UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`AVX Corporation
`Petitioner
`v.
`
`Samsung Electro-Mechanics Co., LTD.
`Patent Owner
`
`Patent No. 9,326,381
`Issue Date: April 26, 2016
`Title: MULTILAYER CERAMIC CAPACITOR AND BOARD
`HAVING THE SAME MOUNTED THEREON
`_______________
`
`Post-Grant Review No. PGR2017-00010
`____________________________________________________________
`
`DECLARATION OF RANDALL LEWIS
`
`1
`
`Exhibit 1015
`PGR2017-00010
`AVX CORPORATION
`
`000001
`
`
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`AVX Corporation
`Petitioner
`v.
`
`Samsung Electro-Mechanics Co., LTD.
`Patent Owner
`
`Patent No. 9,326,381
`Issue Date: April 26, 2016
`Title: MULTILAYER CERAMIC CAPACITOR AND BOARD
`HAVING THE SAME MOUNTED THEREON
`_______________
`
`Post-Grant Review No. PGR2017-00010
`____________________________________________________________
`
`DECLARATION OF RANDALL LEWIS
`
`1
`
`Exhibit 1015
`PGR2017-00010
`AVX CORPORATION
`
`000001
`
`
`
`1.
`
`I, Randall Lewis, resident at 280 Greenwood Road, Afton, Tennessee,
`
`hereby declare as follows:
`
`2.
`
`I am a scanning electron microscopy (SEM) engineer for AVX
`
`Corporation in Fountain Inn, South Carolina. I have held this position since July
`
`of 2005 and have over 38 years of experience in the field of physical analysis of
`
`electronic components including capacitors. My principle job is to evaluate
`
`components being developed by the Advanced Products and Technology group.
`
`As part of my employment at AVX Corporation and in my role as SEM engineer, I
`
`routinely cross-section (or otherwise deconstruct) electrical components such as
`
`multi-layer ceramic capacitors and analyze those electrical components using a
`
`scanning electron microscope and associated hardware and software tools.
`
`3.
`
`In early January of 2017, I was provided with a reel of capacitors by
`
`Mr. John Galvagni, and was asked to assist in analyzing the physical dimensions
`
`and other properties of several samples of the capacitors on each reel. I selected
`
`three sample capacitors from the reel provided by Mr. Galvagni. To prepare the
`
`samples for SEM analysis, as is my typical habit, I cased each of the sample
`
`capacitors on a mount in a two part acrylic epoxy called Castamount, which is
`
`purchased from Pace Industries. The samples were each placed in a same
`
`orientation according to their external electrodes, and the mount was labeled with
`
`2
`
`000002
`
`
`
`the date on which the mount was prepared. Samples of the capacitors provided by
`
`Mr. Galvagni were the only samples mounted on that date. After the Castamount
`
`epoxy cured, the sample capacitors from Mr. Galvagni were sectioned to reveal a
`
`cross-sectional area suitable for visible analysis with a scanning electron
`
`microscope. For the sectioning, as is my typical habit, I used an Allied High Tech
`
`MultiPrep grinder and polisher and carbide sanding paper purchased from Allied
`
`High Tech. This process used to mount and section the sample capacitors from
`
`Mr. Galvagni is the same process I routinely use in my role as SEM engineer for
`
`critical destructive physical analysis requests of electrical components. I have
`
`performed sample preparations such as this approximately 3,000 times in my
`
`career at AVX, and the results of my preparation and subsequent analysis are
`
`regularly relied upon by me and others at AVX during the normal course of
`
`business.
`
`4.
`
`After completion of the mounting and sectioning process, I witnessed
`
`Mr. Galvagni take photographs of the respective cross-sections of each sample
`
`capacitor with a Zeiss Axio Imager Optical Microscope. After these initial
`
`photographs were taken, the sample capacitors were prepared for scanning electron
`
`microscope evaluation of the dielectric grain structure between internal electrode
`
`layers. To prepare the sample capacitors for this analysis, I placed the mount onto
`
`an aluminum stub using conductive carbon adhesive and aluminum adhesive strips.
`
`3
`
`000003
`
`
`
`The mount and the aluminum stub were then placed in a Denton Vacuum Desk-1
`
`chamber and degassed and sputter-coated for 30 seconds with gold-palladium.
`
`This process used to prepare the samples for scanning electron microscope
`
`evaluation is the same process I routinely use in my role as SEM engineer for
`
`preparing samples for such evaluation. I have performed sample preparations such
`
`as this approximately 3,000 times in my career at AVX, and the results of my
`
`preparation and subsequent analysis are regularly relied upon by me and others at
`
`AVX during the normal course of business.
`
`5.
`
`The gold-palladium coated capacitors and mount were then placed in
`
`a Zeiss Sigma field emission scanning electron microscope (SEM) with which I
`
`reviewed each of the samples of the capacitors provided by Mr. Galvagni. The
`
`dielectric layers were the same for each of the three samples of the capacitors
`
`provided by Mr. Galvagni both in numbers of grains per layer and approximate
`
`size of the grains themselves. I took magnified photographs of the dielectric grain
`
`structure for sample 2 of the sample capacitors provided by Mr. Galvagni using a
`
`Carl Zeiss Backscatter Detector at 5,000 times magnification and at 20,000 times
`
`magnification. I selected sample 2 because it offered the clearest photographs
`
`from the three samples of the dielectric grain structure. This sample 2 is the same
`
`sample as the sample 2 capacitor to which Mr. Galvagni refers in his declaration. I
`
`personally provided the following photographs of sample 2 to Mr. Galvagni on a
`
`4
`
`000004
`
`
`
`thumb drive, the first of which is taken at 5,000 times magnification and the
`
`second of which taken at 20,000 times magnification:
`
`
`
`5
`
`000005
`
`
`
`
`
`6.
`
`The measurement software overlaid the 1 μm and 200 nm scales,
`
`respectively, in the bottom, left corners of the above photographs. The SEM and
`
`measurement software are calibrated annually by a service technician from the
`
`manufacturer (i.e., Zeiss) to ensure the continued accuracy of these overlaid
`
`measurement scales.
`
`7.
`
`I hereby declare under penalty of perjury under the laws of the United
`
`States of America that the foregoing is true and correct, and that all statements
`
`made of my own knowledge are true and that all statements made on information
`
`6
`
`000006
`
`
`
`andbelief are believed to be true.
`
`I understandthat willful false statements and the
`
`like are punishablebyfine or imprisonment, or both (18 U.S.C. § 1001).
`
`Executed on January 25, 2017
`
`QAPPL
`
`Randall Lewis
`
`7
`000007
`
`000007
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
