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Georgia campaign law faces challenge from Libertarian, Green parties
Multiple judges have ruled leadership committees are likely illegal because they give an unfair advantage to some candidates. But the law is still on the books.
Cove handed season-long registration embargo
Cove Rangers are "considering all available options" after having a season-long registration ban imposed upon them by the SPFL over rule breaches.
Health department can’t change Oklahoma gender designations on birth certificate, court rules
State law has never allowed changes to the sex designation on Oklahoman’s birth certificates, the state’s high court ruled.
September Monthly Review: Health MCP Guy?
For all the time I spend talking about APIs and data exchange, this newsletter has had embarrassingly little interoperability of its own. It’s old-school SaaS, baby - UI or bust. Not all of that is my fault! Substack, for all its popularity, is (as mentioned before) really frustrating as my system of record. The primary user it optimizes towards is the reader, whose attention feeds the app, the Notes feed, and the recommendation network that Substack is actually selling. Health API Guy is a reader-supported publication. To receive new posts and support my work, consider becoming a free or paid subscriber. Subscribe They’re falling into the same trap that Medium once sprinted into, albeit at a much more glacial speed. Younger generations may not remember (or never knew) it, but Medium once lured publications like The Ringer and Signal v. Noise onto its platform, only to lose them as it rebuilt itself around a paywall and an algorithmic feed. Substack’s original pitch circa 2020 was the antidote (you own your list), but every new feed feature chips away at it. I get it: writers are generic supply in the eyes of the Substack product team. Generic supply follows demand, so the consistent pressure on the PMs is to generate demand, which leads to every product cycle going toward discovery (Notes, recommendations, the app, live video). The end result lackluster author tools (laggy and broken analytics are truly crippling) all despite the premium price point. The archive is where it crosses from authorial gripes to actual reader impact, though. Across Substack and LinkedIn, I’ve published 1,218 posts and nearly 900,000 words since 2018. Substack’s native search can see only the 464 posts that live on Substack, and even there it’s woefully inadequate at surfacing relevant content (even for the guy who wrote it)! Readers have the same problem, writ large. Ask the Archive Fixing search (for both my readers and my own use) turned out to be extremely non-trivial, unfortunately: There’s no public API for readers to access content RSS exists for new content notification, but it only carries the 20 most recent posts and cuts paid ones off at the preview The only Substack MCP is an admin tool for analytics The export exists for authors, but it’s painfully awkward and slow. So I built something to work around that: the Health API Guy MCP. It’s a private MCP server holding the full text of everything I’ve written across Substack and LinkedIn. Add it to Claude or ChatGPT as a connector and you can ask things like: It pairs keyword search (for acronyms and case names, of which we have many) with semantic search. Every post is also labeled by topic, form, and court case, so you can pull a lawsuit’s (or multiple cases’) entire docket across Substack and LinkedIn in one query: Hail, Healthapiguyhydra This is also a bit of me eating my own cooking. I’ve spent the year arguing that headless healthcare is arriving and that developers want primitives over abstractions. Last week in Hail, Benihydra, I watched Salesforce plug its platform into Claude and bet that the records underneath outlive whatever interface sits on top: Salesforce must believe that the Hydra’s immortal head is the records, permissions, and business logic (in that they will survive whatever happens to the interface). It felt a bit hypocritical to keep my own archive behind a Substack search bar. The archive is the body. Substack is one head, and now whatever tool you might use is another. Will the EHRs follow my lead? Probably not imminently, but one can hope! Why Founding Members Only The MCP is available to Founding Member subscribers. A few reasons: It costs money and time to run. Hosting, the database, Clerk usage and AI compute for search and labeling are significant operational costs (that increase with usage). Substack gives me no way to automate access. There’s no API to check whether someone is a paid subscriber, so every user is manual operations for now. It’s a beta. We’ll need to improve things and parts will break. I’d rather they break for a small group of dedicated readers who will tell me about it. The Founding tier deserved a real benefit. Until now it was mostly a generous tip. Now it comes with something. If you’re already a Founding Member, reply to this email with the address you’d like provisioned. If you’re not and want in, upgrade here. Larger teams (such as companies) can get access too: group subscriptions at the Founding tier come with the group discount. The admin for the subscription can reply with the list of addresses to provision. Get 20% off a group subscription Pricing Founding membership is now a flat $200 a year, replacing the old suggested $150 that readers could adjust. Existing Founding Members will have access grandfathered in at their previous rate. Month in Review Articles Published Make Networks Dumb Again (Sep 11): AI is making old analog networks cheaper to use and flooding them with machine traffic in the process. A plea for agent-native rails with the intelligence at the endpoints, and for Washington to drag them to ubiquity. Interoperability, Unbuttoned (Sep 29): Interoperability is a series of workflows in a trenchcoat, and this post finally takes the trenchcoat off. A color-coded map shows which provider workflows went digital, which are fragmented, and which still run on fax. Video Content Antitrust’s System of Record Problem (Sep 3): The FTC’s investigation into Epic prompted a ninety-minute webinar, now posted with chapters and a smoothed transcript. We get into why market definition, missing B2B share data, and the SSNIP test leave antitrust poorly suited to systems of record, plus why information blocking may be doing more than any pending lawsuit. The Information Exchange: Cerner Milking Edition (Sep 18): This was so fucking fun. Ryan Tucker, Ryan Brickner, Brad Thorson, and I try an Around the Horn format, complete with points, penalties, and a mute button. We debate whether Oracle Health is dead, who would actually buy Cerner (IBM enters the chat), p(Doom), and why the front desk still hands you a clipboard. Regulatory Ask Not What Your Network Can Do (Sep 23): CDC’s RFI on public health data intermediaries lists use cases already served, unevenly, by eCR, lab reporting, IZ Gateway, and syndromic surveillance. The real opportunity sits in one question about AI: a network that can handle the next emergency without another interface project. Court cases Particle v. Epic: The Naughty Schoolteacher (Sep 4): After a summer-long vigil, the answer on Epic’s early summary judgment bid is two paragraphs and a remedial assignment. Particle advances to the next grade, and market definition gets another year of discovery. The Epic Discovery Files (Sep 8): Texas’s motions to compel arrive with a 251-page appendix of requests, objections, and meet-and-confer letters with Cravath. Inside: Epic using generative AI for document review, denied interoperability requests in scope, and Noerr-Pennington raised against lobbying discovery. Epic v. Health Gorilla: “Working as Designed” (Sep 9): Epic wants nothing to do with the data breach MDL, and explaining why puts fresh discovery on the public docket. The spiciest allegation: Health Gorilla told GuardDog to scrub its law firm business from its website instead of cutting off access. Veeva v. Epic: Legal Bypass Surgery (Sep 15): Veeva asks the Wisconsin Supreme Court to skip the Court of Appeals, while law professors and three policy groups line up as amici. Meanwhile, Epic’s lawyers apologize for another round of citation errors, including a quote that never existed. Texas v. Epic: Behind the Black Bars (Sep 17): The court portal served up Epic’s unredacted filings, revealing a $5 million document review budget and the AI workflow behind it. Also inside: the 200-plus company names Texas wants searched, and one very expensive Zoom invitation. OpenEvidence v. Doximity: Consequences Will Follow (Sep 25): OpenEvidence tells the court it will not comply with a discovery order, and its own lawyers at Quinn Emanuel say they won’t defend the choice. Add years of Slack reported unrecoverable, and Rule 37 sanctions come into view. Health Tech Keeps Choosing Violence (Sep 28): Doximity moves to end OpenEvidence’s case, Epic asks Texas to show its work, and a sleepy Audacious Inquiry patent fight sprouts antitrust and information blocking counterclaims. The main event is a long-sealed Cognizant v. Infosys ruling that hints where system of record antitrust claims can survive. EHRs One Verb for Oracle Health (Sep 14): Oracle’s earnings call quantifies every data center to the decimal point, while Oracle Health gets a single verb: “accelerate.” Panning the few healthcare mentions turns up an agentic care management system, a research-to-care ledger play, and the question of whether healthcare gets Larry’s patience. Epic’s Forretress Under Siege (Sep 30): Judy Faulkner tells a panel Epic paused hundreds of projects to harden its software and calls it a “shame,” while a spokesperson insists the roadmap hasn’t changed. Project Glasswing, a Pokémon-branded QAN sprint, and a trove of Jodel grievances reconcile the two Epics and preview the Jevons paradox coming for all software. Industry Analysis Scanning for a Network (Sep 1): Scan.com raises $220M to build the imaging network labs never got, speedrunning Zocdoc’s consumer-to-B2B pivot. Its wedge to network density may be the most American one available: personal injury litigation. The Front Desk Wants the Damn Whole Building (Sep 16): Hello Patient buys Converse Health, pushing its AI front desk into referrals, chart work, and prior auth. The copilot categories keep blurring, and your distribution partner is still your final boss. Cross-industry Comparisons A Different Patchwork Quilt (Sep 10): Healthcare loves to envy open banking, but the US version has no mandate, a toll booth at Chase, and data quality problems of its own. The grass isn’t greener; it’s another American patchwork quilt, and perhaps a worse one. Hail, Benihydra (Sep 21): Salesforce brings its platform into Claude, Slack, and its own agent, inviting the interfaces that might replace it. Cut off one head and more grow back, so long as the records underneath stay put. Living on A Trade Secret Prayer (Sep 22): Six credit unions are suing Fiserv, the Epic of core banking, by claiming their own member records as trade secrets. Banking has no Cures Act, so its lawyers reach for legal alchemy that healthcare has already tried. Other News None this month External Media Nabla Accelerate NYC: I kicked off fall conference season at Nabla’s Accelerate event in New York, where Delphine Groll opened by asking the room to picture the company it wants to become and the one it doesn’t. I liked her framework of bureaucracy, fear, and ego as the blockers. I also love vendor conferences/events in general - different vibe than industry biggies. Healthcare 101 with Nikhil Krishnan: I briefly guest lectured Out-Of-Pocket’s Healthcare 101 class. Appreciated Nikhil’s takeaways cover whether AI doctors can query HIEs, why healthcare’s data-liberation rules beat most industries’, and the hi-res graphic is in the comments. HCN: Epic Probed by the FTC: I joined the HCN guys to talk through the FTC’s investigation into Epic. Cedric’s new hairdo was an unexpected plot twist. The episode also covers MFN drug pricing, healthcare M&A and Eli Lilly’s acquisition streak. Fall Conferences: At eHealth Exchange’s Annual Meeting in Austin on Oct 27, I’ll moderate a panel on the tensions between AI, HIEs, and timely patient access with Jean Ross (Primary Record), Therasa Bell (Kno2), Byron Crowe (Doctronic), and Michael Marchant (Freenome). Here’s the rest of my schedule if you want to meet up: CommonWell (Redwood Shores, CA): Oct 13-14 Will be participating in a fun Jeopardy event Open@Epic (Madison, WI): Oct 20-23 Will be enjoying Verona, Willy Street, and other local adventures eHealth Exchange and Sequoia Project (Austin, TX): Oct 27-29 Yeehaw HLTH (Vegas): Nov 15-18 Groundhog Day, Venetian Edition RSNA (Chicago): Nov 30-Dec 2 See me at “Governing AI in Breast Imaging: What Health Systems Are Actually Doing” Digital Health Counsel 2026 AI Summit (Seattle): December 2-3 Will likely be speaking to a bunch of lawyers about information blocking Posts I Liked ChatGPT’s Epic integration: game changer or nothing burger?: Joshua Liu, MD offers five thoughts on OpenAI’s Epic launch, starting from the point that it rides the same open APIs available to anyone. He argues read-only access leaves ordering to Art and the ambient startups, and asks why HCA is piloting it alongside Commure. He’s sorta a must-follow at this point - consistently excellent, thought-provoking takes. Epic, Lilly, and the Discovery pass: Seth Chaney reads Epic’s first major Discovery deal (with Eli Lilly), as well as its revised developer terms on commercial displays, as the pipe finally opening between EHRs and pharma. Life sciences and health continue to collide. Scott Rossignol on EHR payer platforms and ePA fees: Scott argues the top ambulatory EHR vendors are turning the prior auth mandate into a per-member-per-year toll on payers, for an API whose operating cost has nothing to do with covered lives. His fix is two lines of regulatory text: put the CRD/DTR/PAS certification criteria in the Base EHR definition, and bring payer-facing ePA connectivity under § 170.404’s cost-based fee rules. It’s a good solution. Health API Guy is a reader-supported publication. To receive new posts and support my work, consider becoming a free or paid subscriber. Subscribe
Tiny image sparks big backlash in Nikon photo contest
Dr Ning Xu denies he broke the rules of Nikon's annual Small World In Motion contest.
Sec. 338(h)(10) elections in business acquisitions
A Sec. 338(h)(10) election can allow parties to a business acquisition to treat a statutory stock purchase as a deemed asset sale for income tax purposes, potentially benefiting both the buyer and the seller. This article discusses the election’s mechanics, eligibility rules, and tax consequences, as well as practical deal considerations.
9th Circuit rejects arguments Prop. 211 law disclosing political donations is unconstitutional
There's nothing unconstitutional about a 2022 Arizona law requiring people be informed of exactly who is spending money on campaign ads designed to influence their votes, a federal appeals court ruled Wednesday.
Punish Man City this season, say other club chiefs
Manchester City's punishment for breaching Premier League rules should be handed down before the end of this season, senior football figures tell BBC Sport.
Health department can’t change Oklahoma gender designations on birth certificate, court rules
State law has never allowed changes to the sex designation on Oklahoman’s birth certificates, the state’s high court ruled.
Transformative new robot that can fly, sail, and swim autonomously
ALBATROSS plays fast and loose with nature’s rules.
New Medicaid eligibility rules begin to take effect Thursday
The ongressional Budget Office projects the changes will push about 16% of people currently on Medicaid or CHIP off those programs
Andy Burnham 'really concerned' if Man City owners sell up after rule breaches
The prime minister compares the allegations against Man City to the plight of his own club Everton.
Debunking political fearmongering over data centers
Americans can meet this new challenge as we always have, leveraging our embrace of the free-market, entrepreneurial spirit, and institutional respect for private property and the rule of law — but …
Microsoft Fabric is where AI agents learn how the business works
Microsoft is turning Fabric into the context layer for AI agents, feeding Power BI semantic models into Copilot by default and adding ontologies with rules.
Pep Guardiola gives backing to Man City after guilty verdict: ‘We will get through this’
Pep Guardiola has broken his silence after Manchester City were found guilty of the majority of the 115 charges against them, reiterating his backing of the owners and the chairman. An independent commission, which was appointed following a four-year investigation to rule over the charges which stretch between 2009 and 2018, ruled that the current Premier League leaders had "sham contracts" arranged for a number of its commercial partners, finding that their income over eight seasons was “hugely overstated by over £830m”. The club vehemently deny the breaches with chief executive Ferran Soriano branding the process a “Premier League conspiracy theory” in a message to players and staff, while City have confirmed they will appeal against the ruling.
Hillsborough school board weighs new rules on partisan politics on campus
The debate began after Robert F. Kennedy Jr. visited a Hillsborough school in August.
Newly proposed federal rules would have “disastrous” impact on Medicaid, insurance funding, state says
Proposed federal rules could cut hundreds of millions of dollars annually for Medicaid and also impact health insurance programs, state says.
Democratic lawmakers call for protections over third country deportations after ‘indefensible’ court ruling
Lawmakers say ‘Congress must step in’ after supreme court ruled to allow Trump officials to resume deporting people where their lives could be in danger
Manchester City stars now fearing Premier League relegation
Manchester City players are worried that they face relegation, after the Premier League’s confirmation of the guilty verdicts from their financial rule breach hearing.Photo by Carl Recine/Getty Imag...
Manchester City players fear Premier League relegation
The Premier League confirmed on Tuesday that Manchester City had been found guilty of 114 of the 115 charges against them. Those charges relate to serious breaches of financial rules, dating all the w...
Dr Mike Israetel's Golden Rules for Muscle Growth – The Science-Backed Way to Actually Get Bigger
The exercise scientist also details how to spot bad science
Tyler T. Ray: The business case for the Roadless Rule
Granite Outdoor Alliance urges businesses to oppose rescinding the Roadless Rule, arguing White Mountain landscapes underpin New Hampshire jobs, customers and i...
After failed execution, health workers say Tennessee's rules flout medical ethics
As another death row inmate’s execution arrives, doctors and nurses in Tennessee say they want medical professionals removed from the execution process. They’ve also joined defense attorneys and nine Republican state lawmakers in demanding a moratorium on the death penalty and an overhaul of the state’s execution methods.
LeBron James Discusses Key to 76ers Building Chemistry
On media day, it's time to stake your claim. LeBron James' first rule of business is to improve the chemistry on the 76ers.
Upstate bridge death ruled suicide, prompts mental health discussions
A man’s death at a Greenville County bridge has been ruled a suicide, sparking conversations about mental health challenges and available resources.
Mamdani's pied-à-terre tax rollout was botched, judge rules
New York City plans to place a tax on multi-million-dollar second homes. A judge ruled Tuesday that its rollout needs to be redone.
Appellate court rejects new rules sought by Brooklyn Democrats
The outgoing chair, Assembly Member Rodneyse Bichotte Hermelyn, unexpectedly bowed out of the race on Monday night.
'Chaos and uncertainty'
If you had the impression that the saga over Manchester City's 115 charges was almost over, think again. Two years since the hearing began, the Premier League has confirmed that City have been found guilty of all charges related to breaches of its financial rules between the 2009-10 and 2017-18 seasons. City have said they are "innocent of the accusations made by the Premier League" and would pursue "appeal avenues open to it, on the basis that the opinion contains clear material errors, of law, principle and fact, and is unsafe."
Calciopoli to Spygate – Previous heavy penalties to scare City fans
Manchester City have been found guilty of all charges related to breaches of Premier League financial rules between 2009-10 and 2017-18 by an independent commission. With the issue of sanctions being addressed separately in a further hearing, the Press Association recalls some of the heaviest penalties handed out in the history of sport.
Man City respond to Premier League verdict: ‘We are innocent’
Manchester City have responded defiantly after an independent commission found the club guilty of serious breaches of the Premier League’s financial rules.The Cityzens insist they are innocent and w...
Ten Kustom shares will become one as it seeks to meet Nasdaq's $1 minimum bid-price rule.
The stated outstanding-share count drops from 6,506,860 to 650,686, subject to rounding up fractional shares. Split-adjusted trading is expected Oct. 1.
NFL considers rule change after Eagles exploit kickoff loophole
FellowNeko/Depositphotos Eagles’ kickoff tactic sparks NFL rule debate The Eagles have sparked fresh discussion around an unusual kickoff tactic involving a holder and no tee. The approach helped Philadelphia create a different angle for kicker Jake Elliott during its Week 2 win over Tennessee. The technique has raised questions about how the NFL’s 2026 kickoff…
Pleasant View rejects changes regarding data centers and adult-themed business, passes adoption of new roads and rules regarding decorative street signs
The Town of Pleasant View Board of Mayor and Aldermen voted not to approve two zoning amendments on first reading at their Sept. 14 meeting, sending proposals on data centers and adult-oriented businesses back to the drawing board for more work and consideration. Ordinance 26-08 would have restricted data centers to areas zoned C4, which
Ex-Trump prosecutor Smith will tell senators he won't 'be silenced' by threats of prosecution
The former Justice Department special counsel who brought two federal indictments against President Donald Trump will tell lawmakers he “will not be silenced by continued threats of prosecution” from the Trump administration and believes the rule of law is being threatened like never before
Ex-Trump prosecutor Smith will tell senators he won't 'be silenced' by threats of prosecution
The former Justice Department special counsel who brought two federal indictments against President Donald Trump will tell lawmakers he “will not be silenced by continued threats of prosecution” from the Trump administration and believes the rule of law is being threatened like never before.
Tariff challengers take Trump back to court: ‘Rinse and repeat’
President Trump hopes the third time will be the charm as his latest round of tariffs heads to court this week. The Supreme Court already ruled Trump can’t invoke an emergency statute to impose his…
Pochettino regrets lack of 'sporting justice' for his ex-Tottenham team amid Man City charges saga
U.S. coach Mauricio Pochettino expressed sadness at an apparent failure of “sporting justice” in his response to reports that Manchester City has been found guilty of almost all of the 115 charges leveled against the club for alleged financial breaches. The alleged rule-breaking by City took place between 2009-18, during which period Pochettino was manager of Tottenham and turned the London team into a challenger for titles in English soccer despite operating on a relatively small budget. The Premier League has yet to officially confirm the verdict that, according to several media outlets, has been passed down by an independent commission following a long-running case.
Confusion and Angst Follow State's Early Rollout of Medicaid Work Rules
In most states, people with Medicaid coverage will have to prove they’re working, volunteering, or studying starting Jan. 1. But Montana put the rules into effect early, and they’re sowing uncertainty and anxiety.
After Failed Execution, Health Workers Say State’s Rules Flout Medical Ethics
The death penalty is legal in 27 states, and lethal injection is the primary method. That means involving medical professionals to store, test, and inject the drugs. After a botched execution in Tennessee, doctors and nurses there say medical professionals need to be removed from the process completely.
Senate passes Protect College Sports Act with decisive vote
The Protect College Sports Act, which would set national rules for NIL deals, the transfer portal and more, was passed by the Senate on Monday night.
The Senate passes the Protect College Sports Act, but the bill's future is unclear
The bill's supporters, which include the NCAA, say it will tame what they call a "Wild West" era of college sports as litigation chips away at long-held rules around eligibility, transfers and pay.
Senate passes sweeping college sports package
It is a massive piece of legislation, setting national rules on everything from NIL compensation to conference realignment.
Senate approves sweeping college sports bill on athlete pay, transfers and NCAA rules
WASHINGTON – The Senate approved a bipartisan college sports overhaul that would codify athlete revenue sharing, regulate NIL and transfers, and give the NCAA limited antitrust protection. Critics say it undercuts athletes’ leverage.
Little Havana business owners call for e-scooter safety rules after crash leaving 1 dead, 1 in critical condition
Trump Officials Revise Biden-Era Sex Discrimination Rules
The change follows a court ruling barring Title IX from protecting L.G.B.T.Q. people and has angered advocates for sexual assault survivors.
Ranking Member Markey: SBA Administrator Loeffler, Trump Administration are Refusing to Answer to America’s 36+ Million Small Businesses and Workers, Leaving Main Street Behind
Loeffler canceled her scheduled Sept. 30 appearance before the Senate Small Business Committee, has not appeared before SBC in more than a year (Washington, September 28) – Ranking Member Edward J. Markey (D-Mass.) today released the following statement after Small Business Administration (SBA) Administrator Kelly Loeffler canceled her scheduled Wednesday appearance before the Small Business and Entrepreneurship Committee. Administrator Loeffler has not appeared before the committee in more than a year and has consistently refused to provide substantial answers to committee members in person, in writing, or via requested briefings. In June, Ranking Member Markey led every Democratic member of the committee in calling on Administrator Loeffler to appear before the committee to answer for the Trump administration’s cruel attacks on American small businesses, entrepreneurs, and workers. The Democratic lawmakers still have not received a response from Administrator Loeffler. “It is unacceptable that Administrator Loeffler chose to cancel her appearance before the Senate Small Business and Entrepreneurship Committee. The Trump administration is once again ignoring the more than 36 million American small businesses, entrepreneurs, and workers who drive our economy and enrich our communities by refusing to answer questions about this administration’s reckless economic policies. It has been more than a year since Administrator Loeffler has appeared before our committee and answered questions from both Democrats and Republicans. Since then, the Trump administration’s attacks on Main Street have only worsened. “Small businesses are facing record high gas and diesel prices, skyrocketing healthcare costs, and never-ending uncertainty from Trump’s trade war with the world. Trump has terrorized Main Streets across the country with violent ICE raids, destroying families, communities, and local economies. Meanwhile, Administrator Loeffler and the Trump SBA have been in a Witness Protection Program, ignoring the Pain on Main Street that they have created. They have chosen to make drastic cuts to SBA funding and essential, bipartisan programs, including the closure of the SBA office in Springfield and removal of the SBA office from Boston; directly attacked immigrant small business owners and destroyed the promise of the American Dream; and proposed shortsighted small business size rules that would benefit billion-dollar businesses over actual small businesses. “It’s clear that Administrator Loeffler, President Trump, and their CEO billionaire buddies want to turn the Small Business Administration into the Big Business Administration, tear down our economy, and abandon Main Street. If that is indeed this administration’s goal, Administrator Loeffler must answer to the millions of small businesses, workers, and families in Massachusetts and across the country that this administration is leaving behind.” ###
The Latest: Trump administration loosens fuel economy standards
The Trump administration has released new fuel economy standards that relax regulatory requirements for automakers to control pollution from gasoline-powered cars and light trucks. The new rules were released Monday
The Latest: Trump administration loosens fuel economy standards
The Trump administration has released new fuel economy standards that relax regulatory requirements for automakers to control pollution from gasoline-powered cars and light trucks. The new rules were released Monday
As work requirements kick in for Medicaid, some states are taking a tougher stance
At least six states will require documentation that individuals are too sick to meet Medicaid work requirements kicking in next year. The rules are stricter than what the federal government is requiring.
Bobby Kotick’s lawyers sent me a bad email (and later apologized)
The message I had received was unsettling—for a moment. Then it was just really confusing. Back on January 20 of this year, at 5:15pm ET, I received an email with the subject line “Legal Correspondence re Bobby Kotick.” It was from the law firm Clare Locke, a firm I’d heard had been emailing reporters in recent years about their coverage of Kotick, the former, longtime CEO of Activision Blizzard. The letter was threatening. A lawyer from the firm introduced themselves as “defamation counsel to Bobby Kotick.” They issued a “demand” that I “correct” a Game File article I’d published a week prior. The article that had irked them had been a scoop of sorts. I’d written about a a 2022 lawsuit brought by a Swedish pension fund, AP7, over Microsoft’s purchase of Activision Blizzard. The suit wasn’t news, but I was first to review and report about Kotick’s extensive pushback to the fund’s claims. The pension fund’s core contention was that the sale had been rushed by Kotick to avoid the consequences of sexual misconduct scandals swirling around the company in 2021. (He’d not been accused of misconduct himself in those suits, to be clear.) As I wrote at the time, Kotick had denied the allegations of the rushed sale. Beyond that, Kotick used a December 2025 reply to the Swedish fund’s lawsuit to assign blame for those workplace scandals, the bad press and even for the AP7 lawsuit. I’d found Kotick’s arguments novel and newsworthy. Across nearly 3,000 words, I explained Kotick’s take: that a Swedish gaming company was behind the Swedish fund’s lawsuit (the Embracer group; they denied it); that the Microsoft-Activision deal was not rushed and was secured at what Kotick felt history had proven to be an optimal price for shareholders; that he believed a conspiracy of people at unions government agencies, PR firms and the media had spun up claims of widespread workplace misconduct at Activision Blizzard in 2021. The article gave context for all of this, letting readers assess the claims and weigh their credibility. As I’d later write to Kotick’s lawyers: I would be surprised if you could point to any news article about Bobby Kotick in the last five years that has spent more of its wordcount articulating his point of view. He is welcome to do an interview with Game File any time. Nonetheless, there they were in my inbox that Tuesday evening: Clare Locke, the law firm that secured a $787.5 million settlement from Fox News over false statements about voting machines. They were emailing me, threatening that failure to comply with their demand could support a claim of “actual malice,” a legal standard for libel. Unless… Unless, they said, I added a key paragraph to my article. This was a paragraph that I already knew Kotick’s lawyers had been emailing reporters about for at least a year, and it was a paragraph that was already in my article. The paragraph they wanted is from a 2023 settlement that California’s Civil Rights Department struck with Activision Blizzard. The settlement had closed a two-year-old lawsuit over alleged sexual discrimination at the game maker. The paragraph basically said that claims of systemic or widespread sexual harassment—or of execs like Kotick tolerating such behavior—had never been proven. I’d already seen proof that Kotick’s lawyers had pushed for the settlement’s language to be added to reports about 2021 sexual discrimination and misconduct lawsuits brought against Activision Blizzard by California and, separately, by the U.S. federal government (both suits were since settled). I knew that Kotick and his lawyers felt that the California settlement language should be mentioned in the same breath as references to an article he hated and denied, a November 2021 Wall Street Journal article claiming Kotick knew “for years” of sexual misconduct at Activision Blizzard. So, in the Game File article that Clare Locke emailed me about, in the interest of ensuring I was being fair and balanced regarding the person I was covering, I had already included the following excerpt from the California settlement [emphasis added in bold]: (Kotick has repeatedly pushed back against that November article in the Wall Street Journal, citing among other things, language from a court-approved consent decree as part of Activision’s 2023 $54 million settlement over the California suit. It states: “no court or any independent investigation has substantiated any allegations that: there has been systemic or widespread sexual harassment at Activision Blizzard [or] that Activision Blizzard senior executives ignored, condoned, or tolerated a culture of systemic harassment, retaliation, or discrimination.”) On the evening of January 20, I was incredulous. How do you write a four page legal threat about a week-old article and miss this? While scrambling to also make my kids dinner, I wrote a lengthy reply to Clare Locke’s lawyers, basically asking them to cool it with the threats and to start making sense. In part, I wrote: I hope you can understand why I am having trouble understanding what you’re asking for, when the statement you’re demanding to see in Game File’s article already appears in Game File’s article. Actual malice, as you know, refers to a reckless disregard for the truth. I’m not sure what your argument is when my article already states your client’s position. Here is where I should remind you, the reader, that I am an independent journalist. I publish on Substack, and have availed myself of the Substack Defender program that provides writers on the platform with legal support. But I’m no Wall Street Journal or New York Times, nor even IGN or GameSpot when it comes to such things as, well, having a legal department. There are more fun things for me to do as an independent journalist than writing back to a powerful law firm representing a very rich person. On the evening of January 20th, I was just trying to cook some pasta, broccoli and chicken nuggets for hungry twins. Nevertheless, I wrote back to them. Two hours later, I got a reply. Summarizing: A lawyer for Clare Locke said they’d “reviewed an incomplete version” of my article and they “apologize for the confusion.” (My guess: Someone didn’t read past the piece’s paywall, even though they’d had a full week to scrounge up the funds to do so. What I’d published above the paywall was balanced, as was what came after.)1 That was almost that, but something about the situation bothered me. The letter had been marked “confidential.” I hadn’t agreed to that, and I disliked the idea that powerful people on the beat that I cover would act like they could unilaterally control what I might tell my readers about. On the morning of the 21st, having already gotten the powerful law firm to back off, I oh-so-wisely re-approached them with just one more thing. I thanked them for clearing things up the night before but noted that I’d never agreed to keep their letter confidential. I’m all for agreeing with a source to keep things off the record, but that’s the thing. We have to agree. You can’t just declare it. I’m not bound by that. I wrote to Clare Locke’s lawyer and said, in part: I trust the matter is resolved. It was disappointing to have to spend less time with my kids last night in order to address your legal letter. Family time’s precious. I will add, for clarity’s sake, that, while your letter stipulated that it was confidential, I did not agree to those terms. In the future, should you wish to communicate with me confidentially, I am happy to agree to classifying our communication as “off the record” prior to the actual communication—as is standard with any professional journalist. The firm’s lawyer replied, not directly addressing the confidentiality issue but asserting that the matter was resolved. Why I didn’t write about this until now In May, I told this story on an episode of Simon Parkin’s podcast My Perfect Console, but I held off on sharing it directly with Game File readers. I held off to avoid stepping on the toes of another reporter, the journalist Mikhail Klimentov. He’d interviewed me in the spring of 2025 about an investigation he was working on regarding Bobby Kotick lawyers pressing the media to add the California settlement language to stories referencing the 2021 lawsuits. And about how some outlets had changed their stories and how some simply deleted them. Initially, I was a third-party source for Klimentov’s reporting, providing on-the-record context about the state of the games media. I’d heard about the letters but hadn’t put the time into pursuing the story. I thought it was interesting, and I was glad he was covering it. When the outlet that Klimentov was going to run his reporting in dropped the story, I began talking to him about potentially publishing his reporting on Game File. This was tentative. Then, in January, when I got my own Clare Locke letter, I told Klimentov that I didn’t think it would make sense for me to publish him, not with me now being part of the story. I had my own version of this situation to tell. But I wished him well and said I’d refrain from telling my tale until he could get his reporting out there. Last Friday, Klimentov finally ran his investigation, in a nearly 48-minute video report for People Make Games. It covers various Clare Locke letters, how media outlets reacted to them and what to make of all this. His video weighs the merits of Kotick’s request and looks at some of the articles that were changed (one of which had a glaring error). I highly recommend watching it: (Note, I did some editorial consulting for a People Make Games video last year but nothing to do with this report.) While many outlets haven’t left any public evidence that they updated their Kotick coverage at Kotick’s counsel’s request, at least one has. Back in October 2025, the mainstream outlet Reuters applied the most transparent article update I’ve seen. On the 3rd of the month, they published an article about the state of the Swedish pension fund’s lawsuit. Days later, they added this: In an October 7 letter sent after publication of this article, Kotick’s defamation counsel disputed claims of widespread harassment at Activision. “Not a single investigation, court finding, verdict, or ruling ever concluded that there was any merit” to the allegations of widespread harassment at Activision, Tom Clare and Nick Brechbill of Clare Locke wrote. I’ve never added a statement to my article on Game File, because none was needed. Not for fairness’ sake, nor to meet any demands of Kotick’s lawyers. I’ve nevertheless wanted to be transparent with Game File readers. If someone powerful is questioning my reporting, is threatening a lawsuit over it… if that threat is part of a pattern involving other games media outlets and if, in my case, the whole thing ran into a ridiculous ditch, I want you to know about it. I also share this as a real example of how I handle threats to Game File. I stand up for my own reporting, even when it’s not comfortable to do so. (In that same category of standing up for the work I do, I’ll point to an incident in late August. Asocial media post I published to X/Twitter regarding reporting I did about Take Two and GTA VI was hit by bogus copyright claim by a firm working for the publisher. I pushed back and got it reversed; even while a bigger games media outlet let themselves be censored. This is the other reason I’m sharing this story: To emphasize that dealing with threats from powerful people is one of the costs of covering the video game industry independently and as fearlessly as possible. This is where you come in. Your support, through free and paid subscriptions (sign up here!), can help me keep doing that. It can ensure that I’ve got the back-up I need. And it can help make fiascoes like this even less of a worry, so I can spend my evenings dealing with more important things, such as making sure I steam the kids’ broccoli just right. 1 That pension fund lawsuit I wrote about in January has all but gone away. In May, the fund and Activision Blizzard owner Microsoft agreed to settle. Lawyers for the fund brokered a $250 million settlement for former Activision Blizzard shareholders. In the settlement, the fund’s lawyers changed their rhetoric. Where once they’d questioned the meaning of the California settlement language, they adopted a version of it for themselves. Several weeks ago, while seeking to get a court to sign off on the terms of the settlement, they proposed their fee for their work in the case: $60 million.
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Intel Panther Lake Teardown, 18A, BSPD, GAAFET, SemiAnalysis STEEL
Panther Lake debuts the first commercial implementation of backside power delivery (BSPDN), introduces Intel’s first iteration of gate-all-around (GAA) transistors, and showcases their advanced packaging capabilities with its Foveros-S assembly. With Panther Lake, Intel’s manufacturing arc has shifted from nebulous roadmaps to shipped silicon, a significant milestone on their long road back to competitive semiconductor manufacturing. To evaluate the extent of Intel’s comeback, we tore down Panther Lake. The SemiAnalysis STEEL teardown lab breaks down advanced datacenter and AI hardware. To learn more about our pipeline or to commission a teardown, contact sales@semianalysis.com. WE’RE HIRING: Architecture, floorplan, packaging, manufacturing, and labs experts. Opportunities from system to transistor and everywhere in between. Check out our Careers page. Our teardown traces 18A from its four-sheet RibbonFETs (Intel’s marketing name for GAAFETs) and gate stacks through contacts, frontside and backside wiring, and the bonded carrier. We explain how these material and integration choices improve gate control and reduce resistance, while adding capacitance, thermal resistance, and process complexity. Our measurements put Panther Lake’s 18A compute logic and TSMC N3E GPU logic at similar logic density. However, 18A does not lead TSMC N3P, N2 or Samsung SF2 in peak density. Panther Lake’s CPU cores are incremental updates, and the high-end GPU still uses TSMC N3E. Panther Lake assembles one compute tile, one GPU tile, and one I/O tile atop a passive base tile using Intel’s Foveros-S advanced packaging. Both compute tile variants use Intel 18A. The Xe3 GPU options are a 4-core GT1 tile on Intel 3 and a larger 12-core GT2 tile on TSMC N3E. Both I/O tile variants use TSMC N6. [1], [2] Our analysis centers on the PTL-U compute tile, both the 4-core and 12-core GPU tiles, as well as the 12-lane I/O tile. In conventional chips, power and signal are routed through the same frontside metal stack towards the device frontend. Power rails consume scarce routing resources near the transistors, while tall via stacks carry VDD and VSS from the coarse upper wires to local rails. Backside power delivery (BSPD) moves the main power network behind the transistor layer, to the backside, separating it from frontside signal routing. We covered BSPD and its impacts in 2024. [3], [4], [5] Intel’s BSPD implementation, branded as “PowerVia”, routes power through dedicated backside metals to nano-TSVs, which connect those rails to local source/drain (S/D) contacts. Implementing that separation requires Intel to build the interconnect stacks from both sides of the wafer. The frontside comprises the M0-M14 signal stack, while the backside comprises the BM0-BM5 power stack. M0 and BM0 are closest to the transistors. The nano-TSVs connect the two sides, but Intel patterns and etches each via from the front after forming the contacts. A narrow via runs from the side of the contact deep into the silicon substrate. Intel then completes the frontside signal metal stack, bonds the wafer to a carrier, flips it and removes the original substrate until the buried via tips are exposed. The backside metal stack is then deposited directly on the revealed vias. The nano-TSV and backside-via profiles taper in opposite directions because Intel forms them from opposite sides of the wafer. The transistor structures form the FEOL. Local contacts and nano-TSVs connect them to the wiring. M0 begins the frontside interconnect stack. The silicon carrier remains attached above the frontside interconnects. It supports the device wafer during substrate removal and backside processing and remains part of the finished chip’s thermal path. PowerVia removes the main power distribution from the congested frontside metals, routing supply through shorter and wider backside wires. Its lateral landing still occupies area in the standard cell, so it recovers less cell area than a direct backside contact. [3] Nano-TSVs beside the logic devices carry VDD or VSS from the backside power network, while signal connections continue upward through the frontside metals. Backside Interconnects Samsung SF2 data is included for comparison to Panther Lake’s within this article. SF2 is the incumbent GAA foundry node but lacks BSPD, serving as a useful reference to evaluate 18A. A full teardown of Samsung’s S26 products, processed on SF2, will be shared soon.Nanosheet-cut EDS comparison. The PowerVia supply path runs from the backside Cu rails through Mo-lined W nano-TSVs to the local transistor contacts. In this cross section, the tapered connection spans roughly 150 nm from the contact level to BM0. The Ta liner confines Cu and promotes adhesion to the surrounding stack; the AlOₓ etch stop controls the next dielectric etch above the rail. Dielectric beneath the ribbons electrically separates the devices from the backside wiring and removes the conducting silicon body below the channel. [6] AlOₓ serves as an etchstop (ES), enabling endpointing and protecting the underlying layers. Low-volatility aluminum fluoride reaction products resist the fluorinated plasma, allowing a thin AlOₓ film to protect the metal while the surrounding low-k dielectric is removed. [6], [7]. While the BM0 and layers above the M1 lines show double AlOx layers, Our SMIC N+3 teardown showed single AlOₓ layers. SMIC uses a simpler local AlOₓ substack, while the remaining cap and etch sequence provide the required landing protection. So why double layers? The closely spaced AlOₓ doublets provide two protected endpoints in the etch sequence. Intel documents an AlOₓ/SiN/AlOₓ stack that explains the benefit. The main dielectric plasma etch stops on the first AlOₓ film; a selective wet clear opens that film; a second plasma etch removes the intermediate SiN and stops on the second AlOₓ film. The final wet clear exposes the metal landing surface. SiN is the intermediate dielectric in Intel’s published example. [8] The second stop protects the metal through a cap breakthrough. Wide openings can etch faster than narrow ones, and etch depth varies across the wafer. Metal under an early-clearing opening would otherwise be exposed while other openings still need more etching. Staged protection widens the process window and reduces metal erosion, corrosion and void formation. [8] TSMC documents AlN/AlOₓ/SiOC/AlOₓ above Cu, with AlN blocking Cu diffusion, and a simpler AlN/SiOC/AlOₓ variant that omits one AlOx film. [9] Levels with different opening sizes, aspect ratios, pattern densities and cap materials need different etch margins. A double AlOx stop is useful where another protected endpoint justifies the added processing. The extra film adds formation, selective opening and cleaning steps, plus another set of interfaces to control adhesion, moisture, and stress. These blanket films are opened through the existing via pattern, so each film does not require another lithography mask. AlOₓ adds parasitic capacitance when it replaces lower-k dielectric; two thin AlOₓ films can nevertheless contain less AlOₓ than one thick film. Total thickness, placement, and theintermediate dielectric determine the electrical cost. Deposition chemistry also changes AlOx permittivity and residual hydroxyl content, which can oxidize the underlying metal. [7], [8], [10], [11] The backside stack separates into relatively fine BM0-BM2 wiring near the devices and coarser BM3-BM5 power distribution. The largest pitch increase occurs between BM2 and BM3. BM0’s pitch closely matches the logic-row height, fitting local power delivery to the cell rows. Higher levels aggregate current through larger conductors: routing density becomes less important than low resistance and current capacity as the network approaches the package. This hierarchy provides wide power wiring for the power delivery network without consuming scarce frontside signal-routing resources. [3] The SemiAnalysis STEEL teardown lab breaks down advanced datacenter and AI hardware. To learn more about our pipeline or to commission a teardown, contact sales@semianalysis.com. WE’RE HIRING: Architecture, floorplan, packaging, manufacturing, and labs experts. Opportunities from system to transistor and everywhere in between. Check out our Careers page. Frontside Interconnects Intel 18A combines Mo-lined W contacts and nano-TSVs with a separate backside Cu power network. Samsung SF2 keeps power on the frontside, using Ti-based contact interfaces and Ta-based barriers and Co liners around Cu wiring. In 18A standard-cell rows, backside power rails supply the devices through nano-TSVs within the cells, freeing frontside routing resources. Samsung’s M0 accommodates both power and signal connections. From the device toward M0, the connection runs through a Ti-based S/D interface, W contact fill, a Mo-lined W via, and the Cu M0 wire. Mo supplies a conductive nucleation and adhesion layer for W, replacing the resistive TiN liner used in conventional W integration. This increases the effective conduction volume within the feature while retaining W fill and its established polishing, cleaning and etching processes. Intel’s Mo/W patent describes this integration tradeoff. The nano-TSV uses the same Mo-lined W construction in the backside supply path. [12] The move from TiN to Mo is an incremental change. While a full Co or Mo fill can also reduce the volume lost to liners in very small features, it requires new integration schemes that increase complexity and risk. Cu remains attractive for wider wires due to its low resistance. As wires and vias shrink, the diffusion barrier consumes an increasing fraction of their cross-section. [12], [12], [14] Intel uses Co/Ru liners at M0-M1, Co at M2-M4, and Nb at M5-M9. The lower-level liners help Cu adhere and reduce void formation during trench fills. Applied Materials’ Endura has new thermal control that facilitate wetting process, so the thin film continuity is good enough that good capillary pressure will drive Cu atoms to the via bottom without voiding. Intel’s choice to use Nb is particularly interesting. Intel’s Nb patent describes a conductive diffusion barrier intended to reduce the barrier’s contribution to resistance relative to conventional Ta-based barriers, particularly at via bottoms where all current crosses the barrier. The patent pairs Nb in coarser levels with the option of lower-cost PVD processing. [15], [16] The upper metal layers support thicker barriers formed through physical vapor deposition (PVD) despite its worse coverage and uniformity. Meanwhile, the lower metal layers require thinner barriers deposited through conformal atomic layer deposition (ALD). Co/Ru adds another material interface and requires controlled deposition and Cu fill. Changing liners and barriers by metal layer allows Intel to optimize interconnect resistance, process complexity, and reliability. [15, 16] RibbonFET, Intel’s name for its gate-all-around FETs (GAAFETs), replaces the FinFET’s vertical fins with four stacked horizontal silicon nanosheets, allowing the gate to surround the channel on every side. The path to GAAFET begins with the planar transistor. A planar MOSFET places the gate above the channel between its source and drain. Pairing an NMOS with a PMOS transistor creates a CMOS inverter, in which the NMOS pulls the output low for a high input, and the PMOS pulls it high for a low input. The gate must retain electrostatic control of the channel to ensure clean switching. As gate lengths shrank, the drain began to compete with the gate for that control, increasing off-state leakage. Electrostatic control was restored through an architectural evolution that raised the channel into a vertical fin and wrapping the gate around three sides. Called “FinFET”, this new architecture packed more effective channel width into a smaller footprint. Further scaling made it harder to maintain both drive current and leakage within smaller cells, and reintroduced the same problems planar MOSFETs faced. Nanosheet GAAFETs close the fourth side by replacing the vertical fin with a stack of horizontal nanosheets, each surrounded by the gate. The tighter electrostatic control suppresses leakage at shorter gate lengths while stacking adds effective channel width within the cell footprint. In a FinFET process, channel width changes in discrete steps as designers must add or remove whole fins. Nanosheet width can instead be adjusted continuously within the process’s design rules. Wider sheets increase drive current, while narrower sheets reduce capacitance at the cost of drive current. Intel 18A uses stacks of four nanosheets each and varies their widths across logic and SRAM. At the process level, adding more sheets to each stack increases effective channel width and drive current, but complicates fabrication. RibbonFET vs MBCFET Samsung began GAAFET production in 2022 with SF3E, following with SF3 and now SF2. Its ‘MBCFET’ provides a useful structural comparison with Intel’s first RibbonFET implementation. [17] STEEL is digging deeper into SF2, used in the Exynos 2600, and TSMC’s GAAFET N2, used in Apple’s A20 Pro, in upcoming newsletter articles. We’re throwing some teasers on X. Let’s compare Samsung SF2’s MBCFET with Intel 18A’s RibbonFET. Subscribe Even to the untrained eye, Intel’s extra nanosheet is obvious. Intel stacks four ribbons to Samsung’s three. Samsung’s sheets are much wider in these fields, so both sheet count and width matter to the available channel perimeter. Sheet width also changes which silicon surfaces carry current. On conventional (001) silicon, wide nanosheets emphasize the broad top and bottom surfaces, favoring electron transport; the larger sidewall contribution in a narrow sheet favors hole transport. Thinner sheets improve gate control but increase confinement and scattering. This makes width and thickness part of the NMOS/PMOS balance, alongside strain and threshold voltage. [18], [19] GAAFET designs like 18A use different work-function-metal (WFM) stacks for NMOS and PMOS. Around each ribbon, a thin SiOx interfacial layer separates the silicon channel from the HfOx high-k dielectric, with La providing dipole tuning and the WFM wrapping the dielectric. NMOS uses a TiAl-based stack, while PMOS uses TiN WFM. W fills the remaining gate trench, providing a lower-resistivity path where the work-function layers are no longer needed. In this field, the PMOS stacks leave room for W between ribbons, while the NMOS stacks occupy more of those gaps. A silicon-based dielectric marks the P/N boundary, allowing the PMOS and NMOS gates, sharing the same gate trench, to be processed sequentially. Fast logic paths, retention circuits, and SRAM need a family of threshold options. Changing threshold without substantially changing device dimensions, capacitance or fabrication complexity is valuable. FinFET processes typically use different work-function-metal stacks. In a four-ribbon GAA stack, the narrow sheet-to-sheet gap limits how much WFM can fit around each channel. La in the gate dielectric creates interfacial dipoles at the SiOx/HfOx boundary, shifting effective work function and tuning threshold voltage. This gives Intel another control alongside its NMOS and PMOS WFM stacks. Low-threshold devices improve critical-path drive; higher thresholds reduce leakage elsewhere. Dipole tuning is especially useful in GAA because it changes threshold without consuming the narrow intersheet gap with thicker WFM. Precise control of La incorporation, diffusion and interface quality has long been a challenge, limiting viability in high volume production but is now seen from every leading-edge foundry. Intel’s patent describes depositing a dipole-forming oxide above HfOx and annealing it toward the interfacial oxide before completing the work-function and fill metals. This separates threshold tuning from the space available for metal. Newer research addresses the thermal cost: imec’s 2026 dipole-middle research inserts the shifter between two HfOx depositions, shortening the diffusion path while protecting SiOx during patterning. [20], [21]Matched-cut EDS, Intel 18A (left) vs. Samsung SF2 (right). Intel retains raised source/drain epi beneath its contacts, while Samsung recesses W deep into the epi to form a V-shaped Ti-lined interface. The deeper contact increases metal-to-semiconductor area and shortens the current path from the lower sheets, reducing contact and spreading resistance. It also removes epi volume and brings the contact etch closer to the channel ends. Retaining more epi preserves the material available for strain transfer, especially from SiGe into PMOS. These geometries balance contact access against stress engineering and etch margin. [22], [23] Samsung stacks three sheets to Intel’s four ribbons, and both processes use sheet width to tune drive strength. In our Samsung cross-sections, widths range roughly from 19 to 30 nm in the NPU rows and 37 to 50 nm in the CU cell. The Samsung nanosheets taper, with the widest sheet at the bottom and the narrowest at the top. Both processes use HfOx gate dielectric and Ti-based work-function stacks, with Al in the NMOS stack. In the Samsung devices shown here, the dielectric and WFM occupy the intersheet gaps, leaving W above the top sheet. Intel’s PMOS stack leaves more room between ribbons, and W fills those gaps while the thicker NMOS stack leaves W mainly in the upper trench. Gate-stack EDS maps. The W between Intel’s PMOS ribbons provides a conductive path close to the lower gates. Where WFM fills the entire gap, the gate still surrounds the channel, but voltage reaches it through the more resistive work-function films. Thinner WFM and dipole tuning preserve room for low-resistivity fill; Mo and Ru are alternative fill metals being developed for further scaling. [24] A masked, sequential WFM flow explains the different gate heights and inter-nanosheet fill. The proposed sequence below shows how separate NMOS and PMOS work-function steps produce that geometry. Enabled by the BSPDN process, Intel replaces the dense-logic silicon subfin with dielectric, removing the parasitic conduction path below the ribbons and reducing substrate-related capacitance. A retained silicon body as in classical, non-SOI, planar and FinFET designs needs junction and punchthrough-stop engineering to suppress leakage. Dielectric isolation makes that leakage less sensitive to the subfin doping profile but adds removal and fill steps. It also weakens the direct thermal path through silicon, making the contacts, metal stacks and package more important for heat extraction. [24], [26] Fluorine is concentrated around selected Intel device structures in the maps. WF6 is a standard precursor for W nucleation and fill, while barrier films protect adjacent dielectrics from fluorine attack. Low-fluorine W processes reduce the residual-F burden. Chloride-based precursors avoid introducing F during W deposition, but require control of chlorine attack, nucleation and fill quality. The integration target is a continuous, low-resistance W path with a thin protective liner and minimal chemical damage to the surrounding stack. [20], [27], [28] The SemiAnalysis STEEL teardown lab breaks down advanced datacenter and AI hardware. To learn more about our pipeline or to commission a teardown, contact sales@semianalysis.com. WE’RE HIRING: Architecture, floorplan, packaging, manufacturing, and labs experts. Opportunities from system to transistor and everywhere in between. Check out our Careers page. We measured cell height, gate pitch, metal geometry, and ribbon dimensions at the XTEM sites shown below. The tables group these dimensions by site and device polarity. Our “sheet cuts” cross the silicon channel and show the ribbons end-on. “gate cuts” run along the channel through successive gates. The 18A logic cell dimensions point to a five-track logic library while the N3E and Intel 3 cell dimensions evidence a seven-track logic library. The DDR-PHY uses wider M0 wires and much larger spacing than core logic. That trades routing density for lower wire resistance and weaker coupling between neighboring nets. The geometry suits the current delivery and coupling requirements of analog, clock, and I/O circuitry. PowerVia lets 18A combine a compact cell height with wider M0 geometry by moving the main power rails off the signal-routing tracks. That relaxes local wire scaling while preserving a small cell footprint. Cell height and gate pitch set the geometric density; pin access and routability determine how much of it a real block can use. [29] The biggest takeaway from our gate-pitch measurements is that Intel 18A compute logic and TSMC N3E GPU logic have similar density in the Bohr representative-cell model. The 18A example is 18.6% denser than the Intel 3 GPU example. Gate pitches are nearly identical across the three sites, so cell height drives most of the difference. The Bohr model combines a four-transistor NAND2 spanning three gate pitches and a 32-transistor scan flip-flop (SFF) spanning nineteen pitches, weighting their densities 60:40. The sensitivity column shows how independently changing cell height and gate pitch by ±1 nm changes the result. This compares representative cell geometries; whole-die density also depends on cell mix and placement. The 18A P-core gives M0 substantially more metal cross section than the N3E vector engine. Treating each profile as a trapezoid gives 2.63 times the area per line and 1.84 times the area after normalization by routing pitch. The larger section reduces the geometric contribution to line resistance and lowers current density for a given current. Taller and wider wires also add capacitance, so circuit delay depends on the balance of resistance and capacitance. The DDR-PHY has less metal area per routing width than the 18A core fields, while remaining above N3E. [30] Area = height × (top CD + bottom CD) / 2, including liners. Area/pitch normalizes by routing width. Taper is the symmetric sidewall angle from vertical, with the largest angle belonging to the DDR-PHY. Compute tile The measurements show how ribbon dimensions and gate-stack geometry vary across the compute tile and between NMOS and PMOS to balance channel drive, gate load and the space needed for the dielectric/WFM stack across logic, SRAM and the DDR-PHY. Width mainly changes available channel perimeter; thickness also changes electrostatic control and carrier confinement. Gate-stack thickness then determines the space left for low-resistivity fill P-core and LP E-core logic Both the P-core and LP E-core use multiple nanosheet widths. Widths are measured on high-magnification XTEMs while wider-field images demonstrate additional width choices within the LP E-core. Multiple widths are expected even within an LP E-core. Timing-critical paths, buffers and cells with different fanout need different drive strengths. The lower-magnification fields show this width diversity beyond the sites quantified in the table. L2 and L3 SRAM GAA gives SRAM designers another way to balance the pull-up (PU), pass-gate (PG), and pull-down (PD) transistors. FinFET bitcells set device strength through fin count while GAA adds nanosheet width as a sizing knob. In a 6T SRAM cell, a strong pull-down relative to the pass-gate limits read disturbance, while a strong pass-gate relative to the pull-up improves writability. During a write, the pass-gate and write driver pull the node storing “1” below the inverter trip point. During a read, the pull-down holds the node storing “0” low. Bias, threshold voltage, mismatch and assist circuitry set the remaining margin. FinFET high-current cells commonly use a PU:PG:PD fin-count pattern of 1:2:2, a device-sizing ratio rather than a current ratio. Ribbon width lets Intel balance SRAM strengths without adding whole fins. The L2 cell uses its narrowest ribbons for PU and widest for PD, improving writability and read stability respectively. Intel’s disclosed HCC operates without assist; its denser HDC uses negative-bitline write assist. Pulling the selected bitline briefly below ground increases pass-gate overdrive so it can overpower the pull-up at lower supply voltage. That buys density and low voltage writability at the cost of boosting circuitry, switching energy, and additional voltage stress that must be controlled. [31], [32] Four rectangular ribbons give the perimeter = 8 × (width + thickness), before corner rounding. PG/PU is 1.49 and PD/PG is 1.16. The L3 structures closely resemble L2 in layout and cell height. Fewer L3 nanosheet widths are tabulated because fewer high-magnification images were available. DDR PHY The DDR-PHY trades density for controlled analog behavior and reliable off-chip signaling. It contains drivers, receivers, delay circuits, and calibration logic that set drive strength, sampling time, and voltage margin. Repeated four-sheet devices with similar widths fit the use of regular transistor units for matching and programmable drive. Its wider local wiring provides room for current delivery and separation of sensitive signals, while consuming more area than a dense core-logic grid. The layout serves the memory channel’s electrical requirements as well as digital logic density. [33] The SemiAnalysis STEEL teardown lab breaks down advanced datacenter and AI hardware. To learn more about our pipeline or to commission a teardown, contact sales@semianalysis.com. WE’RE HIRING: Architecture, floorplan, packaging, manufacturing, and labs experts. Opportunities from system to transistor and everywhere in between. Check out our Careers page. Intel 3 GPU devices Vector engine logic Intel 3’s XVE logic uses two-fin PMOS and NMOS devices with power rails in M0. Its cell height and M0 pitch give a seven-track geometry, two tracks more than the 18A logic. One-fin groups also appear among the two-fin devices. Intel 3 L2 SRAM The Intel 3 L2 SRAM uses the familiar HCC sizing pattern: one PU fin, two PG fins, and two PD fins. N3E GPU devices Vector engine logic The N3E XVE field contains repeated two-fin devices with seven-track cell geometry. N3E remains a FinFET process, giving Panther Lake a direct FinFET-to-RibbonFET comparison. N3E L2 SRAM The N3E L2 SRAM uses the same PU:PG:PD fin-count pattern of 1:2:2. Panther Lake-U follows Lunar Lake’s floorplan quite closely. Both pair 4 P-cores with 4 LP E-cores and NPU, media and display engines in similar locations. Lunar Lake also uses Xe2, the direct predecessor to Panther Lake’s Xe3 GPU. This makes Lunar Lake the most direct basis for our comparisons. Arrow Lake differs in core count and uses the older Xe-LPG GPU architecture, so we only use it where it offers a more direct component-level comparison. Compute tile Panther Lake compute-tile floorplans remain sparse even months after launch. Intel 18A’s backside metal and dielectric stack must be removed without damaging the underlying structures before a clean transistor-level floorplan can be imaged. Most published die shots hide or heavily process the background, but we are quite proud of the die shot we achieved and are excited to show the work we have done. We measured the areas of the key components on the compute tile and compared them with their Lunar Lake predecessors on TSMC N3B. These help us to capture changes in block area and compare the two chips across process nodes and designs. Our total tile areas exclude the scribe-line area. The compute-plus-GPU subtotal below uses the PTL-U compute tile and GT1 GPU; it excludes the I/O tile and passive base. Individual block areas use the boundaries marked on the floorplans The compute-plus-GPU row is recomputed from the displayed PTL-U and GT1 areas. Component rows use their stated per-region counts and are not an additive partition of the whole tile. The P-core area remains almost unchanged between Lunar Lake and Panther Lake, despite L2 capacity increasing from 2.5 MiB to 3 MiB. Arrow Lake uses the same Lion Cove core as Lunar Lake but also has a 3 MiB L2. Cougar Cove fits 20% more L2 into the same P-core area. The larger private cache keeps more of each core’s working set close to its execution units, reducing access to shared L3 and DRAM. Extra capacity adds storage leakage and lookup energy, so designers balance it against avoided lower-level accesses. The shared P-core L3 cache also shrank by 14.8%. [2] Cougar Cove combines a similar footprint with Intel’s reported power-efficiency improvements. RibbonFET’s tighter channel control reduces leakage, while PowerVia reduces supply droop and allows tighter voltage guardbands. [1] Darkmont’s four-core LP E-core cluster is 5.0% smaller than Skymont’s on Lunar Lake, with most of the reduction in its L2 regions. The 1 MiB region shrank by 8.4% and the 1.5 MiB region by 14.9%. The tag arrays also use one fewer visible row. Tags identify which memory addresses the data array holds, so rearranging them changes the cache’s layout and wiring without requiring less data capacity. [2] The LP E-cores share one L2. This pools capacity and avoids duplicating all the cache machinery, but the four cores contend for its banks and bandwidth. Their separate cluster also keeps light work away from the performance cluster and its L3, allowing that larger domain to sleep. [1], [2] Cache area includes more than the storage cells. Tags identify each line, decoders select rows, sense amplifiers read the small bitline signal, and wires connect to the banks. Splitting an array into smaller sections shortens wordlines and bitlines, improving access speed, but duplicates peripheral circuits. Panther Lake’s smaller cache regions therefore reflect the complete memory implementation, including how much of each region is devoted to storage. [34] Unlike Meteor Lake and Arrow Lake, Panther Lake has no separate SoC tile. The NPU, LP E-cores, memory controllers, PHYs, media and display engines now share the compute tile. This removes an active die and keeps CPU memory traffic on one die. The cost is moving PHY and I/O-related circuitry onto 18A: drivers, receivers and analog circuits must still meet external voltage, loading and signal-integrity requirements, so their area does not shrink like dense digital logic. [1], [2] The biggest shrink comes from the NPU, which occupies 36.9% less area. NPU 5 consolidates the same total INT8 MAC count into half as many neural compute engines. Each of the three NCEs has a larger MAC array to make the complete NCE envelope 22.6% larger than an NPU 4 engine. Consolidation also halves the number of scratchpads and SHAVE DSPs, from 12 to 6. The MAC array handles matrix multiplication and convolution, while SHAVE executes vector and custom operations that fit the array poorly. [1], [2], [35] The paired floorplans identify each NCE envelope and its scratchpad, MAC, and SHAVE regions. Each measured MAC polygon is counted once per NCE in the area accounting below. The scratchpads store weights, activations, and intermediate results near the MAC arrays, allowing repeated use without fetching them again from DRAM. Halving their number delivers the largest measured area saving but leaves less local storage for the same total MAC count. Layers that no longer fit locally require smaller working tiles or more transfers of intermediate data. The benefit depends on keeping the enlarged arrays busy while managing that tighter storage budget. [36] NPU 5 also adds native FP8. Using half the operand width of FP16 reduces storage and transfer demand, helping workloads fit the smaller local memory budget. Lower precision and format-dependent range make scaling and model validation part of deployment. Hardware activation functions further reduce work that would otherwise occupy the programmable DSPs. [1], [2] Microsoft requires an NPU to deliver at least 40 TOPS for Copilot+ PCs. Both Lunar Lake and Panther Lake meet this threshold, but Panther Lake uses significantly less silicon. GPU tiles Panther Lake is Intel’s first product with Xe3, its latest GPU architecture. It offers two different GPU tiles: a smaller GT1 tile with 4 Xe3 cores on Intel 3 and a larger GT2 tile with 12 Xe3 cores on TSMC N3E. Panther Lake allows us to compare the same GPU architecture across both Intel 3 and TSMC N3E. Wildcat Lake adds a third Xe3 implementation on Intel 18A. A future newsletter will detail Xe3 and its implementation differences across all three process nodes. GT2 scales Xe3 to a different physical layout, with render slices arranged vertically instead of GT1’s horizontal arrangement. Slice placement sets the distances to shared cache banks and the D2D interface. Those wires consume area and add delay, so scaling the number of Xe cores also requires a new balance of cache placement, routing and timing. [1] What’s immediately obvious is that the GT2 tile on TSMC N3E has much smaller Xe cores than GT1. These block areas include logic, caches, and routing. An Xe core on the GT1 tile is ~69% larger than one on Lunar Lake, and ~55% larger than one on GT2. Intel 3 therefore uses substantially more area per Xe core. The block-area gap exceeds the measured logic and SRAM density gaps, bringing routing, timing targets, cell mix, and floorplan allocation into the comparison. The measured vector/matrix engine region is almost unchanged between Lunar Lake and Panther Lake’s GT2 tile. Xe3 retains eight 512-bit vector engines and eight 2048-bit XMX engines per core. Its gains also come from feeding those engines more effectively: more resident threads hide stalls, and variable register allocation lets shaders trade registers per thread against the number of threads kept active. [1] The shared L1/SLM capacity increased by 33% from 192 KiB to 256 KiB, while its area increased only 5%, raising effective density by 27%. L1 retains reused cache lines, while software-managed SLM lets a thread group share data locally. Both reduce traffic to more distant memory. Allocating more SLM per group can also limit how many groups reside on a core at once. [1], [37] The GT1 tile carries 4 MiB of L2 against 16 MiB on the GT2 tile. GT1 divides its L2 cache into four 1 MiB banks, while GT2 uses eight 2 MiB banks. Each bank contains 128 macros, but each N3E macro stores 16 KiB, twice the Intel 3 macro’s 8 KiB capacity. The N3E macro is only 54% larger while holding twice as many bits, giving it 30% higher density: ~23.7 Mbit/mm² versus 18.3 Mbit/mm². Including bank-level circuitry, the gap widens to ~16.9 Mbit/mm² on GT2 versus ~10.4 Mbit/mm² on GT1. GT2 gains density with its macros storing more bits per unit area, and those macros occupy more of each cache bank. Larger macros spread decoder and sense-amplifier overhead across more storage, while a more compact bank layout reduces the share spent on control and routing. The compromise is longer wordlines and bitlines that carry more capacitance. [34] I/O tile Panther Lake uses two I/O tile variants, both fabricated on TSMC N6. The smaller one provides 4 PCIe 5.0 and 8 PCIe 4.0 lanes and serves lower-tier systems as well as those without a discrete GPU, while the larger one adds 8 PCIe 5.0 lanes, bringing the total to 20 lanes, for discrete-GPU connectivity. Panther Lake SKUs with the larger 10- or 12-Xe GPUs use the smaller I/O tile. [38] The smaller I/O tile adds a PCIe 4.0 block and a Thunderbolt block to Lunar Lake’s I/O layout, providing four additional PCIe 4.0 lanes and another Thunderbolt 4 port. Its repeated N6 blocks retain nearly identical areas and layouts. Reusing these proven PHYs and controllers avoids porting and requalifying external interfaces on 18A, where faster digital logic offers less benefit to circuits constrained by the off-chip link. [38] SemiAnalysis’s teardown lab (STEEL) dives deep into the world’s advanced datacenter and AI hardware. To learn more about our pipeline or to commission a teardown, contact sales@semianalysis.com. We’re hiring technical experts from system to transistor and everywhere in between. Check out our Careers page. Panther Lake offers scalability and modularity through its disaggregated packaging that partition compute, GPU, and I/O silicon into separate tiles allowing for a suite of tile configurations. This partitioning makes the package part of Intel’s node economics as it determines how much leading-edge wafer area each product consumes, which functions can remain on other processes, and how much configuration freedom Intel can offer from a shared set of tiles. Furthermore, fabricating the compute and GPU tiles separately confines the new 18A process to the compute tile and allows graphics and I/O to use other, more established, and more cost-effective processes. For Panther Lake, the GPU and I/O tiles are assembled alongside the compute tile on a passive silicon base using Foveros-S. Intel’s current technology brief lists a nominal 36 µm pitch for Foveros-S. Through-silicon vias (TSVs) in the base connect the fine wiring above to the larger package connections below. The functional tiles sit side by side on that passive base in a 2.5D configuration. [39] Our cross-section through the compute and GPU tiles shows the package’s wiring hierarchy. Microbumps connect each active tile to the passive silicon base; its fine redistribution layer (RDL) carries the short, dense tile-to-tile links. TSVs carry connections through the base to the package substrate, which fans them out to the much coarser motherboard solder joints. The base supplies interconnect, while computation remains in the active tiles above it. [39] At the compute-tile edge, the higher-magnification inset shows a local microbump spacing of approximately 25.24 µm and a feature width of 12.33 µm. These local spacings are finer than Intel’s nominal Foveros-S value. The X-ray fields further confirm tighter neighboring bumps, consistent across every die-to-die area found on each tile. Additional X-ray analysis is offered after the paywall. Putting the memory controller beside the CPU removes the D2D transfer that CPU memory requests required in Meteor Lake and Arrow Lake. This avoids the extra transmitter, receiver, and link traversal, saving interface energy and latency. Panther Lake’s separate GPU still crosses a D2D link to reach DRAM, so its larger local caches also help contain package traffic. [1], [40] Smaller dies are less likely to contain a random fatal defect, and screening them before assembly prevents one bad tile from consuming a complete package of good silicon. Reuse also spreads design and qualification work across more products. Against those gains, Intel pays for the passive base, D2D circuits, extra bonding and test steps, and losses during assembly. Cost per working product across the portfolio captures the combined effect of wafer yield, reuse, test, and assembly. [29] Wildcat Lake packaging Intel launched Core Series 3, formerly Wildcat Lake, on 16 April 2026 for value mobile and edge systems. Wildcat Lake keeps 18A but removes the passive base and combines more functions on one die to simplify the package. The two products therefore reveal two distinct ways to commercialize the same leading-edge process. [41] Wildcat Lake’s 18A die combines up to two Cougar Cove P-cores, four Darkmont LP E-cores, two Xe3 cores and a smaller NPU. A separate platform-controller die supplies I/O, connected through UCIe, Intel’s first processor implementation of the standard. Consolidating graphics remove a tile boundary and the passive base, reducing assembly complexity for a modest-bandwidth value product. It also ties CPU and graphics scaling to the same die, giving up Panther Lake’s ability to swap in a much larger GPU. [42], [43] In July 2021, Intel CEO Pat Gelsinger set out an ambitious process roadmap aimed at regaining performance leadership by 2025, later described as five nodes in four years. Five years and one CEO later, Intel’s comeback story is not as unambiguously positive as Pat may have hoped. [44], [45] Intel once set the pace for process technology, bringing high-k metal gate technology and FinFETs into volume production years ahead of the rest of the industry. Its 22 nm FinFET process reached consumers with Ivy Bridge in 2012. [46] Intel’s integrated device manufacturing (IDM) model allowed its architects and process engineers to co-optimize products and processes. Starting with Sandy Bridge, Intel dominated x86, while AMD struggled with Bulldozer. That lead faltered at 14 nm and broke at 10 nm. Intel targeted a massive 2.7× density increase, but the node arrived years late and required several revisions before it could support Intel’s full lineup. This delay forced Intel to stretch 14 nm across six generations, while TSMC moved ahead in process technology and AMD recovered in x86. By 2019, Intel was still shipping 14 nm across most of its product stack, with its 10 nm client ramp focused on Ice Lake mobile processors. Meanwhile, TSMC was shipping N7 and N7+, and AMD’s Zen 2 compute chiplets used N7 to raise core counts and improve efficiency. Intel’s process failures were central to its decline, but unsound business decisions furthered their downward slide. Product delays compounded product mistakes, pushing client, server, and FPGA roadmaps off schedule. Several attempts to enter AI (Nervana and Gaudi) and networking (Tofino) also failed to establish lasting businesses. Intel’s recovery has focused on consumer CPUs and advanced packaging. Tiger Lake, Alder Lake, Lunar Lake and now Panther Lake have restored Intel’s consumer roadmap. On the process side, Intel 4 shipped with Meteor Lake, Intel 3 with Granite Rapids and Sierra Forest, and Intel 18A with Panther Lake. Intel has also made advanced packaging part of its foundry offering. However, Intel is still playing catch-up in servers. Several Xeon generations arrived years late and trailed contemporary AMD and Arm server CPUs in performance, efficiency, and core count. The process roadmap is back, but Intel does not hold the same process-technology leadership position it held prior to 10 nm. The introduction of gate-all-around nanosheets and backside power delivery are two of the biggest changes to transistor integration in a decade. Intel took on both changes at once: 18A paired its first RibbonFET with PowerVia in Panther Lake. Panther Lake is a substantial manufacturing milestone. Our cross-sections show how RibbonFET and PowerVia reshape local contacts and wiring, while the floorplans show where architectural consolidation and process choices save area. A sustained competitive lead depends on product performance, cost, yield, and the next implementation. The SemiAnalysis STEEL teardown lab breaks down advanced datacenter and AI hardware. To learn more about our pipeline or to commission a teardown, contact sales@semianalysis.com. WE’RE HIRING: Architecture, floorplan, packaging, manufacturing, and labs experts. Opportunities from system to transistor and everywhere in between. Check out our Careers page.. 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