`
`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.
`____________
`
`IPR2017-018411
`Patent 7,893,501
`____________
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`1 Case IPR2017-01842 has been consolidated with this proceeding(cid:15916)
`
`
`
`Patent Owner Godo Kaisha IP Bridge 1 (“Patent Owner”), by and through
`
`their attorneys, respectfully requests oral argument, currently scheduled for
`
`September 6, 2018. Patent Owner requests a total of 60 minutes to present its
`
`arguments for IPR2017-01841.
`
`The oral argument for IPR2017-01843 is also scheduled for September 6,
`
`2018 and involves the same patent—U.S. Patent No. 7,893,501. In IPR2017-
`
`01843, Patent Owner is also requesting a total of 60 minutes to present its
`
`arguments. If the oral arguments are consolidated for IPR2017-01841 and
`
`IPR2017-01843, Patent Owner still requests a total of 120 minutes to present its
`
`arguments for both proceedings. Patent Owner requests this amount of time for
`
`such a consolidated hearing because the prior art, disputed limitations, and issues
`
`in IPR2017-01841 are different from those in IPR2017-01843.
`
`Pursuant to 37 C.F.R § 42.70(a), and without intending to waive any issue
`
`not specifically identified, Patent Owner identifies the following issues to be
`
`argued:
`
`1. The proper construction of “the MISFET: includes an active region of
`
`the semiconductor substrate;”
`
`2. Failure of Petitioner to meet its burden of proving obviousness of
`
`claims 1, 4-7, 9–12, 14–19, 21, and 23–25 under 35 U.S.C. § 103(a) in
`
`view of Igarashi and Woerlee;
`
`1
`
`
`
`3. Failure of Petitioner to meet its burden of proving obviousness of
`
`claim 13 under 35 U.S.C. § 103(a) in view of Igarashi, Woerlee, and
`
`Hokazono;
`
`4. Exclusion of Petitioner’s improper new arguments in its Reply as
`
`identified in Paper No. 27;
`
`a. Petitioner’s improper new theory that it would have been
`
`obvious to modify Igarashi’s Fifth Embodiment to add isolation
`
`regions in view of Igarashi’s disclosure of isolation regions in
`
`its First Embodiment.
`
`b. Petitioner’s improper new theory that it would have been
`
`obvious to modify Igarashi’s Fifth Embodiment to add isolation
`
`regions in view of Woerlee.
`
`c. Petitioner’s improper new argument that transistors without
`
`isolation region share an active region.
`
`d. Petitioner’s improper new argument that the entire area between
`
`the two STI in Petitioner’s modified Igarashi Figure 12 meets
`
`the claimed active region.
`
`5. Petitioner’s improper new argument that the area between the two STI
`
`in Petitioner’s modified Igarashi Figure 12 includes multiple active
`
`regions.
`
`2
`
`
`
`6. Exclusion of Exhibit 1026, paragraph 18 of Exhibit 1027, and certain
`
`portions of the July 25th deposition transcript of Petitioner’s expert
`
`(Ex. 2026) as set forth in Patent Owner’s Motion to Exclude
`
`Evidence;
`
`7. Any issues specified by Petitioner in its request for Oral Argument;
`
`8. Any motions or issues that remain pending at the time of the hearing;
`
`9. Any other issues the Board deems necessary for issuing a final written
`
`decision.
`
`Dated: August 9, 2018
`
`Respectfully submitted,
`Godo Kaisha IP Bridge 1
`
`By /Joshua J. Miller/
`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
`
`3
`
`
`
`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
`
`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
`
`David.Cavanaugh@wilmerhale.com
`
`Dominic E. Massa
`
`Dominic.Massa@wilmerhale.com
`
`Michael H. Smith
`
`MichaelH.Smith@wilmerhale.com
`
`Date: August 9, 2018
`
`/MacAulay Rush/
`MacAulay Rush
`Patent Paralegal
`WOLF GREENFIELD & SACKS, P.C.
`
`4
`
`
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