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Vertical comb drive actuators are now frequently used for rotating micromirrors. For constructing the vertical comb, paired combs positioned at different heights are necessary. In many cases, Si dry etching is carried out from front and bottom surfaces of SOI wafer. The alignment accuracy between combs depends on the aligner accuracy. The backside Si etching becomes very deep with the increase of technical difficulty. In this study, a new method for realizing the vertical comb in SOI-MEMS and its performance is examined.