STC.UNM v. Intel Corporation

Filing 112

DECLARATION re 110 Brief of Brian Ferrall by Intel Corporation (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9)(Atkinson, Clifford)

1

Q

You can answer if you can.

2

A

I have, yes.

3

Q

What sort of devices?

4

A

This is shot key barriers.

5

Q

Shot key, okay?

6

A

Yeah.

7

Q

Anything else?

8

A

Diodes.

9

Q

Anything else?

10

A

That is my best recollection.

11

Q

During your time at UNM, have you ever

12
13

created any working integrated circuit?
A

14

No.
MR. FERRALL: Let's mark this as the next

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exhibit.

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(Exhibit No. 35 - STC's Responses to Intel.)

17

Q

We have marked as 35 a document that is

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entitled STC's Responses to Intel Corporation's

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Second Set of Interrogatories. You see that?

20

A

Yes.

21

Q

Have you ever seen this document?

22

A

Yes.

23

Q

Did you provide some information for these

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25

responses?
A

I believe this information came from the

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1

A

I have to go into some of the paper we

2

explain that. You know the difference between

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linear and nonlinear. Linear is just straight line

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and so resist as a function of intensity has some

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nonlinear behavior. That is what it is saying.

6
7

Q

You don't claim to have developed resist

with nonlinear properties yourself?

8

A

Good God, no.

9

Q

That existed long before you came to CHTM;

10

right?

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12
13

A

That is the gift of people who made the

resist, yes.
Q

When you use the term here higher

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harmonics, is that the same as higher spatial

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frequencies.

16

A

I believe so.

17

Q

So, am I right, then, that the

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nonlinearities of resist can itself provide for

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higher spatial frequencies in a pattern?

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MR. VOGT: Object; lack of foundation.
A

If you go back to the previous one, it

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says, nonlinearities add higher harmonics but cannot

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provide denser patterns. So, you cannot extend --

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you cannot change the period with nonlinearity.

25

Q

Right. But my point is the nonlinearities

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1

of resist cannot provide a denser pattern but it can

2

add --

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4
5
6

A

Spatial frequencies, yes. That is what

the square pattern shows, yeah.
Q

So, now, if you can go, I think, two pages

forward to the page ending in 9027.

7

A

Okay.

8

Q

And the last main bullet point lists two

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examples; right?

10

A

Uh-huh. Yeah. Okay.

11

Q

So, let's take those one at a time. The

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first one says "Add patterns in sacrificial layer,

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(spatial frequency multiplication.)"

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15
16
17

A

This is talking about additional spatial

frequencies in a sacrificial layer.
Q

Sacrificial layer being, for example, a

layer of silicon dioxide?

18

A

Silicon nitride, yes.

19

Q

What is meant by spatial frequency

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21

multiplication?
A

I don't remember. The terminologies are

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different. It has been such a long time. Some

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people call it doubling. Some people call it

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extension, multiplication. If I have to say

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anything, I'll just say that it means you can add

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