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)

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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. 16 (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 Unsigned 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 Unsigned Page 48 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 Unsigned Page 49

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