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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`BROADCOM LIMITED,
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`Petitioner
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`v.
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`TESSERA, INC.
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`Patent Owner.
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`Case No. IPR2017-00889
`U.S. Patent No. 6,841,107
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`DECLARATION OF C. P. WONG, PH.D. UNDER 37 C.F.R. § 1.68
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`Broadcom Exhibit 1006
`Page 1 of 40
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`TABLE OF CONTENTS
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`I.
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`SCOPE OF THE DECLARATION ........................................................ 1
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`II. EXPERT QUALIFICATIONS AND BACKGROUND ........................ 2
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`III. MATERIALS REVIEWED .................................................................... 4
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`IV. SUMMARY OF OPINIONS .................................................................. 5
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`V. PERSON OF ORDINARY SKILL IN THE ART OF THE ʼ107
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`PATENT ......................................................................................................... 5
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`VI. UNDERSTANDING OF LEGAL PRINCIPLES ................................... 7
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`VII. OVERVIEW OF THE ʼ107 PATENT/TECHNOLOGY
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`BACKGROUND .......................................................................................... 16
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`A. The ʼ107 Patent ................................................................................ 16
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`VIII. CLAIM CONSTRUCTION ............................................................ 18
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`IX. YANAGIHARA ANTICIPATES CLAIMS 1, 2, 5, 6 AND 8 ............. 18
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`A. Yanagihara Discloses all Limitations of Independent Claim 1. ...... 19
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`1.
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`2.
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`“A microelectronic assembly comprising:” ..................................... 19
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`“a microelectronic element having a first surface including a central
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`region and a peripheral region surrounding said central region, said
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`microelectronic element including a plurality of contacts disposed in said
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`central region” ............................................................................................... 19
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`Broadcom Exhibit 1006
`Page 2 of 40
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`3.
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`“a compliant layer overlying said peripheral region of said first
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`surface, said compliant layer having a bottom surface facing toward said
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`first surface of said microelectronic element, a top surface facing upwardly
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`away from the first surface of said microelectronic element and one or more
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`edge surfaces extending between said top and bottom surfaces of said
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`compliant layer; and” .................................................................................... 21
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`4.
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`“a plurality of bond ribbons disposed over said compliant layer so
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`that said bond ribbons extend over said top surface and one or more of said
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`edge surfaces and said bond ribbons electrically connect said contacts to
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`conductive terminals overlying the top surface of said compliant layer.” ... 23
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`B. Yanagihara Discloses All Limitations of Dependent Claim 2. ....... 25
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`C. Yanagihara Discloses All Limitations of Claim 5. .......................... 25
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`D. Yanagihara Discloses All Limitations of Claim 6. .......................... 27
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`E. Yanagihara Discloses All Limitations of Claim 8. .......................... 28
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`X. YANAGIHARA IN VIEW OF HARADA RENDERS OBVIOUS
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`CLAIM 3 ....................................................................................................... 30
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`XI. YANAGIHARA IN VIEW OF INOUE RENDERS OBVIOUS
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`CLAIMS 4 AND 7 ........................................................................................ 33
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`XII. CONCLUSION ..................................................................................... 36
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`Broadcom Exhibit 1006
`Page 3 of 40
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`I, C. P. Wong, being over the age of 18 and competent to make the
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`statements herein, hereby declare the following:
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`I.
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`SCOPE OF THE DECLARATION
`1.
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`I have been retained on behalf of Petitioner Broadcom Limited
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`(“Petitioner”) as an expert consultant to analyze and provide my opinions on
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`the validity of U.S. Patent No. 6,847,107 (the “ʼ107 Patent”), and such other
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`topics as addressed in this report.
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`2.
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`3.
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`I make this declaration based upon my personal knowledge.
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`The statements herein include my opinions and the bases for
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`those opinions, which relate to the following documents of the pending inter
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`parties review petition:
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`Exhibit 1001: U.S. Patent No. 6,847,107 (“the ʼ107 Patent”)
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`Exhibit 1002: File History of U.S. Patent No. 6,847,107
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`Exhibit 1003: Japanese Patent Publication No. JPH05-144823
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`(“Yanagihara”) (with English translation and attendant
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`affidavit)
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`Exhibit 1004: Japanese Patent Publication No. JPS64-1257
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`(“Harada”) (with English translation and attendant affidavit)
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`Exhibit 1005: Japanese Patent Publication No. JPH02-272737
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`(“Inoue”) (with English translation and attendant affidavit)
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`Broadcom Exhibit 1006
`Page 4 of 40
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`4. Although I am being compensated for my time at a rate of $550
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`per hour in preparing this declaration, the opinions herein are my own, and I
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`have no stake in the outcome of the review proceeding. My compensation
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`does not depend in any way on the outcome of the Petitioner’s petition.
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`5.
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`If called upon to do so, I am prepared to testify as an expert
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`witness in this regard.
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`6.
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`This declaration is based on information currently available to
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`me. To the extent that additional information becomes available, I reserve
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`the right to continue my investigation and study, which may include a
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`review of documents and information that may be produced, as well as
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`testimony from depositions that have not yet been taken.
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`II. EXPERT QUALIFICATIONS AND BACKGROUND
`7. A detailed Curriculum Vitae that includes my professional
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`qualifications, publications, honors and professional activities is attached
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`with this report as Attachment A.
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`8.
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`I am a Regents’ Professor and the Charles Smithgall Institute-
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`Endowed Chair in the School of Materials Science and Engineering at the
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`Georgia Institute of Technology (GT).
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`9.
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`I received my BS degree from Purdue University, and my M.S.
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`and Ph.D. degree from the Pennsylvania State University. After my doctoral
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`- 2 -
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`Broadcom Exhibit 1006
`Page 5 of 40
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`study, I was awarded a postdoctoral fellowship under Nobel laureate Prof.
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`Henry Taube at Stanford University. Prior to joining Georgia Tech, I was
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`with AT&T Bell Laboratories for many years and became an AT&T Bell
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`Laboratories Fellow (the highest technical award bestowed by AT&T Bell
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`Labs) in 1992.
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`10.
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`I have published widely with over 1,000 technical papers, and
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`authored and edited 12 books. I have yielded fruitful research results and
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`hold over 55 US patents. I have made significant contributions to the
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`industry by pioneering new materials, which fundamentally changed the
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`semiconductor packaging industry.
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`11.
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`I have successfully motivated and nurtured numerous inquisitive
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`young minds over the years. As a distinguished scholar, I was awarded
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`numerous international honors, such as the IEEE Components, Packaging
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`and Manufacturing Technology (CPMT) Society Outstanding Sustained
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`Technical Contributions Award in 1995, the IEEE Third Millennium Medal
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`in 2000, the IEEE Education Activities Board (EAB) Education Award in
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`2001, the IEEE CPMT Society Exceptional Technical Contributions Award
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`in 2002, the Georgia Tech (GT) Class 1934 Distinguished Professor Award
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`(the highest award by GT to its faculty) in 2004, named holder of the
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`Charles Smithgall Institute-Endowed Chair (one of the two GT Institute-
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`- 3 -
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`Broadcom Exhibit 1006
`Page 6 of 40
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`endowed Chairs) in 2005, the IEEE Components, Packaging and
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`Manufacturing Technology Field Award(hailed as Father of the Modern
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`Semiconductor Packaging) in 2006, the Sigma Xi’s Monie Ferst Award in
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`2007, the Society of Manufacturing Engineers’ Total Excellence in
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`Electronic Manufacturing Award in 2008, and the IEEE CPMT Society
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`David Feldman Award in 2009. I also received the 2012 International
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`Dresden Barkhausen Award (Germany).
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`12.
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`I am a member of the US National Academy of Engineering
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`(elected in 2000), and a foreign academician member of the Chinese
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`Academy of Engineering (elected in 2013).
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`13. During the past four (4) years, I have not provided expert
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`testimony or reports in any cases.
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`III. MATERIALS REVIEWED
`14.
`I have reviewed the documents referenced above to form my
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`opinions.
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`15.
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`I intend to continue to review materials that may inform my
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`opinions expressed in this Declaration. I reserve the right to amend or
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`supplement this Declaration and to rely on additional materials and
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`testimony brought to my attention during the course of this proceeding.
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`Broadcom Exhibit 1006
`Page 7 of 40
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`IV. SUMMARY OF OPINIONS
`16. Based on the materials that I have reviewed, the analyses I have
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`performed, the positions I have summarized within this declaration, and my
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`personal experience, I have formed at least the opinions listed below.
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`17. Claims 1, 2, 5, 6 and 8 of the ʼ107 Patent are anticipated by
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`Yanagihara.
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`18. Claim 3 of the ʼ107 Patent would have been obvious based on
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`Yanagihara in view of Harada.
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`19. Claims 4 and 7 of the ʼ107 Patent would have been obvious
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`based on Yanagihara in view of Inoue.
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`V.
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`PERSON OF ORDINARY SKILL IN THE ART OF THE ʼ107
`PATENT
`20.
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`I understand that the patent, the claims in the patent, and the
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`prior art are interpreted the way a person of ordinary skill in the art would
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`have interpreted the material at the time of the invention. I understand that
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`the “time of the invention” here is the earliest priority date that the
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`applicants for the ʼ107 Patent claimed in the United States Patent and
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`Trademark Office, namely, October 31, 1995.
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`21.
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`In determining the characteristics of a hypothetical person of
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`ordinary skill in the art of the relevant patents at the time of the claimed
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`invention, I considered several things, including the factors discussed below,
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`Broadcom Exhibit 1006
`Page 8 of 40
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`as well (1) the levels of education and experience of the inventor and other
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`persons actively working in the field; (2) the types of problems encountered
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`in the field; (3) prior art solutions to those problems; (4) the rapidity with
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`which innovations are made; and (5) the sophistication of the technology.
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`Finally, I placed myself back in the relevant time period and considered the
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`individuals that I had worked with in the field.
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`22.
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`It is my opinion that one of ordinary skill in the art at the time
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`of the priority date of the patent would have been someone with at least an
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`undergraduate degree in engineering, physics, chemistry, materials science,
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`or similar field, and three to five years of industry experience in the field of
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`integrated circuit packaging.
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`23.
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`I am prepared to testify as an expert in this field and also as
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`someone who had at least the knowledge of the person of ordinary skill in
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`the art at the time of the purported invention, and someone who worked with
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`others that had at least the knowledge of the person of ordinary skill in the
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`art at the time of the purported invention.
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`24.
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` I understand that the person of ordinary skill is a hypothetical
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`person who is assumed to be aware of all the pertinent information that
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`qualifies as prior art. In addition, the person of ordinary skill in the art
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`makes inferences and takes creative steps.
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`Broadcom Exhibit 1006
`Page 9 of 40
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`25. Unless otherwise stated, my statements below refer to the
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`knowledge, beliefs and abilities of a person having ordinary skill in the art of
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`the ʼ107 patent at the time of the purported invention of the ʼ107 patent
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`VI. UNDERSTANDING OF LEGAL PRINCIPLES
`26.
`I am not an attorney and will offer no opinions on the law. I
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`have, however, developed an understanding of several legal principles
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`concerning invalidity (and other relevant issues). I have applied this
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`understanding in arriving at my stated opinions and conclusions in this
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`Declaration.
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`27. My understanding is that there are two different types of
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`asserted claims in the ‘107 patent. One type of claim is called an
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`independent claim. The other type of claim is called a dependent claim. An
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`independent claim is a claim that does not refer to any other claim of the
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`patent. An independent claim must be read separately from the other claims
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`to determine the scope of the claim. A dependent claim is a claim that refers
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`to at least one other claim in the patent. A dependent claim incorporates all
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`of the elements of any claim to which the dependent claim refers, as well as
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`the elements recited in the dependent claim itself.
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`28. While I am not an attorney, I have gained from counsel an
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`understanding of the law that pertains to the invalidity of patents.
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`Broadcom Exhibit 1006
`Page 10 of 40
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`29.
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`I understand that all patent claims of an issued patent are
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`presumed to be valid. I understand that the presumption of validity may be
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`overcome if the subject matter of the claims is either not novel or is obvious
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`after analysis of “prior art.” The subject matter of one or more claims is not
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`novel if it was known or used by others in this country, or patented or
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`described in a printed publication in this or a foreign country, before the
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`applicant(s) invented the subject matter of the claims. In addition, claims are
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`not novel if the subject matter of the claims was patented or described in a
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`printed publication in this or a foreign country or in public use or on sale in
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`this country, more than one year prior to the date of the application for
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`patent in the United States, and for various other reasons described in
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`Section 102 of the Patent Act and discussed in further detail below.
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`30. Prior art can include publications, patents, patent applications,
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`published patent applications, or prior knowledge or disclosure, use, sale, or
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`offer for sale in the United States of the patented subject matter by others
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`either prior to the date of invention or more than one year prior to the date
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`the patent application was filed.
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`31.
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`I understand that in order for a claim to be invalid for lack of
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`novelty, or anticipated, a single prior art reference must disclose each and
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`every limitation of the patent claim. It is not considered in a void, rather, one
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`- 8 -
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`Broadcom Exhibit 1006
`Page 11 of 40
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`must take into account what a person of ordinary skill in the art would have
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`understood from the reference. I also understand that one should consider
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`not only what is expressly disclosed in the prior art reference, but also what
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`would naturally, inherently have been understood from what is disclosed in
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`the prior art reference. I understand that to prove inherency, the missing
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`descriptive matter is necessarily present in the reference, and it would be so
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`recognized by one of ordinary skill in the art.
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`32.
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`I understand that in order to invalidate a dependent claim, all
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`elements of that dependent claim and the claim from which it depends must
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`be taught or suggested.
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`33.
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`I understand that determining anticipation of the patent claim
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`requires a comparison of the properly construed claim language to the prior
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`art on an element-by-element basis.
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`34.
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`I understand that a claimed invention is “anticipated” if each and
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`every element of the claim, as properly construed, has been disclosed in a
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`single prior art reference, or has been embodied in a single prior art device
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`or practice, either explicitly or inherently (i.e., necessarily present or
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`implied), and the claimed arrangement or combination of those elements
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`must also be disclosed, either expressly or inherently, in the same prior art
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`reference. I understand that prior art includes various categories of
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`Broadcom Exhibit 1006
`Page 12 of 40
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`information such as printed publications, patents, actual commercial
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`products, and/or other physical embodiments.
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`35.
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`I understand that although anticipation cannot be established by
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`combining references, additional references may be used to interpret the
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`anticipating reference by, for example, indicating what the anticipating
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`reference would have meant to one having ordinary skill in the art. In
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`addition, the description provided in the prior art must be such that a person
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`of ordinary skill in the art in the field of invention could, based on the
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`reference, practice the invention without undue experimentation.
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`36.
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`I understand that a patent claim must be nonobvious to be valid.
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`I understand obviousness is determined from the perspective of one of
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`ordinary skill in the art at the time the invention was filed.
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`37.
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`I understand that patent claims are obvious if, although not
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`identically disclosed or described, the differences between the subject matter
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`sought to be patented and the prior art are such that the subject matter as a
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`whole would have been obvious at the time the invention was made to a
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`person having ordinary skill in the art to which said subject matter pertains.
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`38.
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`I understand that a patent claim is rendered obvious if the
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`claimed subject matter as a whole would have been obvious to a person of
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`ordinary skill in the art as of the date of invention. I understand that this
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`Broadcom Exhibit 1006
`Page 13 of 40
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`determination is made after weighing the following factors: (1) level of
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`ordinary skill in the pertinent art; (2) the scope and content of the prior art;
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`(3) the differences between the prior art as a whole and the claim at issue;
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`and (4) as appropriate, secondary considerations of non-obviousness.
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`39.
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`I understand that the knowledge and understanding of a person
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`of ordinary skill in the art provides a reference point from which the prior art
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`and claimed invention should be viewed. This reference point prevents one
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`from using his or her own insight or hindsight in deciding whether a claim is
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`obvious, but I further understand that if a person of ordinary skill in the art
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`can implement the claimed invention as a predictable variation of a known
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`product, then the claim may be rendered obvious. I further understand that a
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`person of ordinary skill in the art is presumed to have knowledge of the
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`relevant prior art at the time of the claimed invention, and the scope of the
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`prior art comprises any prior art that was reasonably pertinent to the
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`particular problems the inventor faced.
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`40.
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`I understand that an obviousness evaluation can be made of a
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`single reference or a combination of multiple prior art references. I
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`understand that a proper obviousness analysis as to two or more references
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`generally requires a reason that would have prompted a person of ordinary
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`skill in the relevant field to combine the elements of multiple prior art
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`Broadcom Exhibit 1006
`Page 14 of 40
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`references in the way the claimed new invention does. I understand that the
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`prior art references themselves may provide a suggestion, motivation, or
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`reason to combine. I further understand that obviousness analysis
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`recognizes that market demand, rather than scientific literature, often drives
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`innovation, and that a motivation to combine references may be supplied by
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`the direction of the marketplace or other external factors.
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`41.
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`I understand that a particular combination may be proven
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`obvious merely by showing that it was obvious to try the combination. For
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`example, when there is a design need or market pressure to solve a problem
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`and there are a finite number of identified, predictable solutions, a person of
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`ordinary skill has good reason to pursue the known options within his or her
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`technical grasp because the result is likely the product not of innovation but
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`of ordinary skill and common sense.
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`42.
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`I further understand that a proper obviousness analysis focuses
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`on what was known or obvious to a person of ordinary skill in the art, not
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`just the patentee. Accordingly, I understand that any need or problem
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`known in the field of endeavor at the time of invention and addressed by the
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`patent can provide a reason for combining the elements in the manner
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`claimed.
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`Broadcom Exhibit 1006
`Page 15 of 40
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`43.
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`In sum, my understanding is that prior art teachings are properly
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`combined where a person of ordinary skill in the art having the
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`understanding and knowledge reflected in the prior art and motivated by the
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`general problem facing the inventor, would have been led to make the
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`combination of elements recited in the claims. Under this analysis, the prior
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`art references themselves, or any need or problem known in the field of
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`endeavor at the time of the claimed invention, can provide a reason for
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`combining the elements of multiple prior art references in the claimed
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`manner.
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`44.
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`I understand that at least the following rationales may support a
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`finding of obviousness:
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`i. Combining prior art elements according to known methods to
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`yield predictable results;
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`ii. Simple substitution of one known element for another to obtain
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`predictable results;
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`iii. Use of a known technique to improve similar devices (methods,
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`or products) in the same way;
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`iv. Applying a known technique to a known device (method, or
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`product) ready for improvement to yield predictable results;
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`Broadcom Exhibit 1006
`Page 16 of 40
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`v.
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`“Obvious to try”—choosing from a finite number of identified,
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`predictable solutions, with a reasonable expectation of success;
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`vi. A predictable variation of work in the same or a different field
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`of endeavor if a person of ordinary skill would be able to
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`implement the variation;
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`vii.
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`If, at the time of the alleged invention, there existed a known
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`problem for which there was an obvious solution encompassed
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`by the patent’s claims;
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`viii. Known work in one field of endeavor may prompt variations of
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`it for use in either the same field or a different one based on
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`design incentives or other market forces if the variations would
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`have been predictable to one of ordinary skill in the art; and
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`ix. Some teaching, suggestion, or motivation in the prior art that
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`would have led one of ordinary skill to modify the prior art
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`reference or to combine prior art reference teachings to arrive at
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`the claimed invention.
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`45.
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`I have been informed and understand that secondary
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`considerations of non-obviousness may include: (1) whether the invention
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`proceeded in a direction contrary to accepted wisdom in the field; (2)
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`whether there was a long felt but unresolved need in the art that was satisfied
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`Broadcom Exhibit 1006
`Page 17 of 40
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`by the invention; (3) whether others had tried but failed to make the
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`invention; (4) whether others copied the invention; (5) whether the invention
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`achieved unexpected results; (6) whether the invention was praised by
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`others; (7) whether others have taken licenses to use the invention; (8)
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`whether experts or those skilled in the art at the making of the invention
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`expressed surprise or disbelief regarding the invention; (9) whether products
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`incorporating the invention have achieved commercial success that is
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`attributable to the invention; and (10) whether or not others having ordinary
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`skill in the field independently made the claimed invention at about the same
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`time the inventor made the invention.
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`46.
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`I also understand that for any such secondary consideration to be
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`relevant, the patentee must establish a connection or nexus between the
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`secondary consideration and the claimed invention. For example,
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`commercial success is relevant to obviousness only if the success of the
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`product is related to a feature of the patent claims. If, however, commercial
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`success is due to advertising, promotion, salesmanship or the like, or is due
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`to features of the product other than the claimed invention, then any
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`commercial success should not be considered an indication of non-
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`obviousness.
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`Broadcom Exhibit 1006
`Page 18 of 40
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`47. Yanagihara was published on June 11, 1993, and thus (as
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`informed by counsel) is prior art under at least 35 U.S.C. § 102(b).
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`48. Harada was published on January 5, 1989, and thus (as informed
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`by counsel) is prior art under at least 35 U.S.C. § 102(b).
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`49.
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`Inoue was published on November 7, 1990, and thus (as
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`informed by counsel) is prior art under at least 35 U.S.C. § 102(b).
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`VII. OVERVIEW OF THE ʼ107 PATENT/TECHNOLOGY
`BACKGROUND
`A.
` The ʼ107 Patent
`50. Generally, the ’107 patent relates to semiconductor chip
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`packaging, and particularly a compliant semiconductor package structure.
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`(Ex. 1001 at 1:25-28.)
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`51. Semiconductor chips are mounted on substrates and connected
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`to other electrical components via bonding to electrical traces. (Id. at 1:31-
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`39.)
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`52.
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`In “flip-chip” bonding, the contact-bearing surface of the chip
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`faces towards the substrate, and each contact is joined by a solder bond to
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`the corresponding pad on the substrate. (Id. at 1:65 – 2:1.) This is done by
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`positioning solder balls on the substrate or chip, juxtaposing the chip with
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`the substrate in the front-face-down orientation, and momentarily reflowing
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`the solder. (Id. at 2:1-4.) While the flip-chip technique has several
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`Broadcom Exhibit 1006
`Page 19 of 40
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`advantages, it potentially creates substantially rigid solder bonds that are
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`subject to failure under thermal stress. (Id. at 2:6-13.) Further, the ʼ107
`
`Patent claims that the flip-chip technique makes it difficult to test the chip
`
`before attaching it to the substrate. (Id. at 2:13-15.) I disagree that this is
`
`true, as flip-chips can be tested using a “wafer level test.”
`
`53. The ʼ107 Patent purports to improve the flip chip technique to
`
`address the aforementioned problems. The ʼ107 Patent describes a
`
`fabrication process in which a first dielectric protective layer is provided on
`
`a contact bearing surface of a semiconductor chip. (Id. at 3:31-33.) A
`
`compliant layer preferably consisting of silicone, flexibilized epoxy, a
`
`thermosetting polymer or polyimide is provided atop the dielectric protective
`
`layer. (Id. at 3:40-43.) The compliant layer has a substantially flat top
`
`surface and edges that gradually slope down to the top surface of the
`
`dielectric protective layer. (Id. at 3:43-45.) Bond ribbons are then
`
`selectively formed atop both the first dielectric protective layer and the
`
`compliant layer such that each bond ribbon electrically connects each chip
`
`contact to a respective terminal position on the compliant layer. (Id. at 3:52-
`
`55.) The terminal positions are the conductive elements that connect the
`
`finished assembly to a separate substrate such as a printed circuit board. (Id.
`
`at 3:58-60.)
`
`- 17 -
`
`Broadcom Exhibit 1006
`Page 20 of 40
`
`
`
`
`
`54.
`
`I have reviewed the ‘107 Patent and the prosecution file history
`
`for the ‘107 Patent. (Ex. 1001 and Ex. 1002.)
`
`VIII. CLAIM CONSTRUCTION
`55.
`I understand that, Because the ’107 patent is expired, the
`
`applicable claim construction standard is that claim terms are given their
`
`ordinary and customary meanings, as would be understood by a person of
`
`ordinary skill in the art at the time of the invention, having taken into
`
`consideration the language of the claims, the specification, and the
`
`prosecution history of record. Any special definition for a claim term must
`
`be set forth with reasonable clarity, deliberateness, and precision.
`
`56.
`
`It is my opinion that all claim terms of the ‘107 Patent should
`
`be given their ordinary meaning and no express construction of any claim
`
`term is required.
`
`57.
`
`In the event that one or more express constructions of any claim
`
`term is entered by the Board, I reserve the right to revisit my analysis under
`
`such construction(s).
`
`IX. YANAGIHARA ANTICIPATES CLAIMS 1, 2, 5, 6 AND 8
`58. Yanagihara discloses each and every element of claims 1, 2, 5,
`
`6 and 8.
`
`- 18 -
`
`Broadcom Exhibit 1006
`Page 21 of 40
`
`
`
`
`
`A. Yanagihara Discloses all Limitations of Independent Claim
`1.
`
`59.
`
`In my opinion, one of ordinary skill in the art would understand
`
`that Yanagihara discloses all of the limitations of independent claim 1. For
`
`the reasons that follow, it is my opinion that Yanagihara anticipates
`
`independent claim 1.
`
`1.
`
`“A microelectronic assembly comprising:”
`
`60.
`
`I am informed that the preamble of claim 1 is not limiting
`
`because, for instance, it merely provides a description for the limitations in
`
`the body of the claim. Regardless, even if the preamble is found to be
`
`limiting, Yanagihara discloses “a microelectronic assembly.” Specifically,
`
`Yanagihara discloses “a method for forming high-density bumps, allowing
`
`easy formation of bumps for electrically conductive circuits in high density
`
`at pad portions on a wafer.” (Ex. 1003, Object (emphasis added).) An
`
`“electrically conductive circuit” is a “microelectronic assembly.”
`
`2.
`
`“a microelectronic element having a first surface
`including a central region and a peripheral region
`surrounding said central region, said microelectronic
`element including a plurality of contacts disposed in
`said central region”
`
`61. Yanagihara discloses a microelectronic element having a first
`
`surface including a central region and a peripheral region surrounding said
`
`central region, said microelectronic element including a plurality of contacts
`
`- 19 -
`
`Broadcom Exhibit 1006
`Page 22 of 40
`
`
`
`disposed in said central region. Figure 13 shows a chip with a first surface
`
`including a central region and a peripheral region surrounding the central
`
`region, with a plurality of contacts in the central region.
`
`
`
`Central
`region
`
`Peripheral
`region
`
`Contacts
`
`
`
`62. The specification further describes a cushion portion 6
`
`“disposed on the periphery” that surrounds the central region of the chip
`
`
`
`- 20 -
`
`Broadcom Exhibit 1006
`Page 23 of 40
`
`
`
`
`
`shown in Figure 13, and “forming an electrically conductive circuit 10 from
`
`a surface of each pad portion 3 to a surface of the cushion portion 6.” (Ex.
`
`1003, Configuration.) Thus, Yanagihara discloses pad portions 3 (i.e., the
`
`claimed “plurality of contacts”) disposed in the central region of a chip 2
`
`that is surrounded by a periphery region that includes “cushion portion 6.”
`
`3.
`
`“a compliant layer overlying said peripheral region of
`said first surface, said compliant layer having a
`bottom surface facing toward said first surface of said
`microelectronic element, a top surface facing
`upwardly away from the first surface of said
`microelectronic element and one or more edge
`surfaces extending between said top and bottom
`surfaces of said compliant layer; and”
`
`63. Yanagihara discloses a compliant layer overlying the peripheral
`
`region. In particular, Yanagihara discloses a cushion portion 6 composed of
`
`a “a photosensitive polyimide” that is “disposed on the periphery of each of
`
`chips on a wafer.” (Ex. 1003 ¶ 5.) The polyimide cushion portion is a
`
`compliant layer.
`
`64. As seen in annotated Figures 13 and 12 below, Yanagihara also
`
`makes clear that the polyimide compliant-layer cushion portion has three
`
`surfaces: a bottom surface facing the microelectronic element, a top surface
`
`facing away from the microelectronic element, and two edge surface that
`
`each “slopes gently” extending between the top and bottom surfaces. (Id. ¶
`
`6.) The slope of the edge surfaces can be seen in Figures 13 and 12:
`
`- 21 -
`
`Broadcom Exhibit 1006
`Page 24 of 40
`
`
`
`
`
`Edge surface
`
`
`
`
`
`Edge surface
`
`65.
`
`In sum, Figures 13 and 12 show the polyimide cushion (i.e., the
`
`claimed “compliant layer”) overlying the peripheral region of the chip, with
`
`the bottom surface contacting the top (first) surface of the chip, a top surface
`
`facing away from the first surface of the chip, and “gently-sloping” edge
`
`- 22 -
`
`Broadcom Exhibit 1006
`Page 25 of 40
`
`
`
`surfaces extending between the top and bottom surfaces of the polyimide
`
`
`
`layer.
`
`4.
`
`“a plurality of bond ribbons disposed over said
`compliant layer so that said bond ribbons extend over
`said top surface and one or more of said edge surfaces
`and said bond ribbons electrically connect said
`contacts to conductive terminals overlying the top
`surface of said compliant layer.”
`
`66. Yanagihara discloses a plurality of bond ribbons disposed over
`
`said compliant layer so that said bond ribbons extend over said top surface
`
`and one or more of said
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