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
15
exhibit.
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(Exhibit No. 35 - STC's Responses to Intel.)
17
Q
We have marked as 35 a document that is
18
entitled STC's Responses to Intel Corporation's
19
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
24
25
responses?
A
I believe this information came from the
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Page 30
1
A
I have to go into some of the paper we
2
explain that. You know the difference between
3
linear and nonlinear. Linear is just straight line
4
and so resist as a function of intensity has some
5
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?
11
12
13
A
That is the gift of people who made the
resist, yes.
Q
When you use the term here higher
14
harmonics, is that the same as higher spatial
15
frequencies.
16
A
I believe so.
17
Q
So, am I right, then, that the
18
nonlinearities of resist can itself provide for
19
higher spatial frequencies in a pattern?
20
21
MR. VOGT: Object; lack of foundation.
A
If you go back to the previous one, it
22
says, nonlinearities add higher harmonics but cannot
23
provide denser patterns. So, you cannot extend --
24
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 --
3
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
9
examples; right?
10
A
Uh-huh. Yeah. Okay.
11
Q
So, let's take those one at a time. The
12
first one says "Add patterns in sacrificial layer,
13
(spatial frequency multiplication.)"
14
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
20
21
multiplication?
A
I don't remember. The terminologies are
22
different. It has been such a long time. Some
23
people call it doubling. Some people call it
24
extension, multiplication. If I have to say
25
anything, I'll just say that it means you can add
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