Petitioner Semiconductor Components Industries, LLC (onsemi)
`Oral Argument for PTAB Hearing
`Semiconductor Components Industries, LLC and Texas Instruments Incorporated v. Greenthread, LLC
`IPR2023-01242 (U.S. Patent No. 11,121,222)
`IPR2023-01243 (U.S. Patent No. 10,510,842)
`IPR2023-01244 (U.S. Patent No. 11,121,222)
`November 13, 2024
`
`© Copyright Baker Botts 2024. All Rights Reserved.
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`ONSEMI EXHIBIT 1056, Page 1
`Semiconductor Components Industries, LLC et al. v. Greenthread LLC
`IPR2023-01242
`
`Greenthread Ex. 2087, p. 1 of 81
`Semiconductor v. Greenthread
`
`
`Oral Argument for PTAB Hearing
`Semiconductor Components Industries, LLC and Texas Instruments Incorporated v. Greenthread, LLC
`IPR2023-01242 (U.S. Patent No. 11,121,222)
`IPR2023-01243 (U.S. Patent No. 10,510,842)
`IPR2023-01244 (U.S. Patent No. 11,121,222)
`November 13, 2024
`
`© Copyright Baker Botts 2024. All Rights Reserved.
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`ONSEMI EXHIBIT 1056, Page 1
`Semiconductor Components Industries, LLC et al. v. Greenthread LLC
`IPR2023-01242
`
`Greenthread Ex. 2087, p. 1 of 81
`Semiconductor v. Greenthread
`
`
`
`Table of Contents
`
`01
`
`Overview of the ’222 and ’842 Patents
`and Instituted Grounds
`
`05
`
`The “isolation region” dependent
`claims are obvious
`
`The prior art discloses all claim limitations
`
`02
`
`06
`
`Patent Owner’s settlement agreements
`do not show non-obviousness
`
`03
`
`The “aid carrier movement” limitations
`are obvious
`
`The Petition is timely
`
`07
`
`04 The “opposite in conductivity” limitations
`are obvious
`
`BAKER BOTTS
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`Greenthread Ex. 2087, p. 2 of 81
`Semiconductor v. Greenthread
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`2
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`
`
`OVERVIEW OF ’222 AND ’842 PATENTS
`AND INSTITUTED GROUNDS
`
`OVERVIEW
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Greenthread Ex. 2087, p. 3 of 81
`Semiconductor v. Greenthread
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`
`
`THE ’222 AND ’842 PATENTS
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Greenthread Ex. 2087, p. 4 of 81
`Semiconductor v. Greenthread
`
`
`
`’842 Patent
`
`1. A semiconductor device, comprising:
`
`a substrate of a first doping type at a first doping level having first and second surfaces;
`
`a first active region disposed adjacent the first surface of the substrate with a second
`doping type opposite in conductivity to the first doping type and within which transistors can
`be formed;
`
`a second active region separate from the first active region disposed adjacent to the first
`active region and within which transistors can be formed;
`
`transistors formed in at least one of the first active region or second active region; and
`
`at least a portion of at least one of the first and second active regions having at least one
`graded dopant concentration to aid carrier movement from the first surface to the second
`surface of the substrate.
`
`‘842 Patent, EX1001 (-01243), Claim 1
`
`BAKER BOTTS
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`Greenthread Ex. 2087, p. 5 of 81
`Semiconductor v. Greenthread
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`5
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`
`
`’222 Patent
`
`1. A VLSI semiconductor device, comprising:
`
`a substrate of a first doping type at a first doping level having a surface;
`
`a first active region disposed adjacent the surface with a second doping type opposite in
`conductivity to the first doping type and within which transistors can be formed;
`
`a second active region separate from the first active region disposed adjacent to the first
`active region and within which transistors can be formed;
`
`transistors formed in at least one of the first active region or second active region;
`
`at least a portion of at least one of the first and second active regions having at least one
`graded dopant concentration to aid carrier movement from the first and second active
`regions towards an area of the substrate where there are no active regions; and
`
`at least one well region adjacent to the first or second active region containing at least one
`graded dopant region, the graded dopant region to aid carrier movement from the surface
`towards the area of the substrate where there are no active regions, wherein at least some of
`the transistors form digital logic of the VLSI semiconductor device.
`
`BAKER BOTTS
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`’222 Patent, EX1001 (-01242, -01244), Claim 1
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Greenthread Ex. 2087, p. 6 of 81
`Semiconductor v. Greenthread
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`6
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`
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`’222 Patent
`
`44. A CMOS Semiconductor device, comprising:
`
`a surface layer;
`
`a substrate;
`
`an active region including a source and a drain, disposed on one surface of the surface layer;
`a single drift layer disposed between the other surface of the surface layer and the substrate,
`the drift layer having a graded concentration of dopants extending between the surface layer
`and the substrate, the drift layer further having a first static unidirectional electric drift field
`to aid the movement of carriers from the surface layer to an area of the substrate where
`there are no active regions; and
`
`at least one well region disposed in the single drift layer, the well region having a graded
`concentration of dopants and a second static unidirectional electric drift field to aid the
`movement of carriers from the surface layer to the area of the substrate where there are no
`active regions.
`
`‘222 Patent, EX1001 (-01242, -01244), Claim 44
`
`BAKER BOTTS
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Greenthread Ex. 2087, p. 7 of 81
`Semiconductor v. Greenthread
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`7
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`
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`INSTITUTED GROUNDS
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Greenthread Ex. 2087, p. 8 of 81
`Semiconductor v. Greenthread
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`
`
`Instituted Grounds
`
`Ground
`I
`
`IPR2023-01242 (U.S. Patent 11,121,222)
`35 U.S.C. §
`Claims
`1–9, 13, 14, 16–21, 23–28, 32–42
`103(a)
`
`Prior art
`Kawagoe (EX1007)
`
`II
`III
`IV
`V
`
`VI
`
`1, 2, 4–9, 13–23, 25-28, 32–42
`1–9, 13, 14, 16–21, 23–28, 32–42
`1, 2, 4–9, 13–23, 25–28, 32–42
`19, 37
`
`19, 37
`
`103(a)
`103(a)
`103(a)
`103(a)
`
`103(a)
`
`Wieczorek (EX1006), Wolf (EX1008)
`Kawagoe, Gupta (EX1014)
`Wieczorek, Wolf, Gupta
`Kawagoe, Silverbrook (EX1042)
`Wieczorek, Wolf, Silverbrook
`
`Institution Decision, Paper 32 (-01242)
`
`BAKER BOTTS
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Greenthread Ex. 2087, p. 9 of 81
`Semiconductor v. Greenthread
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`9
`
`
`
`Instituted Grounds
`
`Ground
`I
`
`II
`III
`IV
`
`IPR2023-01243 (U.S. Patent 10,510,842)
`35 U.S.C. §
`Claims
`1-18
`103(a)
`
`Prior art
`Kawagoe (EX1007)
`
`1-3, 5-11, 13-18
`1-18
`1-3, 5-11, 13-18
`
`103(a)
`103(a)
`103(a)
`
`Wieczorek (EX1006), Wolf (EX1008)
`Kawagoe, Gupta (EX1014)
`Wieczorek, Wolf, Gupta
`Petition, Paper 2 (-01243), 13-62
`Institution Decision, Paper 31 (-01243)
`
`BAKER BOTTS
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`Greenthread Ex. 2087, p. 10 of 81
`Semiconductor v. Greenthread
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`10
`
`
`
`Instituted Grounds
`
`Ground
`
`I
`
`II
`
`IPR2023-01244 (U.S. Patent 11,121,222)
`35 U.S.C. §
`Claims
`
`44
`
`44
`
`103(a)
`
`103(a)
`
`Prior art
`
`Payne (EX1005)
`
`Sakai (EX1006), Kawagoe (EX1007)
`Institution Decision, Paper 32 (-01244)
`
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`Greenthread Ex. 2087, p. 11 of 81
`Semiconductor v. Greenthread
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`11
`
`
`
`THE PRIOR ART DISCLOSES ALL
`CLAIM LIMITATIONS
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Greenthread Ex. 2087, p. 12 of 81
`Semiconductor v. Greenthread
`
`
`
`Kawagoe (U.S. Patent No. 6,043,114) [EX1007]
`
`BAKER BOTTS
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Greenthread Ex. 2087, p. 13 of 81
`Semiconductor v. Greenthread
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`Kawagoe, EX1007 (-01242,
`-01243, -01244)
`
`13
`
`
`
`Kawagoe has a graded dopant concentration to aid carrier movement
`
`“Thus, the impurity concentration of the
`p-well 6p is given such a gradient that it
`is gradually lowered in the depthwise
`direction from the surface of the epitaxial
`layer 2E, so that the influence to be
`caused by the carriers (or electrons) due
`to the (cid:303)-ray is lowered. Specifically, the
`electrons produced by the (cid:303)-ray are
`attracted to the substrate body 2S by
`that
`concentration gradient and
`prevented from entering the p-well 6p
`so that the soft errors can be reduced in
`case the MIS memory of the DRAM or
`the like is formed in the p-well 6p.”
`
`Kawagoe, EX1007, 16:2-11K EX1007 16 2 11
`
`
`Kawagoe, EX1007, Figs. 17, 23 (annotated)
`
`BAKER BOTTS
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`Greenthread Ex. 2087, p. 14 of 81
`Semiconductor v. Greenthread
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`Petition, Paper 2 (-01242), 18-23;
`Reply, Paper 62 (-01242), 1-15;
`Petition, Paper 2 (-01243), 25-32;
`Reply, Paper 61 (-01243), 1-15;
`Petition, Paper 2 (-01244), 48-67;
`Reply, Paper 61 (-01244), 1-13
`14
`
`
`
`Kawagoe discloses the elements of Claim 1 (’222 Patent)
`
`1. A VLSI semiconductor device, comprising:
`
`a substrate of a first doping type at a first doping level having a surface;
`
`a first active region disposed adjacent the surface with a second doping
`type opposite in conductivity to the first doping type and within which
`transistors can be formed;
`
`a second active region separate from the first active region disposed
`adjacent to the first active region and within which transistors can be
`formed;
`
`transistors formed in at least one of the first active region or second
`active region;
`
`at least a portion of at least one of the first and second active regions
`having at least one graded dopant concentration to aid carrier
`movement from the first and second active regions towards an area of
`the substrate where there are no active regions; and
`
`at least one well region adjacent to the first or second active region
`containing at least one graded dopant region, the graded dopant region
`to aid carrier movement from the surface towards the area of the
`substrate where there are no active regions, wherein at least some of
`the transistors form digital logic of the VLSI semiconductor device.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Greenthread Ex. 2087, p. 15 of 81
`Semiconductor v. Greenthread
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`Petition, Paper 2 (-01242), 6-28
`15
`
`CMOS
`
`BAKER BOTTS
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`
`
`Kawagoe discloses the elements of Claim 1 (’842 Patent)
`
`1. A semiconductor device, comprising:
`
`a substrate of a first doping type at a first doping level having
`first and second surfaces;
`
`a first active region disposed adjacent the first surface of the
`substrate with a second doping type opposite in conductivity to
`the first doping type and within which transistors can be
`formed;
`
`a second active region separate from the first active region
`disposed adjacent to the first active region and within which
`transistors can be formed;
`
`transistors formed in at least one of the first active region or
`second active region; and
`
`at least a portion of at least one of the first and second active
`regions having at least one graded dopant concentration to aid
`carrier movement from the first surface to the second surface
`of the substrate.
`
`Petition, Paper 2 (-01243), 13-32
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Greenthread Ex. 2087, p. 16 of 81
`Semiconductor v. Greenthread
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`16
`
`CMOS
`
`BAKER BOTTS
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`
`
`Wieczorek (U.S. Patent App. Pub. 2003/0183856) [EX1006/1038]
`
`BAKER BOTTS
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Greenthread Ex. 2087, p. 17 of 81
`Semiconductor v. Greenthread
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`Wieczorek, EX1006 (-01242,
`-01243), EX1038 (-01244)
`17
`
`
`
`Wieczorek has a graded dopant concentration to aid carrier movement
`
`Wieczorek, EX1006 (-01242, -01243),
`EX1038 (-01244), Fig. 1b/2b (annotated)
`
`BAKER BOTTS
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Petition, Paper 2 (-01242), 55-62;
`Reply, Paper 62 (-01242), 15-16;
`Petition, Paper 2 (-01243), 50-54;
`Reply, Paper 61 (-01243), 15-16;
`Greenthread Ex. 2087, p. 18 of 81
`Semiconductor v. Greenthread
`Petition, Paper 2 (-01244), 51-52, 56
`
`18
`
`
`
`Wolf (Silicon Processing for the VLSI Era) (2000) [EX1008]
`
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`Greenthread Ex. 2087, p. 19 of 81
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`Wolf, EX1008 (-01242,
`-01243, -01244)
`19
`
`
`
`Wolf: active regions include source, drain, and channel of transistor
`
`“The top surface of the body consists of
`active or transistor regions as well as
`passive or (field) regions. The active
`regions are those in which transistor
`action occurs; i.e., the channel and the
`heavily doped source and drain regions.”
`
`Wolf, EX1008B (01242), pp. 300Wolf EX1008B (01242) pp 300
`
`Wolf, EX1008 (-01242, -01243, -01244), pp. 299-300 (annotated)
`
`BAKER BOTTS
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Petition, Paper 2 (-01242), 13-16, 45, 52-58;
`Reply, Paper 62 (-01242), 15-19;
`Petition, Paper 2 (-01243), 19-23, 40, 46-52;
`Reply, Paper 61 (-01243), 15-19;
`Petition, Paper 2 (-01244), 15-18, 45-48
`Greenthread Ex. 2087, p. 20 of 81
`Semiconductor v. Greenthread
`20
`
`
`
`Wieczorek/Wolf discloses the elements of Claim 1 (’222 Patent)
`
`1. A VLSI semiconductor device, comprising:
`
`a substrate of a first doping type at a first doping level having a surface;
`
`a first active region disposed adjacent the surface with a second doping
`type opposite in conductivity to the first doping type and within which
`transistors can be formed;
`
`a second active region separate from the first active region disposed
`adjacent to the first active region and within which transistors can be
`formed;
`
`transistors formed in at least one of the first active region or second
`active region;
`
`at least a portion of at least one of the first and second active regions
`having at least one graded dopant concentration to aid carrier
`movement from the first and second active regions towards an area of
`the substrate where there are no active regions; and
`
`at least one well region adjacent to the first or second active region
`containing at least one graded dopant region, the graded dopant region
`to aid carrier movement from the surface towards the area of the
`substrate where there are no active regions, wherein at least some of
`the transistors form digital logic of the VLSI semiconductor device.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Greenthread Ex. 2087, p. 21 of 81
`Petition, Paper 2 (-01242), 45-63
`Semiconductor v. Greenthread
`
`21
`
`CMOS
`
`BAKER BOTTS
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`
`
`Wieczorek/Wolf discloses the elements of Claim 1 (’842 Patent)
`
`CMOS
`
`1. A semiconductor device, comprising:
`
`a substrate of a first doping type at a first doping level having
`first and second surfaces;
`
`a first active region disposed adjacent the first surface of the
`substrate with a second doping type opposite in conductivity to
`the first doping type and within which transistors can be
`formed;
`
`a second active region separate from the first active region
`disposed adjacent to the first active region and within which
`transistors can be formed;
`
`transistors formed in at least one of the first active region or
`second active region; and
`
`at least a portion of at least one of the first and second active
`regions having at least one graded dopant concentration to aid
`carrier movement from the first surface to the second surface
`of the substrate.
`
`Petition, Paper 2 (-01243), 40-54
`
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`Greenthread Ex. 2087, p. 22 of 81
`Semiconductor v. Greenthread
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`22
`
`
`
`Payne (U.S. Patent 4,684,971) [EX1005] (-01244)
`
`BAKER BOTTS
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`Greenthread Ex. 2087, p. 23 of 81
`Semiconductor v. Greenthread
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`Payne, EX1005 (-01244)
`23
`
`
`
`Payne has a graded dopant concentration to aid carrier movement
`
`BAKER BOTTS
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`Payne, EX1005 (-01244), Figs. 10, 11 (annotated)
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Greenthread Ex. 2087, p. 24 of 81
`Semiconductor v. Greenthread
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`Petition, Paper 2 (-01244), 18-40
`Reply, Paper 61 (-01244), 13-16
`24
`
`
`
`Payne discloses the elements of Claim 44 (’222 Patent)
`
`44. A CMOS Semiconductor device, comprising:
`
`a surface layer;
`
`a substrate;
`
`an active region including a source and a drain, disposed on one
`surface of the surface layer;
`a single drift layer disposed between the other surface of the
`surface layer and the substrate, the drift layer having a graded
`concentration of dopants extending between the surface layer
`and the substrate, the drift layer further having a first static
`unidirectional electric drift field to aid the movement of carriers
`from the surface layer to an area of the substrate where there
`are no active regions; and
`
`at least one well region disposed in the single drift layer, the well
`region having a graded concentration of dopants and a second
`static unidirectional electric drift field to aid the movement of
`carriers from the surface layer to the area of the substrate where
`there are no active regions.
`
`BAKER BOTTS
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`Greenthread Ex. 2087, p. 25 of 81
`Semiconductor v. Greenthread
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`25
`
`Petition, Paper 2 (-01244), 11-40
`
`
`
`Sakai (U.S. Patent 4,907,058) [EX1006] (-01244)
`
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`Greenthread Ex. 2087, p. 26 of 81
`Semiconductor v. Greenthread
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`Sakai, EX1006 (-01244)
`26
`
`
`
`Sakai has twin double wells and high-to-low dopant concentrations
`
`“At first, a P-well region 2 and an N-well region 3
`each having an impurity concentration of 1015
`to 1016 atoms per cm3 and a depth of 3 to 5μm
`are formed in a surface portion of an N- or P-
`silicon substrate 1 […]. Next, a P-type impurity and
`an N-type impurity are implanted […], and the
`impurity-doped
`regions
`thus obtained are
`extended […] to form a shallow P-well region 4
`and a shallow N-well region 5 each having a depth
`of 0.5 to 1.5μm and an impurity concentration of
`5x1016 to 1018 atoms per cm3[.]”
`Sakai, EX1006 (-01244), 5:56-6:4
`
`Sakai, EX1006 (-01244), Fig. 10D (annotated)
`
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`Greenthread Ex. 2087, p. 27 of 81
`Semiconductor v. Greenthread
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`Petition, Paper 2 (-01244), 10, 48-57
`27
`
`
`
`Sakai/Kawagoe discloses the elements of Claim 44 (’222 Patent)
`
`Sakai
`
`Kawagoe
`
`44. A CMOS Semiconductor device, comprising:
`
`a surface layer;
`
`a substrate;
`
`an active region including a source and a drain, disposed on one
`surface of the surface layer;
`a single drift layer disposed between the other surface of the
`surface layer and the substrate, the drift layer having a graded
`concentration of dopants extending between the surface layer
`and the substrate, the drift layer further having a first static
`unidirectional electric drift field to aid the movement of carriers
`from the surface layer to an area of the substrate where there
`are no active regions; and
`
`at least one well region disposed in the single drift layer, the well
`region having a graded concentration of dopants and a second
`static unidirectional electric drift field to aid the movement of
`carriers from the surface layer to the area of the substrate where
`there are no active regions.
`
`BAKER BOTTS
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`Greenthread Ex. 2087, p. 28 of 81
`Semiconductor v. Greenthread
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`28
`
`Petition, Paper 2 (-01244), 40-67
`
`
`
`Gupta (U.S. Patent 6,163,877) [EX1014] (-01242, -01243)
`
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`Greenthread Ex. 2087, p. 29 of 81
`Semiconductor v. Greenthread
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`Gupta, EX1014
`(-01242, -01243)
`29
`
`
`
`Gupta: a plurality of “transistors” or “devices” was well known
`
`“FIG. 4 is an illustration of a layout style
`known as one dimensional layout style.
`[…] Referring to FIG. 4, one dimensional
`layout 402
`includes
`two horizontal
`diffusion rows for the placement of P and
`N
`transistors. PMOS
`transistors are
`placed
`in top row 418 and NMOS
`transistor are placed in bottom row 420.
`If
`two
`adjacent
`transistors
`have
`electrically equivalent terminals, they are
`abutted so as to share a diffusion area,
`forming a chain.”
`
`
`
`Gupta, EX1014 (-01242, -01243), 4:12-43G t EX1014 ( 01242 01243) 4 12 43
`
`Gupta, EX1014 (-01242, -01243), Fig. 4 (annotated)
`
`BAKER BOTTS
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`Greenthread Ex. 2087, p. 30 of 81
`Semiconductor v. Greenthread
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`Petition, Paper 2 (-01242), 78-83;
`Petition, Paper 2 (-01243), 62-67
`30
`
`
`
`Silverbrook (U.S. Patent 6,614,560) [EX1042] (-01242)
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`BAKER BOTTS
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`Greenthread Ex. 2087, p. 31 of 81
`Semiconductor v. Greenthread
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`Silverbrook,
`EX1042 (-01242)
`31
`
`
`
`Silverbrook: “CMOS image sensors” were well known
`
`“Turning now to FIG. 15, there is shown
`an example layout of the Image Capture
`and Processing Chip (ICP) 48. The Image
`Capture and Processing Chip 48 provides
`most of the electronic functionality of the
`camera with the exception of the print
`head chip. The chip 48 is a highly
`integrated System. It combines CMOS
`image Sensing,
`analog
`to digital
`conversion, digital
`image processing,
`DRAM Storage, ROM, and miscellaneous
`control functions in a Single chip.”
`
`Silverbrook, EX1042 (-01242), 6:41-49Silverbrook EX1042 ( 01242) 6:41 49
`
`BAKER BOTTS
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`Silverbrook, EX1042 (-01242), Fig. 15
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Greenthread Ex. 2087, p. 32 of 81
`Semiconductor v. Greenthread
`
`Petition, Paper 2 (-01242), 83-85
`32
`
`
`
`THE “AID CARRIER MOVEMENT”
`LIMITATIONS ARE OBVIOUS
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Greenthread Ex. 2087, p. 33 of 81
`Semiconductor v. Greenthread
`
`
`
`The prior art gradients aid carrier movement
`
`• No dispute that there are
`graded dopant concentrations
`in Kawagoe, Wieczorek, and
`Payne
`• No dispute that graded dopant
`concentrations generate
`electric fields
`• No dispute that electric fields
`provide a force in the same
`direction of field
`
`BAKER BOTTS
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Greenthread Ex. 2087, p. 34 of 81
`Semiconductor v. Greenthread
`
`Reply, Paper 62 (-01242), 1-2;
`Reply, Paper 61 (-01243), 1-2;
`Reply, Paper 61 (-01244), 1-2
`34
`
`
`
`No dispute that graded concentrations generate electric fields
`
`PO’s Expert
`EX1052 (-01242, -01243,
`-01244), 83:24-84:23
`
`E
`
`E
`
`BAKER BOTTS
`
`E
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Q. And how does the -- how does a
`graded dopant concentration relate to
`the idea of carrier drift?
`A. There's really two things that go on,
`but one is the gradient of a charge
`causes electrical -- electrical
`field…The gradient is just the first
`derivative. It's a differential operator.
`So it's the slope, literally. So the slope
`of the charge densities are
`proportional to the field that's
`given off. So this charge gradient
`produces a field which will act upon
`other charge particles.
`
`Greenthread Ex. 2087, p. 35 of 81
`Semiconductor v. Greenthread
`
`Reply, Paper 62 (-01242), 1-3;
`Reply, Paper 61 (-01243), 1-3;
`Reply, Paper 61 (-01244), 1-2
`35
`
`
`
`Petitioner’sPetitioner s
`
`Expert
`EX2058 (-01242, -01243,
`-01244), 165:17-166:6
`
`No dispute that electric fields “provide a force … aiding
`movement in the direction of the force”
`Q. And you relied on that logic, […] if slope is downward, then carriers
`will move; is that basically the logic that you applied? […]
`A. No. As I've said, if [...] you have a downward-sloping graded
`dopant concentration, we know from the basic physics that that will
`lead to an electric field and that will create a force, which tends to
`move the carriers.
`Q. So when you talk about in paragraph 49 a concentration gradient
`aiding carrier movement or impeding carrier movement, that cannot
`be agnostic to the direction of the carrier movement, right?
`A. Well, a field will provide a force in a direction aiding -- direction --
`aiding movement in the direction of the force. That's just basic
`physics.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`Reply, Paper 62 (-01242), 1-2, 8-9; Reply, Paper 61 (-01243), 1-2, 9;Reply Paper 62 (-01242) 1-2 8-9; Reply Paper 61 (-01243) 1-2 9;
`Greenthread Ex. 2087, p. 36 of 81
`Semiconductor v. Greenthread
`Reply, Paper 61 (-01244), 1-2, 8
`
`PO’s Expert
`EX1052 (-01242, -01243,
`052 ( 01242 0124
`-01244), 108:15-23
`
`BAKER BOTTS
`
`36
`
`
`
`It should be undisputed that these forces “aid carrier movement”
`
`E
`
`E
`
`Petitioner’sPetitioner
`
`Expert
`
`
`“[W]e know from the basic physics that that “[W
`
`will lead to an electric field and that will create w
`a force, which tends to move the carriers.”
`EX2058 (-01242, -01243,
`-01244), 165:17-166:6
`
`PO’s Expert
`
`E
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`“[A] field will provide a force in a
`direction aiding -- direction -- aiding
`ddddddddddddddddddddddddddddddddddddii
`movement in the direction of the force.
`That's just basic physics.”
`
`EX1052 (-01242, -01243,
`-01244), 108:15-23
`Reply, Paper 62 (-01242), 1-2, 8-9; Reply, Paper 61 (-01243), 1-2, 9;
`Reply, Paper 61 (-01244), 1-2, 8
`Greenthread Ex. 2087, p. 37 of 81
`37
`Semiconductor v. Greenthread
`
`BAKER BOTTS
`
`
`
`It should be undisputed that these forces “aid carrier movement”
`Kawagoe: “electrons produced by the (cid:303)-ray are attracted to
`the substrate body 2S by that concentration gradient and
`prevented from entering the p-well”
`
`Kawagoe, EX1007 (-01242,
`-01243, -01244), 16:2-11,
`Figs. 17, 23
`
`ee-
`
`ee-
`
`ee-
`
`Petition, Paper 2 (-01242), 24-28;
`POR, Paper 47 (-01242), 16;
`Reply, Paper 62 (-01242), 7-10;
`Petition, Paper 2 (-01243), 27-32;
`POR, Paper 46 (-01243), 16-17;
`Reply, Paper 61 (-01243), 7-10;
`Petition, Paper 2 (-01244), 57-67;
`POR, Paper 46 (-01244), 16-17;
`Reply, Paper 61 (-01244), 6-9
`
`Kawagoe, EX1007 (-01242,
`Greenthread Ex. 2087, p. 38 of 81
`-01243, -01244), Figs. 17, 23
`Semiconductor v. Greenthread
`
`38
`
`BAKER BOTTS
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Greenthread’s flawed arguments about “aid carrier movement”
`
`What Greenthread says:
`“Graded” does not mean “aided”
`
`•
`
`• Direction of slope insufficient to show “aided”
`
`Why this argument fails:
`
`• Petitioner has shown that specific gradients in Petitioner has shown that specific grad
`prior art would aid carrier movement
`
`• The patents do not disclose any required slope The patents d
`
`magnitude
`
`• External hypothetical forces may overcome
`internal electric field from gradient
`
`• The prior art does not have such external The prio
`
`forces
`
`• Kawagoe does not address carriers in the
`active region
`
`• The same electric field in Kawagoe extends The same electric field in Kawag
`
`through active region and well
`
`BAKER BOTTS
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Greenthread Ex. 2087, p. 39 of 81
`Semiconductor v. Greenthread
`
`Reply, Paper 62 (-01242), 1-15;
`Reply, Paper 61 (-01243), 1-15;
`Reply, Paper 61 (-01244), 1-13
`39
`
`
`
`PETITIONER HAS NEVER ARGUED
`“GRADED” MEANS “AIDED”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Greenthread Ex. 2087, p. 40 of 81
`Semiconductor v. Greenthread
`
`
`
`The prior art gradients aid movement in the claimed direction
`Claim 1 (842): at least one graded
`dopant concentration to aid carrier
`movement from the first surface to
`the second surface of the substrate
`
`E
`
`E
`
`E
`
`E
`
`E
`
`E
`
`BAKER BOTTS
`
`Claim 1 (222): at least one graded dopant
`concentration to aid carrier movement
`from the first and second active regions
`towards an area of the substrate where
`there are no active regions
`
`Claim 44 (222): a first static unidirectional electric
`drift field to aid the movement of carriers from
`the surface layer to an area of the substrate
`where there are no active regions
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Reply, Paper 62 (-01242), 1-4; Petition, Paper 2 (-01242), 18-28, 55-60;
`Greenthread Ex. 2087, p. 41 of 81
`Reply, Paper 61 (-01243), 1-4; Petition, Paper 2 (-01243), 25-32, 50-54;
`Semiconductor v. Greenthread
`Reply, Paper 61 (-01244), 1-4; Petition, Paper 2 (-01244), 24-40, 57-67
`
`41
`
`
`
`Petitioner applied plain and ordinary meaning
`
`“[T]he impurity concentration of the p-
`well 6p is given such a gradient that it is
`gradually lowered in the depthwise
`direction from the surface of the
`epitaxial layer 2E, so that the influence to
`be caused by the carriers (or electrons)
`due to the (cid:303)-ray is lowered. Specifically,
`the electrons produced (cid:69)y the (cid:303)(cid:16)ray
`are attracted to the substrate body 2S
`by that concentration gradient … so
`that the soft errors can be reduced in
`case the MIS memory of the DRAM or
`the like is formed in the p-well 6p.”
`Kawagoe, EX1007 (-01242, -01243, -01244), 16:2-11, Figs. 17, 23
`
`Petition at 22: “In light of the above, Kawagoe satisfies elements [1.5]/[21.5]/[39.5]/[41.5]/[42.5]
`under Patent Owner’s plain meaning construction of the ‘to aid carrier movement’ term.”
`BAKER BOTTS
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Reply, Paper 62 (-01242), 1-4; Petition, Paper 2 (-01242), 22, 27, 59;
`Reply, Paper 61 (-01243), 1-4; Petition, Paper 2 (-01243), 29, 53;
`Greenthread Ex. 2087, p. 42 of 81
`Reply, Paper 61 (-01244), 1-4; Petition, Paper 2 (-01244), 32, 39, 60, 66
`Semiconductor v. Greenthread
`
`42
`
`
`
`Petitioner addressed an alternative construction
`Petition at 22: “Kawagoe also satisfies these claim elements under Intel’s alternative proposed
`construction that the term means ‘to sweep the carriers from the first and second active
`regions towards an area of the substrate where there is no active region.’” (Cleaned up)
`“Kawagoe’s Figure 17 illustrates a
`downward-sloping graded dopant
`concentration and Applicant
`represented to Patent Office during
`prosecution of the parent ‘195 Patent
`that a downward-sloping graded
`dopant concentration was known in
`the prior art to create an ‘inherent
`‘built-in’ unidirectional electric
`field’ that sweeps carriers down into
`the substrate (where there are no
`active regions)[.]”
`
`BAKER BOTTS
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Reply, Paper 62 (-01242), 1-4; Petition, Paper 2 (-01242), 22-23, 27-28, 59-60;
`Reply, Paper 61 (-01243), 1-4; Petition, Paper 2 (-01243), 29-30, 53-54;
`Reply, Paper 61 (-01244), 1-4; Petition, Paper 2 (-01244), 32-33, 39-40, 60-61, 66-67
`Greenthread Ex. 2087, p. 43 of 81
`Semiconductor v. Greenthread
`EX1016 (-01242, -01243), EX1020 (-01244), 289-290
`
`43
`
`
`
`NO SPECIFIC SLOPE IS REQUIRED
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Greenthread Ex. 2087, p. 44 of 81
`Semiconductor v. Greenthread
`
`
`
`The claims do not require any specific dopant gradient
`
`Claim 1 (222): at least a portion of at least one
`of the first and second active regions having at
`least one graded dopant concentration to aid
`carrier movement from the first and second
`active regions towards an area of the substrate
`where there are no active regions
`
`Claim 1 (842): at least a portion of at least one
`of the first and second active regions having at
`least one graded dopant concentration to aid
`carrier movement from the first surface to the
`second surface of the substrate
`
`Claim 44 (222): the drift layer further having
`a first static unidirectional electric drift field
`to aid the movement of carriers from the
`surface layer to an area of the substrate
`where there are no active regions
`
`BAKER BOTTS
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Reply, Paper 62 (-01242), 5-9; Petition, Paper 2 (-01242), 18-28, 55-60;
`Reply, Paper 61 (-01243), 5-9; Petition, Paper 2 (-01243), 25-32, 50-54;
`Reply, Paper 61 (-01244), 4-8; Petition, Paper 2 (-01244), 24-40, 57-67
`Greenthread Ex. 2087, p. 45 of 81
`Semiconductor v. Greenthread
`45
`
`
`
`The specification only refers to a “relative slope”
`
`“The relative slope of the donor concentration throughout the
`base creates a suitable aiding drift electric field.”
`
`Fig. 5B
`
`
`’222 Patent, EX1001 (-01242, -01244), 2:60-64’222 Patent, EX1001 (-01242, -01244), 2:60-64
`’842 Patent, EX1002 (-01243), 3:1-4
`
`Fig. 5C
`
`’222 Patent, EX1001 (-01242, -01244), Fig. 5B
`’842 Patent, EX1002 (-01243), Fig. 5B
`
`’222 Patent, EX1001 (-01242, -01244), Fig. 5C
`’842 Patent, EX1002 (-01243), Fig. 5C
`
`BAKER BOTTS
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Greenthread Ex. 2087, p. 46 of 81
`Semiconductor v. Greenthread
`
`Reply, Paper 62 (-01242), 6;
`Reply, Paper 61 (-01243), 6;
`Reply, Paper 61 (-01244), 5
`
`46
`
`
`
`Applicant later explained “relative slope” means one side being
`“relatively lower than the other side”
`Related U.S. Patent Application 17/728,588 – Response filed
`August 1, 2024
`
`“The structure of this transistor is described as having
`a base region that has a donor dopant concentration
`gradient that is high at the emitter-base junction and
`low at the base-collector injunction. This corresponds
`to the label ‘B’ in Figure 1. This is defined as a
`‘relative slope’ which means nothing more than
`the fact that one-side is relatively lower than the
`other side. This slope is defined "throughout" the
`base to create ‘a suitable aiding drift electric field, to
`help the holes (p-n-p transistor) traverse from the
`emitter to collector.”
`
`BAKER BOTTS
`
`EX1054 (-01242, -01243, -01244), 12;
`EX1055 (-01242, -01243, -01244), 5
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`EX1054 (-01242, -01243, -01244), 12;
`EX1055 (-01242, -01243, -01244), 5
`Reply, Paper 62 (-01242), 6;
`Reply, Paper 61 (-01243), 6;
`Reply, Paper 61 (-01244), 5
`
`47
`
`Greenthread Ex. 2087, p. 47 of 81
`Semiconductor v. Greenthread
`
`
`
`Example dopant concentrations for emitter-collector gradient
`are irrelevant
`
`“The relative doping concentrations of emitter
`and collector
`regions varies from 1018 to
`1020/cm3, whereas the base region is 1014 to
`1016/cm3
`depending
`on
`the
`desired
`characteristics of the BJT. In graded base p-n-p
`transistors, the donor dopant concentration may
`be 10 to 100x at the emitter-base junction,
`relative to the base-collector junction 60 (1x). The
`gradient can be linear, quasi linear, exponential
`or complimentary error function. The relative
`slope of the donor concentration throughout the
`base creates a suitable aiding drift electric field,
`to help the holes (p-n-p transistor) transverse
`from emitter to collector.”
`
`’222 Patent, EX1001 (-01242, -01244), Fig. 1
`
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