.D.
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`U.S. Patent 7,402,903
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`monograph available to the public soon after the cataloging work is completed,
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`usually within a week. Libraries can create original cataloging records or use an
`
`existing record in OCLC to create a copy cataloging record. As soon as the
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`cataloging record is completed, it is added to the library’s online catalog for users.
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`If the record is an original record, it is also entered into OCLC WorldCat. If it is a
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`copy cataloging record, the library’s holding symbol is attached to the existing
`
`original record in OCLC WorldCat to facilitate searching and interlibrary loan.
`
`15. The cataloging of serials and the serial check-in process are discussed
`
`here to show how libraries usually provide access to newly received serial issues.
`
`According to the glossary of the RDA: Resource Description and Access cataloging
`
`standard, a serial is “a mode of issuance of a manifestation issued in successive parts,
`
`usually bearing numbering, that has no predetermined conclusion. A serial includes
`
`a periodical, monographic series, newspaper, etc.” Because the publisher of a serial
`
`makes new issues of the serial available successively, a customary cataloging
`
`practice is to create one bibliographic record for the serial, and the MARC serial
`
`record typically provides information on the beginning date and frequency of the
`
`serial, not the dates of individual issues. In other words, libraries typically do not
`
`create MARC records for individual issues of a serial. Instead, they rely on a serial
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`check-in system to track the receipt of new issues. A common check-in practice is
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`
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`to date stamp a new issue when it arrives. This practice has become automated since
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` Declaration of Ingrid Hsieh-Yee, Ph.D.
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`U.S. Patent 7,402,903
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`the late 1990s, and libraries now vary in how they share the receipt date of a new
`
`serial issue with the public. Some libraries use a date stamp, some affix a label to
`
`indicate the receipt date, some pencil in the receipt date, and some do not provide
`
`the information to the public.
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`16. The serial check-in process usually takes less than an hour, and one of
`
`the steps involves placing a date stamp on the new issue to document the date the
`
`issue is checked in. After that, the holdings information of the serial is updated in
`
`the library’s catalog so that users know which issues are available for request or
`
`access. After serial check-in is completed, the new issue is placed on the shelf with
`
`the previous issues of the serial. Libraries with a public periodical room typically
`
`place new issues in the periodical room for easy user access. Because information
`
`presented in serials often reflects latest discovery, a general practice of libraries is to
`
`make new issues of serials available for user access soon after they are checked in,
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`usually within a week.
`
`17. There are two ways to catalog conference proceedings. One approach
`
`is to catalog each conference proceedings as a book to make the proceedings easily
`
`discoverable. This means that once a volume of conference proceedings is cataloged
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`as a book, the book is processed quickly to make it available for public access,
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`
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`usually within a week. Another approach is to catalog conference proceedings as a
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` Declaration of Ingrid Hsieh-Yee, Ph.D.
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`U.S. Patent 7,402,903
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`serial when the conference takes place fairly regularly and the title of the conference
`
`remain largely the same. In such a case, a serial record is created, and no individual
`
`record is created for each conference proceedings, but the proceedings received are
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`noted in the holdings record to let the public know which year’s proceedings are
`
`available. The physical copy of the proceedings is checked in through the serial
`
`check-in process, and made available for public access soon after the serial check-in
`
`is completed, usually on the same day or within a week.
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`IV. SCOPE OF THE WORK
`
`18.
`
`I have been asked to offer an opinion on the authenticity and public
`
`availability date of the following documents:
`
`• Tuinhout, H. P., & Peters, W. C. M., (1998, March), Measurement of
`
`lithographical proximity effects on matching of bipolar transistors, ICMTS
`
`1998, Proceedings of 1998 International Conference on Microelectronic
`
`Test Structures (Cat. No. 98CH36157), pp. 7-12. Ex.1011 (“Tuinhout”);
`
`• Ren, F., Pearton, S. J., Hobson, W. S., Fullowan, T. R., Lothian, J., &
`
`Yanof, A. W., (1990, February), Implant isolation of GaAs-AlGaAs
`
`heterojunction bipolar transistor structures, Applied Physics Letters, vol. 56,
`
`no. 9, pp. 860-862. Ex.1026 (“Ren”); and
`
`
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`10
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`U.S. Patent 7,402,903
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`• Semiconductor Industry Association, (1994), The National Technology
`
`Roadmap for Semiconductors, 1994 Edition, Ex.1045 (“the 1994 NTRS”).
`
`19.
`
`I am rendering my expert opinion on the authenticity of the documents
`
`referenced herein and on whether they were published. I also provide my opinion on
`
`when and how these documents were publicly disseminated or otherwise made
`
`publicly available to the extent that persons interested and ordinarily skilled in the
`
`subject matter or art, exercising reasonable diligence, could have located and
`
`retrieved these documents.
`
`20.
`
`I have been informed by counsel that an item is considered authentic if
`
`there is sufficient evidence to support a finding that the item is what it is claimed to
`
`be. I have also been informed that authenticity can be established based on the
`
`contents of the documents themselves, such as the appearance, content, substance,
`
`internal patterns, protocols followed, or other distinctive characteristics of the item.
`
`21.
`
`I have been further informed by counsel that a given document is
`
`deemed “published” upon a satisfactory showing that such a document has been
`
`disseminated or otherwise made publicly available such that persons interested and
`
`ordinarily skilled in the subject matter or art could locate and obtain the document
`
`after exercising reasonable diligence. I have also been informed by counsel that
`
`materials available in a library constitute “printed publications” if they are cataloged
`
`
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`11
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`and indexed according to general library practices and protocols that make the
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` Declaration of Ingrid Hsieh-Yee, Ph.D.
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`U.S. Patent 7,402,903
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`references available and accessible to members of the interested public.
`
`22.
`
`I have been informed by counsel that U.S. Patent 7,402,903 has an
`
`earliest claimed priority date of January 22, 2003. I have assessed public
`
`availability of the documents referenced below as of this priority date.
`
`A. Evidence Considered in Forming My Opinions
`
`23.
`
`In the preparation of this declaration, I have reviewed the documents
`
`referenced below and any other documents I reference herein. Each of these is a type
`
`of material that experts in my field would reasonably rely upon when forming their
`
`opinions:
`
`(1) The documents referenced above in Paragraph 18;
`
`(2) Metadata record of Tuinhout, available at IEEE Xplore at
`
`https://ieeexplore.ieee.org/abstract/document/688025, accessed and
`
`obtained on May 12, 2022, Appendix 1011A;
`
`(3) Webpage for ICMTS 98 Tutorial and Technical Program archived
`
`on October 7, 2000 by the Internet Archive, available at
`
`https://web.archive.org/web/20001007195343/http://www.ee.ed.ac.
`
`uk/~ajw/ICMTS/prog98.html#Conference%20Proceedings
`
`from
`
`Internet Archive, accessed and obtained on May 20, 2022,
`
`Appendix 1011B;
`
`
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`12
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` Declaration of Ingrid Hsieh-Yee, Ph.D.
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`U.S. Patent 7,402,903
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`(4) Library copy of Tuinhout, obtained from Linda Hall Library on May
`
`6, 2022, Appendix 1011C;
`
`(5) Bibliographic and MARC records for ICMTS 1998: proceedings of
`
`the 1998 IEEE International Conference on Microelectronic Test
`
`Structures that contains Tuinhout, available from the online catalog
`
`of
`
`the
`
`Linda
`
`Hall
`
`Library
`
`at
`
`https://catalog.lindahall.org/permalink/01LINDAHALL_INST/19l
`
`da7s/alma992975863405961, accessed and obtained on May 6,
`
`2022, Appendix 1011D;
`
`(6)
`
`Selected citations to Tuinhout, obtained from Google Scholar,
`
`Appendix 1011E;
`
`(7) Webpage
`
`for Ren,
`
`available
`
`from
`
`the
`
`publisher
`
`at
`
`https://aip.scitation.org/doi/abs/10.1063/1.102683, accessed and
`
`obtained on May 13, 2022, Appendix 1026A;
`
`(8) Library copy of Ren, obtained from Linda Hall Library on May 13,
`
`2022, Appendix 1026B;
`
`(9) Bibliographic and MARC records for Applied Physics Letters that
`
`contains Ren, available from the online catalog of the Linda Hall
`
`Library
`
`at
`
`https://lindahall.primo.exlibrisgroup.com/permalink/01LINDAHA
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`13
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` Declaration of Ingrid Hsieh-Yee, Ph.D.
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`U.S. Patent 7,402,903
`
`LL_INST/19lda7s/alma992785733405961, accessed and obtained
`
`on May 13, 2022, Appendix 1026C;
`
`(10) Copyright registration record for vol. 56, no. 9 of Applied Physics
`
`Letters that contains Ren, available at https://cocatalog.loc.gov/cgi-
`
`bin/Pwebrecon.cgi?v1=37&ti=26,37&Search%5FArg=Applied%2
`
`0Physics%20Letters&Search%5FCode=TALL&CNT=25&PID=
`
`W3jD5IbDBQX31mKVJpH5cyyE&SEQ=20220513151737&SID
`
`=1, accessed and obtained on May 13, 2022, Appendix 1026D;
`
`(11) Selected early citations to Ren, obtained from Google Scholar,
`
`Appendix 1026E;
`
`(12) Webpage
`
`for The National Technology Roadmap
`
`for
`
`Semiconductors, 1994 Edition, Electronic Versions, archived by
`
`Internet Archive on March 27, 1997, available from Internet
`
`Archive
`
`at
`
`https://web.archive.org/web/19970327233124/http://www.sematec
`
`h.org/public/roadmap/94e_rdmp.htm, accessed and obtained on
`
`May 23, 2022, Appendix 1045A;
`
`(13) Full text of The National Technology Roadmap for Semiconductors,
`
`1994 Edition, Electronic Versions, archived by Internet Archive on
`
`March 28, 1997,
`
`available
`
`from
`
`Internet Archive
`
`at
`
`14
`
`Ex. 1006
`GLOBALFOUNDRIES, INC. / Page 17 of 413
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`

`

`
`
`
`
`
`
` Declaration of Ingrid Hsieh-Yee, Ph.D.
`
`U.S. Patent 7,402,903
`
`https://web.archive.org/web/19970328002512/http://www.sematec
`
`h.org/public/roadmap/ntrs94.pdf, accessed and obtained on May 23,
`
`2022, Appendix 1045B;
`
`(14) Library record for The National Technology Roadmap
`
`for
`
`Semiconductors, 1994 Edition, available from WorldCat on OCLC
`
`FirstSearch (subscription required for access), accessed and
`
`obtained on May 22, 2022, Appendix 1045C;
`
`(15) Early citations
`
`to The National Technology Roadmap
`
`for
`
`Semiconductors, 1994 Edition, obtained from Google Scholar,
`
`Appendix 1045D;
`
`(16) Spencer, W. J., & Seidel, T. E., (1995, October), National
`
`technology
`
`roadmaps:
`
`the US
`
`semiconductor experience,
`
`Proceedings of 4th International Conference on Solid-State and IC
`
`Technology (pp. 211-220), Ex.1047; and
`
`(17) Harrell, S., Seidel, T., & Fay, B., (1996), The National Technology
`
`Roadmap for Semiconductors and SEMATECH future directions,
`
`Microelectronic Engineering, 30(1-4), 11-15, Ex.1048.
`
`15
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`Ex. 1006
`GLOBALFOUNDRIES, INC. / Page 18 of 413
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`
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`V. AUTHENTICATION AND PUBLIC AVAILABILITY OF TUINHOUT
`(EX.1011)
`
` Declaration of Ingrid Hsieh-Yee, Ph.D.
`
`U.S. Patent 7,402,903
`
`A. Authentication
`
`24. Ex.1011 is a true and correct copy of Measurement of lithographical
`
`proximity effects on matching of bipolar transistors, (“Tuinhout”), by Tuinhout et
`
`al.,
`
`in ICMTS 1998, Proceedings of 1998
`
`International Conference on
`
`Microelectronic Test Structures, pp. 7-12, that I obtained from the IEEE Xplore
`
`Digital Library (commonly referred to as IEEE Xplore) created and maintained by
`
`the Institute of Electrical and Electronics Engineers. When I began preparing this
`
`declaration I searched WorldCat by the title of Tuinhout for records, and retrieved a
`
`record (http://www.worldcat.org/oclc/5872312443) for Tuinhout. The “Find a copy
`
`online” area of the record showed a “View full text” link that led me to a metadata
`
`record for Tuinhout in IEEE Xplore. I then used the PDF link in the metadata record
`
`to purchase Tuinhout. This IEEE copy is presented as Ex.1011 in this declaration.
`
`25. Ex.1011 at page 1 (internal page 7) shows the title, authors, and
`
`abstract, and the top of this page shows Tuinhout appears in “Proc. IEEE 1998 Int.
`
`Conference on Microelectronic Test Structures, Vol. 11, March 1998.” The bottom
`
`of this page shows a “1998” copyright date with IEEE as the copyright holder. It
`
`also shows Tuinhout appears in a publication whose ISBN (International Standard
`
`Book Number) is “0-7803-4348-4” and the publication’s IEEE Catalog Number is
`
`
`
`16
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`Ex. 1006
`GLOBALFOUNDRIES, INC. / Page 19 of 413
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`
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`“98CH36157.” Ex.1011 shows that Tuinhout has a total of six pages, including six
`
` Declaration of Ingrid Hsieh-Yee, Ph.D.
`
`U.S. Patent 7,402,903
`
`sections, eight figures and 10 references.
`
`26. To show that Tuinhout is part of ICMTS 1998, I obtained front matter
`
`of the conference proceedings from the IEEE webpage for this conference at
`
`https://ieeexplore.ieee.org/xpl/conhome/5634/proceeding and attached the front
`
`matter (https://ieeexplore.ieee.org/stamp/stamp.jsp?tp=&arnumber=688017) to the
`
`end of the Tuinhout article in Ex.1011. Page 7 is the proceedings cover that shows
`
`“ICMTS 1998, Proceedings of
`
`the 1998
`
`International Conference on
`
`Microelectronic Test Structures, March 23-26, 1998, Kanazawa, Japan,” and
`
`indicates the conference was sponsored by the IEEE Electron Devices Society. The
`
`cover also shows two identifiers of this publication as “98CH36157” and “97-
`
`80476” that have the appearance of an IEEE catalog number and a Library of
`
`Congress number.
`
`27.
`
` Page 8 of Ex.1011 is the copyright page that shows the web address of
`
`ICMTS is http://www.ee.ed.ac.uk/ICMTS/ and the copyright date of this publication
`
`is “1998” with the Institute of Electrical and Electronics Engineers, Inc. as the
`
`copyright holder. This page shows IEEE of Piscataway, NJ is the publisher. In
`
`addition, the copyright page shows the IEEE Catalog Number for this work is
`
`“98CH36157,” the ISBNs for this work are “0-7803-4348-4” (for softbound), “0-
`
`
`
`17
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`Ex. 1006
`GLOBALFOUNDRIES, INC. / Page 20 of 413
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`

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`
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`7803-4349-2” (for casebound), and “0-7803-4350-6” (for microfiche), and the
`
` Declaration of Ingrid Hsieh-Yee, Ph.D.
`
`U.S. Patent 7,402,903
`
`Library of Congress number for this work is “97-80476.” Pages 9 to 12 (internal
`
`pages ii to v) of Ex.1011 are the table of contents that shows the conference has 11
`
`sessions, and Tuinhout is the first paper in “Session II Matching” and runs from
`
`pages 7 to 12.
`
`28. The IEEE copy of Tuinhout (Ex.1011) is in a condition that creates no
`
`suspicion about its authenticity. Specifically, this copy is not missing any
`
`intermediate pages, the text on each page appears to flow seamlessly from one page
`
`to the next, and there are no visible alterations to the document. Moreover, Ex.1011
`
`was found in the custody of a digital library owned and managed by the publisher, a
`
`place where, if authentic, it would likely be found. Accordingly, I see no reason to
`
`question the authenticity of the IEEE copy of Tuinhout (Ex.1011).
`
`B.
`
`IEEE Metadata Record
`
`29. Appendix 1011A is a true and correct copy of the metadata record for
`
`Tuinhout that I obtained from IEEE Xplore. I personally located, identified, and
`
`obtained this record. This is the type of record experts in my field would reasonably
`
`rely upon when forming their opinions.
`
`30. Page 1 of the IEEE metadata record (Appendix 1011A) shows the title
`
`and authors of Tuinhout. It also shows IEEE as the publisher, and indicates that
`
`
`
`18
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`Ex. 1006
`GLOBALFOUNDRIES, INC. / Page 21 of 413
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`
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`Tuinhout has 20 paper citations, and its full text has 170 views. Page 2 shows an
`
` Declaration of Ingrid Hsieh-Yee, Ph.D.
`
`U.S. Patent 7,402,903
`
`abstract that is identical to the abstract in Ex.1011, and indicates Tuinhout was
`
`published in “ICMTS 1998. Proceedings of the 1998 International Conference on
`
`Microelectronic Test Structures (Cat. No.98CH36157)” and the ISBN of the
`
`publication is “0-7803-4348-4.” Page 2 also shows the DOI (digital object identifier)
`
`of Tuinhout is “10.1109/ICMTS.1998.688025” and indicates Tuinhout is part of the
`
`conference that took place in Kanazawa, Japan, from 23-26 March 1998. The “Date
`
`Added to IEEE Xplore” field shows the metadata record for Tuinhout was added to
`
`the system on “06 August 2002.”
`
`31. The IEEE metadata record for Tuinhout (Appendix 1011A) and the
`
`front matter of the conference proceedings (pages 7 to 12 of Ex.1011) inform my
`
`opinion that Tuinhout was published in 1998, and the metadata record for this article
`
`was added to IEEE Xplore on August 6, 2002, meaning Tuinhout became
`
`discoverable in IEEE Xplore from August 6, 2002 on. As of that date, members of
`
`the interested public would have been able to locate the IEEE metadata record for
`
`Tuinhout and purchase the article from IEEE or obtain it from an institution that
`
`subscribed to IEEE Xplore.
`
`C.
`
`Internet Archive Record
`
`32. Appendix 1011B is a true and correct copy of “ICMTS 98 Tutorial and
`
`Technical Program” that was first archived by the Internet Ar