STC.UNM v. Intel Corporation

Filing 159

MOTION STC.UNMS MOTION FOR CONSTRUCTION OF THE TRANSFERRING STEPS IN CLAIM 6 by STC. UNM. (Attachments: # 1 Exhibit A - Excerpts from B. Smith Testimony)(Pedersen, Steven)

Exhibit A
[Excerpts from] Bruce Smith Deposition Testimony

BRUCE SMITH - SEPTEMBER 14, 2011

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEW MEXICO

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---oOo---

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STC.UNM,

)
Plaintiff,
)
) Case No.: 10-CV-01077-RV-DWS.
vs.
)
Volume 1
)
Pages 1 to 211
INTEL CORPORATION,
)
Defendant.
)
________________________)

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DEPOSITION OF BRUCE SMITH

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Wednesday, September 14, 2011

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Reported by:

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HEIDI BELTON, CSR, RPR, CRR, CCRR

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Certified Shorthand Reporter No. 12885

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_________________________________________________________

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JAN BROWN & ASSOCIATES

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WORLDWIDE DEPOSITION & VIDEOGRAPHY SERVICES

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701 Battery Street, 3rd Floor, San Francisco, CA 94111

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[phone] or [phone]

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1
JAN BROWN & ASSOCIATES

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or

[phone]

BRUCE SMITH - SEPTEMBER 14, 2011

16:47:58

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the impact of doing a damascene process with photoresist

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still on the wafer.

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like.

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BY MR. STADHEIM:

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Q.

Yeah.

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A.

Again photoresist --

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THE WITNESS:

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MR. HUR:

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THE WITNESS:

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certainly be a part, but the polishing process wouldn't

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have the photoresist in place.

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BY MR. STADHEIM:

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Q.

I'm sorry.

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A.

The polishing process would --

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Q.

No.

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A.

A damascene process, part of that processing

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sequence would include photoresist.

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damascene process photoresist would be in place, but to

THE WITNESS:

Q.

I'm afraid I haven't looked into

We can step through that if you

What do you need to do; just think about it?

Or what do you need to do?
A.

Your question was could you perform a

damascene process with photoresist still on the wafer.

MR. HUR:
scope.

Object to the form.

Outside the

Incomplete hypothetical.
Photoresist --

Go ahead.

Sorry.

Photoresist on the wafer would

Would you repeat that?

I mean the whole thing, what you said.

So part of the

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JAN BROWN & ASSOCIATES

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BRUCE SMITH - SEPTEMBER 14, 2011

16:48:57

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complete that damascene process you wouldn't do the

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polishing with the photoresist in place.

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precise.

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I'm referring to lines 42 to 44.

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"Transferring said first pattern and second pattern into

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said substrate using a combined mask including parts of

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said first mask layer and said second photoresist."

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damascene process, could you do it while there was still

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photoresist on the wafer?

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etching.

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process -- let me say it that way.

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the damascene process could certainly be carried out

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using the transfer step that you just read, which would

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have the photoresist in place.

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BY MR. STADHEIM:

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MR. HUR:

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Outside the scope.

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Q.

So you couldn't complete the -- let me be more
Look at claim 6 of the patent, please.

And

And I'll read it.

If you were to do that procedure using a

MR. HUR:

Object to the form.

Incomplete hypothetical.
THE WITNESS:

Q.

Vague.

Outside the scope.
This damascene process involves

If the etching step of the damascene
The etching step of

Could you electroplate copper with resist

still on the wafer?
Objection; incomplete hypothetical.
Object to the form.

THE WITNESS:

There are certain parts of the
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