Ex parte POLETTO et al. - Page 5




          Appeal No. 1996-3113                                                        
          Application 08/099,243                                                      



          the transistor and substrate.  In their reply brief,                        
          Appellants argue:                                                           
                         Most representations of bipolar transistors                  
               show only three connections to the bipolar                             
               transistor: emitter, base, and collector.  (In some                    
               cases multiple-emitter or multiple-collector devices                   
               have been proposed, and multiple collectors                            
               naturally imply the possibility of multiple separate                   
               collector currents.)  The types of current which are                   
               considered in Tatsuya are only the usual three,                        
               namely emitter, collector, and base currents                           
               (although there are two collector current                              
               components, from the two collectors).                                  
                         By contrast, the present application                         
               extensively discusses, and shows how to use, a                         
               FOURTH type of current component, namely the                           
               substrate current.  As extensively discussed in the                    
               application (and also shown by the expert                              
               testimony), substrate current is not the same as                       
               emitter current, base current, or collector current.                   
               (Emphasis added.)                                                      
               Appellants have also submitted a Rule 132 Declaration                  
          from Richard A. Blanchard stating:                                          
                         It is NOT TRUE that “Tatsuya’s leaked                        
               current to the substrate is continually                                
               monitored/generated as the potential across the                        
               sensing resistor 26 and that potential is compared                     
               with the forward voltage drops of the diode 28.”                       
               Resistor 26 measures auxiliary collector current,                      
               NOT substrate current.  Tatsuya deals ONLY with the                    
               three basic types of current which are used in                         
               normal circuit connections of bipolar transistors,                     
               namely base, collector and emitter currents.  The                      
               current application deals with a fourth type of                        
               current, the substrate current. (Paragraph No. 12.)                    
                                          5                                           





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