throbber
DOCKET NO.: 2003195-00123US1 and US2
`Filed By: David L. Cavanaugh, Reg. No. 36,476
`Dominic E. Massa, Reg. No. 44,905
`Michael H. Smith, Reg. No. 71,190
`1875 Pennsylvania Ave. NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: David.Cavanaugh@wilmerhale.com
`Dominic.Massa@wilmerhale.com
`MichaelH.Smith@wilmerhale.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY LTD.
`Petitioner
`
`v.
`
`GODO KAISHA IP BRIDGE 1
`Patent Owner.
`
`Case IPR2017-018411
`
`PETITIONER’S RESPONSE TO PATENT OWNER’S OBSERVATIONS
`ON CROSS-EXAMINATION
`
`
`
`
` 1
`
` Case IPR2017-01842 has been consolidated with this proceeding.
`
`

`

`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
`
`
`Petitioner submits this response to Patent Owner’s Observations on Cross
`
`Examination. Patent Owner (“PO”) presents seventeen observations on Dr.
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`Shanfield’s testimony. While Petitioner believes that the testimony will be
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`appropriately viewed and weighed by the Board, the specific observations
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`presented by Patent Owner misstate or omit the full testimony of Dr. Shanfield,
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`and are often irrelevant, as specified below.
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`Response to Observation #1
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`
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`PO contends Ex. 2026 at 88:10-89:7, 92:9-14, and 95:4-96:18 shows that the
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`parties have the same construction for the claim term “an active region made of a
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`semiconductor substrate.” PO’s observation ignores Dr. Shanfield emphasis that
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`he disagrees with PO’s interpretation because the term does not require a one-to-
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`one correspondence between an active region and a transistor. Ex. 2026, 94:15-
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`95:3 (“I don't agree with the patent owner's interpretation of that phrase… I don't
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`agree with the patent owner's interpretation, which, as I explain in the following
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`sentences, limits the active region to a single transistor, for example.”). By
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`contrast, after reviewing Dr. Shanfield’s Reply Declaration, Dr. Glew testified he
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`had no opinion on this claim term. Ex. 1029, 46:1-47:6 (“Q. Sitting here today,
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`you don't have an opinion on whether the phrase ‘an active region made of a
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`semiconductor substrate[’] requires a one-to-one correspondence with a MISFET,[]
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`correct? A. I haven't been asked to analyze that with respect to that question. So I
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`1
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`

`

`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
`
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`haven't formed an opinion on that.”). Dr. Shanfield’s undisputed testimony is that
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`the active region does not require a one-to-one correspondence. Ex. 1027, ¶¶7-20;
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`Ex. 1002, ¶¶66-67; see also DI, 8-9.
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`Response to Observation #2
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`PO contends Ex. 2026 at 84:18-86:12 and 95:4-96:18 shows that Dr. Glew’s
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`statement that semiconductor devices have been made without isolation regions is
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`not misleading. As noted for Observation #1, PO ignores Dr. Shanfield emphasis
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`that he disagrees with PO’s interpretation of the term “an active region made of a
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`semiconductor substrate.” Id., 94:15-95:3. Dr. Shanfield also confirmed that “you
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`can have an active region without an isolation region,” id., 84:18-85:1, and
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`explained that whether a transistor can theoretically exist without isolation is “not
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`particularly relevant to the ’501 patent because in 2003, all transistors -- virtually
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`all transistors included isolation regions.” Id., 87:12-87:18. Dr. Glew agrees that
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`using spacing rather than isolation “would not be a typical solution.” Ex. 1024,
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`111:18-25. Moreover, as noted for Observation #1, Dr. Glew has testified he has
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`no opinion on this claim term, and thus Dr. Shanfield’s testimony is undisputed.
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`Ex. 1029, 46:1-47:6; Ex. 1027, ¶¶7-20; Ex. 1002, ¶¶66-67.
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`Response to Observation #3
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`
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`PO contends Ex. 2026 at 84:18-86:12 and 95:4-96:18 supports unspecified
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`testimony from Dr. Glew that transistors without isolation do not have an active
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`2
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`

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`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
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`region. To the contrary, Dr. Shanfield’s testimony confirms that all functional
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`transistors include an active region and that virtually all transistors at the time of
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`the alleged invention used isolation. Id., 84:18-85:1, 87:12-87:18; Ex. 1027, ¶16;
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`Ex. 1002, ¶37-44. Dr. Shanfield’s testimony also confirms Dr. Glew has not
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`identified a single reference that describes a transistor as not having an active
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`region or that says a lack isolation means there is no active region. Ex. 1027, ¶¶16-
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`19; see also Sur-sur-reply, 3. Moreover, Dr. Glew has testified he had no opinion
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`on this claim term. Ex. 1029, 46:1-47:6. Dr. Shanfield’s consistent testimony
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`confirms both that a POSITA would have understood the transistors in Igarashi’s
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`Fig. 12 embodiment include an active region because Igarashi expressly discloses
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`performing “isolation” to form an “active element region,” and that this limitation
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`would have been obvious, because virtually all transistors at the time of the ’501
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`patent included these features. Ex. 1027, ¶¶7-20; Ex. 1002, ¶¶61-81.
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`Response to Observation #4
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`
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`PO contends that Ex. 2026 at 84:18-86:12 and 95:4-96:18 allegedly
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`establishes that the absence of an isolation region signifies the absence of an active
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`region. Patent Owner is incorrect. Dr. Shanfield confirms that all functional
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`transistors, even rare examples without isolation, still include active regions. Id.,
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`84:18-85:1, Ex. 1027, ¶16. Dr. Shanfield adds that isolation regions are typically
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`used to define an active region, but it is not a requirement. Ex. 2026, 88:2-9 (“Q.
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`3
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`

`

`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
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`So in your opinion, isolation regions are not required to define an active region in a
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`transistor; is that right? A. It is not required. It’s not a requirement. But as far as
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`what’s relevant, it’s useful to understand how a transistor is really built, or groups
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`or transistors are really build, and not some very exceptional situation.”). PO’s
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`observation is also irrelevant because virtually all transistors at time of invention
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`used isolation. Id., 87:12-87:18. Dr. Glew agrees using spacing rather than
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`isolation “would not be a typical solution.” Ex. 1024, 111:18-25. Moreover, Dr.
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`Glew has testified he had no opinion on the meaning of this claim term. Ex. 1029,
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`46:1-47:6. Thus, Dr. Shanfield’s testimony is undisputed.
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`Response to Observation #5
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`
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`PO contends Ex. 2026 at 97:10-99:15 and 105:14-106:18 shows that Dr.
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`Shanfield admitted that the formation region Rn of the transistor does not include
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`the isolation region and argues this is contrary to the patent. This observation
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`mischaracterizes Dr. Shanfield’s plain testimony in the cited section. Id., 98:12-24
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`(“Q. So the formation region is a part of the substrate in which the transistor is
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`formed; is that accurate? A. It looks like they're including some of the isolation
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`region in region Rn. That's not where the transistor is being formed. Q. So the
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`formation region includes portions of the -- at least portions of the isolation region?
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`A. It's hard to tell. This is a schematic diagram, so I don't know whether -- how
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`literally to take exactly where that bracket extends. Q. But as it's shown in Figure
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`4
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`

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`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
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`1, it does show that the isolation regions are included within what the '501 patent
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`calls the formation region, correct? A. My sense is, because of the name, that
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`they're talking about where the transistor is formed and not the isolation region
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`even though – because if you look to the right side of bracket Rn, it doesn't seem
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`to line up with the isolation region.”).2 This observation also ignores other
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`discussion of the use of the term “formation region” in the ’501 patent. E.g., id.,
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`101:20-23; 102:4-11; and 106:3-6. Moreover, this observation is irrelevant to the
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`arguments made in this proceeding, and even Dr. Glew admits he offers no
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`analysis of a “formation region.” Ex. 1029, 67:4-69:17.
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`Response to Observation #6
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`PO contends that in Ex. 2026 at 97:10-99:15 Dr. Shanfield “admitted that
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`the formation region Rn of the transistor [] is shown in the ’501 patent as including
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`the isolation region 2.” This observation mischaracterizes Dr. Shanfield’s plain
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`testimony at 98:20-24 (“My sense is, because of the name, that they're talking
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`about where the transistor is formed and not the isolation region even though –
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`because if you look to the right side of bracket Rn, it doesn't seem to line up with
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`the isolation region.”). Moreover, this observation is irrelevant to the arguments
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`
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` 2
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` All emphasis is added unless noted otherwise
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`5
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`

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`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
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`made in this proceeding, and even Dr. Glew admits he offers no analysis of a
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`“formation region.” Ex. 1029, 67:4-69:17. Contrary to PO’s assertion in this
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`observation that each transistor be isolated from other transistors, Dr. Shanfield’s
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`undisputed testimony is that the active region does not require a one-to-one
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`correspondence. Ex. 1027, ¶¶7-20; Ex. 1002, ¶¶66-67; DI, 8-9.
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`Response to Observation #7
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`
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`PO cites to Ex. 2026 at 112:1-113:21 regarding Dr. Shanfield’s testimony as
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`to the number of active regions in Igarashi’s Fig. 12. This observation
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`mischaracterizes Dr. Shanfield’s testimony and omits Dr. Shanfield’s explanation
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`of the context surrounding his testimony (e.g., Ex. 2026, 114:7-24 (explaining he
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`was “basically harassed”)), as well as Dr. Shanfield’s testimony confirming that he
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`immediately clarified himself in his first deposition, and has been consistent since.
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`Id., 147:10-148:3, 165:16-166:16; Ex. 2009, 93:16-20; Ex. 2010, 410:1-437:22,
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`438:11-19. This observation is also irrelevant because the claims simply recite a
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`transistor that includes an active region and do not preclude there being other
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`transistors or active regions. Ex. 1027, ¶¶7-20, 29-31.
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`Response to Observation #8
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`
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`PO cites to Ex. 2026 at 112:4-11 and 116:22-118:22 regarding Dr.
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`Shanfield’s testimony as to the number of active regions in Igarashi’s Fig. 12.
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`Like Observation #7, this observation mischaracterizes Dr. Shanfield’s testimony
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`6
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`

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`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
`
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`and excludes both Dr. Shanfield’s explanation of the context surrounding his
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`testimony (e.g., Ex. 2026, 114:7-24) and Dr. Shanfield’s testimony confirming that
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`he immediately clarified himself in his first deposition, and has been consistent
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`since. Id., 147:10-148:3, 165:16-166:16; Ex. 2009, 93:16-20; Ex. 2010, 410:1-
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`437:22, 438:11-19. This observation is also irrelevant because the claims simply
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`recite a transistor that includes an active region and do not preclude there being
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`other transistors or active regions. Ex. 1027, ¶¶7-20, 29-31.
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`Response to Observation #9
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`
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`PO cites to Ex. 2026 at 112:4-11, 117:23-118:8, and 147:13-148:3 regarding
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`Dr. Shanfield’s testimony as to the number of active regions in Igarashi’s Fig. 12.
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`Like Observation #7, this observation excludes both Dr. Shanfield’s explanation of
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`the context surrounding his testimony (see Ex. 2026, 114:7-24) and Dr. Shanfield’s
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`testimony confirming that he immediately clarified himself in his first deposition,
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`and has been consistent since. Id., 147:10-149:4; 149:5-150:18, 165:16-166:16;
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`Ex. 2009, 93:16-20; Ex. 2010, 410:1-437:22, 438:11-19. This observation also
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`omits PO’s counsel’s misleading questioning. After questioning Dr. Shanfield
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`about page 93 of the transcript of the initial deposition, PO’s counsel told Dr.
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`Shanfield to “go a couple pages forward” to see if he could find where he clarified
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`his testimony, when in fact Dr. Shanfield had corrected himself on that same page.
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`Ex. 2026, 113:13-114:6; 147:10-149:4; Ex. 2009, 93:16-20. PO’s counsel also
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`7
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`

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`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
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`insisted Dr. Shanfield locate the correction in a transcript covering two full days of
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`deposition without providing him an adequate opportunity to do so. Ex. 2026,
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`117:23-122:5 (“… Q. But in the time that's just passed, you haven't found it? A. In
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`the two minutes, yeah…). On re-direct, when given the opportunity to do so, Dr.
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`Shanfield confirmed where he had clarified his testimony during the initial
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`deposition. Id., 147:10-148:3, 165:16-166:16; Ex. 2009, 93:16-20; Ex. 2010,
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`401:17-402:5.
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`Response to Observation #10
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`
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`PO cites to Ex. 2026 at 123:7-15 contending it allegedly “confirms Patent
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`Owner’s position that the Petition and [Dr.] Shanfield’s original declaration filed
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`with it failed to demonstrate where an ‘active region’ as claimed is found in
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`modified Igarashi Fig. 12.” To the contrary, the cited testimony confirms that the
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`claims simply recite a transistor that includes an active region and do not preclude
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`there being other transistors or active regions. Ex. 2026, 123:7-15; Ex. 1027, ¶¶7-
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`20, 29-31. This observation is also misleading because both experts have testified
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`that the figures in the ’501 patent and Igarashi are shown schematically (Ex. 2026,
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`67:12-17 (“Figure 1 is shown schematically…”), 98:12-16 (“… This is a schematic
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`diagram, so I don't know whether -- how literally to take exactly where that bracket
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`extends.”); Ex. 1024, 109:13-16 (“Paragraph 117 describes ‘Figure 12 is a
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`schematic sectional view showing a semiconductor device according to the fifth
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`8
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`

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`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
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`embodiment of the present invention.’”)) and identification of precise boundaries is
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`not required by claim 1. As demonstrated in the Petition and throughout this
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`proceeding, Dr. Shanfield’s consistent testimony confirms both that a POSITA
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`would have understood the transistors in Igarashi’s Fig. 12 embodiment include an
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`active region because Igarashi expressly discloses performing “isolation” to form
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`an “active element region,” and that this limitation would have been obvious,
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`because virtually all transistors at the time of the ’501 patent included these
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`features. Ex. 1027, ¶¶7-20; Ex. 1002, ¶¶61-81.
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`Response to Observation #11
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`PO contends Ex. 2026 at 123:18-124:18 “shows that [Dr.] Shanfield cannot
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`determine whether there is only one, or more than one, active region in Petitioner’s
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`modified Igarashi Figure 12.” This observation mischaracterizes Dr. Shanfield’s
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`testimony. Dr. Shanfield’s initial declaration included an annotated version of Fig.
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`12 from Igarashi, which identified the active region and included ellipsis indicating
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`the wafer could include additional structures not shown. Ex. 1002, ¶66. Dr.
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`Shanfield was asked unclear questions that did not specify if he was being asked
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`about the identified active region, or whether he was being asked about other
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`potential isolation regions and active regions represented by the ellipsis. Ex. 2026,
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`123:23-124:8 (“A. And the reason I said that was because there could be STI not
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`shown. And those would form active regions that weren’t pictured. And that is
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`9
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`

`

`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
`
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`what I was referring to when I said I couldn’t answer it because it’s not pictured. I
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`said, ‘I haven’t indicated in this drawing what else there is, beyond what Igarashi
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`has drawn.’”). By contrast, when PO’s counsel gave Dr. Shanfield an opportunity
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`to explain his answer and posed its questions more clearly, Dr. Shanfield had no
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`difficulty explaining that he had identified an active region formed between the
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`STI in Fig. 12. Ex. 107:17-108:24; see also Ex. 1027, ¶29, Ex. 1002, ¶66.
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`Response to Observation #12
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`
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`PO cites to Ex. 2026 at 125:13-126:11 and, just as in Observation #11, this
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`observation mischaracterizes Dr. Shanfield’s testimony. As explained above for
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`Observation #11, Dr. Shanfield was not unable to say how many active regions
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`were present. Rather, his testimony makes clear he identified the active region in
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`Fig. 12 and included ellipsis to indicate there could be others. Ex. 2026, 107:17-
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`108:24, 125:13-126:11; Ex. 1027, ¶29, Ex. 1002, ¶66. This observation is also
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`irrelevant. Dr. Shanfield confirmed that Igarashi discloses the claimed “active
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`region” regardless of what assumptions are made about the ellipses in annotated
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`Fig. 12, Ex. 2026, 150:14-18.
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`Response to Observation #13
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`PO contends Ex. 2026 at 126:21-127:18 “demonstrates that at the reply stage
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`[Dr.] Shanfield readily addressed an issue he did not address in his original
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`declaration.” This observation is incorrect and mischaracterizes Dr. Shanfield’s
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`10
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`

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`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
`
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`testimony. As Dr. Shanfield explains in his Reply Declaration (Ex. 1027, ¶¶34-
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`36), during the initial deposition, he was asked and attempted to answer a long
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`series of questions that were posed in a manner that did not make technical sense,
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`despite Dr. Shanfield’s efforts to seek clarification. As discussed above for
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`Observation #11, during cross-examination on his Reply Declaration, Dr.
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`Shanfield went out of his way to explain how the questioning had been unclear and
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`to help Patent Owner’s counsel ask the questions more clearly. Ex. 2026, 107:17-
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`108:24, 123:23-124:8. Having helped PO’s counsel clarify its questions and
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`address some of the ambiguity in its previously questions, Dr. Shanfield could
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`readily answer PO counsel’s questions when more clearly presented. Id.
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`Response to Observation #14
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`PO contends Ex. 2026 at 56:17-58:2 and 160:20-23 contradicts Dr.
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`Shanfield’s testimony that Igarashi’s etch stop silicon nitride layer 8 meets the film
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`in claim 1. This observation ignores Dr. Shanfield’s repeated, unambiguous
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`testimony on cross that the claims do not require stress: “Q. Does that language
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`require that the silicon nitride film apply stress? A. No. The claim language
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`doesn’t require stress.” Ex. 2026, 51:22-52:2; id., 30:4-6 (“A. … But there is no
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`requirement in the limitations of the first claim that it has to be a stress film.”); id.
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`52:21-53:6 (“Q. So it’s your opinion that in order for a silicon nitride film to meet
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`the limitations of Claim 1, I must induce stress? A. No. Q. So the silicon nitride
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`11
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`

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`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
`
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`film that’s called out in Claim 1 isn’t required to apply stress to meet the
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`limitations of the claim? A. That’s correct, yes.”); see also Ex. 1002, ¶46 n. 3.
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`PO’s observation mischaracterizes Dr. Shanfield’s testimony at 56:17-58:2. The
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`surrounding testimony makes clear Dr. Shanfield is discussing an exemplary
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`embodiment, not what is required by the claims. Ex. 2026, 56:4-16 (“Q. So in the
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`context of the '501 patent, can a silicon nitride film, which is called out in the last
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`limitation of Claim 1, be made out of multiple layers if those layers deliver only
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`negligible stress? A. There's nothing in the claim language that prohibits it. The
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`context of the '501 patent though is referring to silicon nitride that will create a
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`stress field in the substrate as a whole. So in the literal sense, the claim language
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`doesn't prohibit the theoretical zero stress film. But what's being referred to is a
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`stress-inducing film.”). Dr. Shanfield confirmed on re-direct that this testimony
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`was “referring to the embodiment in the specification,” not what is required by the
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`claims. Ex. 2026, 144:14-145:6. PO’s citation to Dr. Shanfield’s testimony on re-
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`cross at 160:20-23 is also misleading. PO omits Dr. Shanfield’s immediately
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`preceding testimony, which makes clear his testimony at 160:20-23 was based on
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`confusion after a long day of deposition about the legal requirements for how
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`dependent claims relate to independent claims (in this case dependent claims that
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`are not challenged in this proceeding). Ex. 2026, 159:5-160:19. PO also omits Dr.
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`Shanfield’s confirmation of this misunderstanding of the law, and confirmation
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`12
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`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
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`that as a technical matter, claim 1 does not require stress. Ex. 2026, 167:14-18
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`(“Q. I'm going to represent to you that as a legal matter, a dependent claim recites
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`additional limitations that are not present in the independent claim from which it
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`depends. Do you have that understanding in mind?”), and 170:11-172:14 (“… Yes.
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`I do want to clarify. Now that I understand the legal issue, Claim 1 does not require
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`that -- it does not have any language in it that requires the film to have stress, as I
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`said before. And what that means legally is that it's not required in meeting the
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`limitations of Claim 1.”); see also id., 174:12-23, 175:2-15, 176:4-24, 177:11-19
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`(repeatedly confirming on second re-cross that the challenged claims do not require
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`stress and that he had confused the legal requirements for dependent claims during
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`the first re-cross). This observation is also irrelevant because there is no dispute
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`that the challenged claims do not require stress. PO has never asserted that the
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`challenged claims require a stress film and acknowledges that there is no such
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`requirement. PO Observation #15; PO’s Motion to Exclude (Paper 35) at 8.
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`Response to Observation #15
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`PO cites to Ex. 2026 at 56:17-58:2, 144:1-12, and 160:20-23, alleging that
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`Dr. Shanfield changed his testimony in response to alleged coaching. As discussed
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`above for Observation #14, this allegation is baseless. Dr. Shanfield testified
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`repeatedly and unambiguously throughout the deposition (and this proceeding) that
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`the challenged claims do not require stress. Ex. 2026, 51:22-52:2; id., 30:4-6; id.
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`13
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`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
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`52:21-53:6; see also Ex. 1002, ¶46 n. 3. On re-cross, he misstated the legal
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`relationship between dependent and independent claims on the record and gave
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`testimony based on that misunderstanding. Ex. 2026, 159:5-160:23. Even PO’s
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`counsel recognized that Dr. Shanfield was confused on a legal issue. Id., 159:5-
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`160:19 (“… A… So stress is required in the set of the dependent claims that relate
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`to the independent claim. Q. Perhaps you're confused…”). When the law was
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`clarified, Dr. Shanfield confirmed, consistent with his earlier testimony, that as a
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`technical matter, claim 1 does not require stress. Id., 167:14-21, 171:9-172:14,
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`174:12-23, 175:2-15, 176:4-24, 177:11-19. See also Response to Observation #14.
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`Response to Observation #16
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`
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`PO cites to Ex. 2026 at 56:17-58:2, 160:20-23, 167:14-173:3, and 173:10-
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`178:4, as allegedly showing Dr. Shanfield’s testimony has been inconsistent. To
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`the contrary, as discussed for Observations #14-15, Dr. Shanfield’s testimony has
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`been consistent that, as a technical matter, claim 1 does not require stress. See also
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`Response to Observations #14-15.
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`Response to Observation #17
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`PO cites to Exhibit 2026 at 45:3-18, 56:17-58:2, and 160:20-23 as allegedly
`
`showing Dr. Shanfield testified an etch stop layer cannot satisfy the silicon nitride
`
`film limitation. This observation mischaracterizes Dr. Shanfield’s testimony. As
`
`discussed above, Dr. Shanfield repeatedly and unambiguously testified that the
`
`14
`
`

`

`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
`
`
`claims do not require stress. Response to Observations #14-15. Moreover, Dr.
`
`Shanfield unambiguously confirmed that the claimed silicon nitride film includes
`
`etch stop layers and that Igarashi discloses the claimed silicon nitride film. Ex.
`
`2026, 145:11-13 (Q: Could the silicon nitride film in Claim 1 be a silicon nitride
`
`etch stop layer? A. Yes, it could); 145:20-22 (“Q. Has your testimony that Igarashi
`
`discloses the claimed silicon nitride film changed? A. No, not at all.); 146:8-11
`
`(same); see also Ex. 1002, ¶¶91-102). This observation is also irrelevant because
`
`Patent Owner has never disputed that Igarashi’s silicon nitride film discloses the
`
`claimed silicon nitride film and agrees the claims do not require stress. PO
`
`Observation #15; PO’s Motion to Exclude (Paper 35) at 8.
`
`
`
`Dated: August 22, 2018 Respectfully Submitted,
`
`
`
`/ Michael Smith /________________
`Michael H. Smith, Reg. No. 71,190
`
`15
`
`

`

`U.S. Patent 7,893,501; IPR2017-01841
`Petitioner’s Response to Patent Owner’s Observations on Cross-Examination
`
`CERTIFICATE OF SERVICE
`I hereby certify that, on August 22, 2018, I caused a true and correct copy of the
`
`foregoing materials:
`
` Petitioner’s Response to Patent Owner’s Observations on Cross-
`
`Examination
`
`to be served via email on the following counsel of record as listed in Patent
`
`Owner’s Mandatory Notices:
`
`Gerald B. Hrycyszyn, Registration No. 50,474
`GHrycyszyn-PTAB@wolfgreenfield.com
`
`Richard F. Giunta, Registration No. 36,149
`RGiunta-PTAB@wolfgreenfield.com
`
`Edmund J. Walsh, Registration No. 32,950
`EWalsh-PTAB@wolfgreenfield.com
`
`Joshua Miller, admitted pro hac vice
`Joshua.Miller@wolfgreenfield.com
`
`Wolf, Greenfield & Sacks, P.C.
`600 Atlantic Avenue
`Boston, MA 02210
`
`Respectfully Submitted,
`
`___/ Michael Smith /__________
`Michael H. Smith
`Registration No. 71,190
`
`i
`
`

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