Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 1 of 62
`Case 5:20-cv-05676—EJD Document 42-8 Filed 12/07/20 Page 1 of 62
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`EXHIBIT F
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`EXHIBIT F
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 2 of 62
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`DEMARAY LLC,
`
`Plaintiff,
`v.
`SAMSUNG ELECTRONICS CO., LTD (A
`KOREAN COMPANY), SAMSUNG
`ELECTRONICS AMERICA, INC.,
`SAMSUNG SEMICONDUCTOR, INC., and
`SAMSUNG AUSTIN SEMICONDUCTOR,
`LLC,
`
`Defendants.
`
`Case No. 6:20-cv-00636-ADA
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`PLAINTIFF DEMARAY LLC’S PRELIMINARY INFRINGEMENT CONTENTIONS
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 3 of 62
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`Pursuant to the Court’s October 5, 2020, Order Governing Proceedings – Patent Case,
`Plaintiff Demaray LLC (“Demaray”) provides the following disclosure of its preliminary
`infringement contentions with regard to U.S. Patent Nos. 7,544,276 (“the ’276 Patent”) and
`7,381,657 (“the ’657 Patent”) (collectively, the “Asserted Patents”).
`I.
`Background
`
`These preliminary infringement contentions and associated disclosures (“Preliminary
`Infringement Contentions”) are based on the limited information that Demaray has been able to
`obtain from its investigation to date. Although Demaray has undertaken reasonable efforts to
`prepare these Preliminary Infringement Contentions, the configuration, structure, and operation of
`the physical vapor deposition (“PVD”) reactors for thin film deposition (“Samsung PVD
`Reactors”) in the production of semiconductor products of Defendants Samsung Electronics Co.,
`Ltd. (“SEC”), Samsung Electronics America, Inc. (“SEA”), Samsung Semiconductor, Inc.
`(“SSI”), and Samsung Austin Semiconductor, LLC (“SAS”) (collectively, “Samsung”) are, in
`significant part, proprietary and have not yet been disclosed by Samsung. Demaray requested that
`Samsung provide specifically identified technical information that would enable Demaray to
`provide more detailed Preliminary Infringement Contentions, but Samsung refused Demaray’s
`request.1 Demaray has endeavored to provide a reasonable level of detail in its preliminary
`infringement contentions based upon the limited publicly available information regarding the
`Samsung PVD Reactors and production processes for Samsung’s semiconductor products. Until
`discovery is obtained from Samsung, the proprietary aspects of the Samsung PVD Reactors and
`methods of use of such reactors in the production of Samsung’s semiconductor products have
`
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`1 Demaray sent Samsung a letter on September 15, 2020, identifying limited core technical
`documents related to its PVD reactors in order to ensure that certain claims of the patents could be
`thoroughly addressed in the Preliminary Infringement Contentions. Specifically, Demaray
`requested that Samsung provide documents sufficient to show the suppliers, model numbers, and
`configuration of reactors used for physical vapor deposition of thin films used by Samsung for the
`production of semiconductor devices in the last six years. This included, for example, the power
`sources coupled to the target/substrate for each chamber in each reactor and the types of thin films
`deposited by each chamber in each reactor. Samsung refused these requests during a meet and
`confer dated October 6, 2020.
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`limited the possible breadth and depth of these Preliminary Infringement Contentions. For these
`reasons, among others, Demaray reserves all rights to later amend these Preliminary Infringement
`Contentions based on information later produced by Samsung.
`II.
`Charts Setting Forth Where In The Accused Products Each Element Of The Asserted
`Claims Are Found
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`Attached as Exhibits A and B are charts setting forth Demaray’s preliminary contentions
`regarding where in the accused products each element of the asserted claims are found and an
`identification of the patent claims presently asserted (“Asserted Claims”) and the products,
`methods, or other instrumentalities presently believed to infringe. All claims identified therein—
`including those claims for which it is noted that further discovery from Samsung is believed to be
`required—should be considered asserted, including for purposes of identifying claim terms whose
`constructions may be disputed. Each of the following exhibits, which may contain Demaray
`confidential material, is hereby incorporated by reference:
`Exhibit U.S. Patent No.
`A
`7,544,276
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`B
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`7,381,657
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`Exhibits A and B are intended to be understood by skilled persons in the art. Demaray
`reserves the right to rely on technical documents to further clarify the terms and technologies used
`in these Preliminary Infringement Contentions in its future expert reports and trial evidence.
`Several elements of the Asserted Claims may be satisfied by more than one component, structure,
`process, or action found within or taken by Samsung in the production of Samsung’s
`semiconductor products or the Samsung PVD Reactors. The initial claim charts provided herewith
`may therefore include alternative contentions and theories. For example, where multiple structures
`are identified as corresponding to a particular claim element, the multiple structures may be
`viewed as alternative or supplemental to one another.
`Demaray expressly reserves the right to amend, revise or supplement these disclosures for
`at least any of the following reasons: Samsung’s production of discovery about the production
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`processes for Samsung’s semiconductor products or the Samsung PVD Reactors; the disclosure of
`Samsung’s claim construction positions, invalidity contentions, or non-infringement contentions;
`the Court’s construction of any of the Asserted Claims or any other legal determination of other
`issues; analysis undertaken or determinations made based in whole or part on the foregoing; or for
`any other permissible reason.
`These Preliminary Infringement Contentions provide examples of infringement that
`illustrate Demaray’s infringement theories. However, these examples are non-limiting and are
`included to assist in disclosing and understanding Demaray’s infringement theories. For example,
`details regarding the production processes for Samsung’s semiconductor products or how the
`Samsung PVD Reactors implement certain patent claims may vary from device to device in ways
`not material to the analysis of the Asserted Claims. The specific instrumentalities selected for the
`most detailed discussions in the accompanying charts are, as explained in the charts themselves
`and as further addressed in this document, to be understood as representative of other
`instrumentalities with structures, operation, or other charted characteristics that do not differ from
`the instrumentalities charted in ways that are material to Demaray’s theories of infringement for
`the charted claims.
`Demaray currently understands Samsung’s microprocessor products to be grouped by
`generations and code names corresponding to varying microarchitectures. For example, in these
`Preliminary Infringement Contentions, including in Exhibits A-B hereof, a reference to an
`“Exynos M3” microarchitecture is intended to include all semiconductor products of that
`microarchitecture, including variants thereof unless otherwise specified. Further, a reference to
`Samsung’s DDR4 SDRAM is intended to include all memory products of that architecture,
`including variants thereof, unless otherwise specified.
`III.
`Infringement Under The Doctrine Of Equivalents
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`The enclosed charts disclose the patent claims at issue that are believed to be literally
`present in Samsung’s technology, the elements of which are also believed to be infringed under
`the doctrine of equivalents. Demaray reserves the right to provide further details regarding
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`Samsung’s infringement under the doctrine of equivalents as discovery is provided by Samsung.
`Demaray further reserves the right to assert the doctrine of equivalents in the event that Samsung
`claims that one or more claim limitations are not literally present in any of the production
`processes for Samsung’s semiconductor products or the Samsung PVD Reactors.
`IV.
`Indirect Infringement
`
`To the extent that any element of any Asserted Claim is practiced or alleged by Samsung
`to be practiced by a party or entity other than Samsung, Demaray may assert, and reserves the
`right to assert, that such other party or entity practices such element under the direction or control
`of Samsung or otherwise in a manner that renders Samsung responsible for the performance of the
`entirety of the asserted claims pursuant to, inter alia, 35 U.S.C. §§ 271(a), (f)(1), (f)(2), and/or (g)
`and associated case law. Further, to the extent that any element of any Asserted Claim is
`performed or alleged by Samsung to be performed by a party or entity other than Samsung, and
`Samsung further alleges it is not liable for direct infringement, Demaray may assert, and reserves
`the right to assert, that Samsung is liable for induced and/or contributory infringement pursuant to
`35 U.S.C. §§ 271(b) and 271(c) and associated case law.
`For example, Demaray may assert that Samsung is liable under 35 U.S.C. §§ 271(b) and
`271(c) for infringement by third-parties involved in research and fabrication of Samsung
`semiconductor products using PVD reactors configured or operated as required by the claims that
`Samsung supplies or that are configured or operated in that manner at Samsung’s direction.
`Samsung, for example, may contribute to infringement of the patents-in-suit by providing PVD
`reactors to third-parties configured such that they have no substantial non-infringing use or by
`encouraging or requiring third-parties to use PVD reactors so configured and may induce use of
`such configurations by such third-parties by providing information about how to configure PVD
`reactors for use in production of Samsung semiconductor products, working or partnering with
`third-parties to develop and market products produced using the patented PVD reactor
`configurations, and by providing such third parties with technical support, as just a few
`representative examples. Non-limiting examples of these and other actions that may support
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`Demaray’s indirect infringement allegations can be found on Samsung’s website and third-party
`websites, among numerous other public sources.
`As another example, Samsung may actively and intentionally cause infringement with both
`knowledge of the patents-in-suit and the specific intent to cause use of PVD reactors configured as
`required by the Asserted Claims. See also Section V. Production of certain of Samsung’s
`semiconductor products requires use of PVD reactors that are configured in an infringing manner
`and Samsung may actively work with third parties to develop and manufacture Samsung
`semiconductor products using these processes in reactors configured in an infringing manner.
`Samsung’s actions may further constitute contributory infringement. For example, on
`information and belief, Samsung may supply or caused to be supplied from the United States,
`PVD reactors to third parties configured in a way such that they are especially made or adapted for
`use in an infringing manner and are not staple articles or commodities of commerce suitable for
`substantial non-infringing uses or by encouraging or requiring third-parties to use PVD reactors so
`configured. The PVD reactors as configured may be especially designed to be used in the design,
`development and manufacture of Samsung semiconductor products as discussed above.
`Specific examples of detailed acts of infringement that may be being induced and
`contributed to by Samsung are set forth in more detail in Exhibits A-B. For the configured PVD
`reactors and semiconductor products produced using the infringing processes, Samsung may
`provide specific instructions on both the characteristics and performance requirement of such
`semiconductor products, and the reactor configurations, including infringing reactor
`configurations, required for the production thereof. Thus, Samsung’s indirect infringement may
`occur in connection with each such semiconductor product through the provision of such
`information and support to, for example, third parties involved in the design and manufacture of
`such semiconductor products.
`Demaray incorporates by reference the allegations in its Complaint, along with the analysis
`in the attached charts (Exhibits A-B) with respect to Samsung’s direct, indirect, and willfully
`infringing activity. Demaray further expects Samsung to produce documents and information
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`during the course of discovery that will support Demaray’s direct, indirect, and willful
`infringement allegations.
`V. Willful Infringement
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`Samsung has long had knowledge of the Asserted Patents and its infringement thereof.
`
`Samsung has deliberately continued to infringe in a wanton, malicious, and egregious manner,
`with reckless disregard for Demaray’s patent rights. Samsung’s misconduct has been ongoing for
`years.
`As an example, Dr. Demaray met with representatives of Samsung at Samsung’s Strategy
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`and Innovation Center in San Jose, CA on or about March 7, 2017. Attendees for Samsung
`included Robert Ashcroft from Samsung Research America, Mark Lefebvre from Samsung SDI
`America Inc., and Dr. Debasis Bara from SEA. Subsequent to that meeting, Dr. Demaray provided
`the attendees with materials presented at the meeting, including a PowerPoint presentation
`identifying the Asserted Patents and explaining the use of the technology in barrier layer
`deposition in semiconductor products. Dr. Demaray participated in a follow-up meeting with
`Samsung on April 19, 2017 at Samsung Research America in Mountain View, CA to further
`discuss the technology. The attendees included, among others, Dongmin Im from Samsung
`Advanced Institute of Technology in Korea and Dr. Debasis Bera.
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`As a further example, Samsung frequently cites to patents and patent applications assigned
`to the named inventors on the Asserted Patents, including, among others, Demaray patents and
`patent applications identified to Samsung in the meeting above. For example, the following
`patents and patent applications assigned to Samsung cite to patents and applications on which one
`or more of the named inventors on the Asserted Patents is also named as an inventor: U.S. Patent
`Nos. 9,761,441, 9,590,207, 9,380,692, 9,306,192, 8,859,306, 8,716,931, 8,512,527, 8,154,197,
`7,816,666, 7,744,730, 7,563,672, 7,352,022, 6,723,215 and European Patent Application No.
`EU2131411A1.
`VI.
`Production Of Documents
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 9 of 62
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`As specified in the Court’s Order Governing Proceedings – Patent Case, Demaray is
`producing (1) documents currently in Demaray’s possession, custody or control evidencing
`conception and reduction to practice for each claimed invention and (2) a copy of the file history
`for each patent-in-suit in this action by production numbers: DEMSAM00000001–3160, 3392–
`3448. Demaray consents to sharing documents indicated with the legend “HIGHLY
`CONFIDENTIAL - OUTSIDE COUNSEL EYES ONLY” only with Samsung’s outside counsel
`of record.
`Demaray’s efforts to collect such documents from third parties, including previous
`assignees of the relevant patents, remains ongoing. Demaray will promptly produce to Samsung
`any such non-privileged documents that it may receive after the date of these Preliminary
`Infringement Contentions.
`VII.
`Identification Of Priority Date
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`As specified in the Court’s Order Governing Proceedings – Patent Case, the inventions of
`the Asserted Claims are currently believed to have been conceived
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` and reduced to practice at least as early, and possibly earlier
`. Alternatively, at a minimum, the Asserted Claims of the
`asserted patents are entitled to a priority date of at least as early as March 16, 2002, which is the
`filing date of U.S. Utility App. No. 10/101,863.
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`Dated: October 9, 2020
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`By:
`
`/s/ C. Maclain Wells
`
`C. Maclain Wells (pro hac vice)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`mwells@irell.com
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`Attorneys for Demaray LLC
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`CERTIFICATE OF SERVICE
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`I am employed in the County of Los Angeles, State of California. I am over the age of 18
`and not a party to the within action. My business address is 1800 Avenue of the Stars, Suite 900,
`Los Angeles, California 90067-4276.
`
`On October 9, 2020, I served the foregoing instrument and associated attachments on all
`counsel of record.
`
`X
`
`(BY ELECTRONIC MAIL) I caused the foregoing document to be served
`electronically by electronically mailing a true and correct copy through Irell &
`Manella LLP's electronic mail system to the e-mail address(es), as stated on the
`attached service list, and the transmission was reported as complete and no error
`was reported.
`
`Executed on October 9, 2020, at Sebastopol, California.
`
`I declare under penalty of perjury under the laws of the State of California that the
`foregoing is true and correct.
`
`
`
`
`
`C. Maclain Wells
`(Type or print name)
`
`
`
`
`/s/ C. Maclain Wells
`(Signature)
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 11 of 62
`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`As used herein and with respect to the ’276 Patent and based on Demaray’s present understanding, the term “Samsung Accused
`Products” means each of the following items that were made, used, imported, offered for sale or sold1 by Samsung Electronics Co., Ltd.
`(“SEC”), Samsung Electronics America, Inc. (“SEA”), Samsung Semiconductor, Inc. (“SSI”), and Samsung Austin Semiconductor, LLC
`(“SAS”), including by all subsidiaries, affiliates, or third-parties under their control (individually and collectively, “Samsung”), on or
`after July 14, 2014:
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`(a) all physical-vapor-deposition (“PVD”) reactors configured according to the ’276 Patent and used in the manufacture of Samsung
`products or elements thereof, which includes reactive-magnetron-sputtering (“RMS”) reactors configured according to the ’276
`Patent and used by Samsung in the production of semiconductor products (“Samsung PVD Reactors”);
`
`(b) all Samsung PVD Reactors configured according to the ’276 Patent and used in the manufacture of at least the following
`Samsung products and variants thereof:
`
`Apparent Release Year
`2015
`2017
`2018
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`Microprocessor
`Exynos M1 (Mongoose 1)
`Exynos M2 (Mongoose 2)
`Exynos M3 (Meerkat)
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`(c) all Samsung PVD Reactors configured according to the ’276 Patent and used in the manufacture of other Samsung
`microprocessors;
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`(d) all Samsung PVD Reactors configured according to the ’276 Patent and used in the manufacture of any Samsung products other
`than microprocessors (including, for example and without limitation, Samsung chipsets, network interface controllers, network
`adaptors, memory and storage devices (including, for example, DRAM, NAND, SSDs, eMMC, UFS and other types of memory),
`graphics chips, controllers, FPGAs, MCP products, RF chips, baseband processors, modems, transceivers, embedded processors,
`power and display ICs, and semiconductors within Samsung’s consumer electronic products such as phones, other mobile
`devices, home appliances, and computing, audio and smart home products), as well as use of the Samsung PVD Reactors
`
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`1 References in items (a) – (f) below to a product being “used” in any way should be understood to include any or all of these five
`infringing actions.
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 12 of 62
`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`configured according to the ’276 Patent to make any other Samsung non-microprocessor in the same or materially the same
`manner as described below;
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`(e) to the extent not already included in the above descriptions, all Samsung PVD Reactors configured according to the ’276 Patent
`and used by Samsung in the manufacture of semiconductor products for others or by others in the manufacture of semiconductor
`products for Samsung (including, for example, chips made by companies other than Samsung according to Samsung’s process
`specifications and then included by Samsung within products thereafter sold by Samsung, such as chips within Samsung’s
`consumer electronic products); and
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`(f) all Samsung PVD Reactors configured according to the ’276 Patent and used in the manufacture of any wafers or chips, packaged
`or unpackaged, that constitute or contain semiconductor products within the foregoing descriptions.
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`This claim chart for the ’276 Patent is intended to cover all Samsung Accused Products. The theory of infringement described below in
`connection with the asserted claims is believed to be analogous to the theory of infringement for all Samsung Accused Products.
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`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`’276 Patent
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`Samsung Accused Products
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`1. A reactor according
`to the present
`invention, comprising:
`
`Samsung Accused Products2 are reactors according to the present invention and Samsung uses such reactors in a
`variety of infringing ways in the production of Samsung semiconductor products.
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` For instance,
`Samsung deposits layers (including, e.g., metal nitride layers, such as TaN barrier layers and/or TiN hardmask
`layers) on insulating substrates (e.g., semiconductor wafers) in the production of its semiconductor products,
`including, but not limited to, Samsung processors, memory products, and the other Samsung products identified
`above using Samsung Accused Products at its fabrication plants and research facilities, including but not limited
`to premises within the United States.
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`As a specific example, Samsung has deposited such layers in its memory products using Samsung Accused
`Products since the introduction of its DDR4 SDRAM products. See, e.g., Dkt. No. 21 (Answer) (for example,
`see specifically ¶¶ 31 (“SEC and SAS admit that they use RMS reactors for depositing TaN, where tantalum is
`the target material.”), 57 (“SEC admits that it uses a RMS reactor in the fabrication of TaN layers in certain of
`its DDR4 SDRAM products.”)).
`
`As a further example, Samsung configures and uses, among other reactors, Samsung Accused Products in the
`Endura product line from Applied Materials, Inc. for deposition of such layers (including, e.g., metal nitride
`layers, such as TaN barrier layers and/or TiN hardmask layers) in its semiconductor products. Samsung has
`identified Applied Materials as a supplier. DEMSAM00003387. On information and belief, Samsung can
`modify these reactors for application-specific processes to deposit specific materials. For example, the Endura
`product line includes reactors that can be configured for deposition of TaN layers (e.g., CuBS RFX PVD with
`
`
`2 In the interests of brevity, these charts refer primarily to Samsung, and Samsung’s activities and equipment. Nonetheless,
`Demaray’s infringement theories include Samsung potentially having others practice the asserted claims on its behalf, and other forms of
`infringement, as described in the cover document served with these charts and hereby incorporated within the charts.
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`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`the Encore II Ta(N) barrier chamber) and TiN layers (e.g., Cirrus ionized PVD chamber). See, e.g.,
`DEMSAM00003329–30 (TaN layers); DEMSAM00003323–24 (TiN layers).
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`As an example, a reactor from Applied Materials is shown below:
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`As a further example, Samsung may modify or caused to be modified reactors from Applied Materials with
`application-specific process kits to deposit specific materials. The Endura product line includes reactors that can
`be configured for deposition of TaN layers (e.g., CuBS RFX PVD with the Encore II Ta(N) barrier chamber)
`and TiN layers (e.g., Cirrus ionized PVD chamber). See, e.g., DEMSAM00003329–30 (TaN layers),
`DEMSAM00003323–24 (TiN layers).
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`As an example, an image of an Endura CuBS RFX PVD is shown below:
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`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`To the extent the claim preamble is deemed limiting, Samsung Accused Products thus meet this limitation.
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`[a] a target area for
`receiving a target;
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`The Samsung Accused Products comprise a target area for receiving a target and Samsung uses such reactors
`configured as required in a variety of infringing ways in the production of Samsung semiconductor products.
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`As an example, for Samsung Accused Products, “[i]n PVD, the target is the source of the material to be
`deposited. Atoms are ejected from the target as a result of the bombardment of energetic particles.”
`DEMSAM00003379; see Dkt. No. 21 (Answer) (for example, see specifically ¶ 54 (“SEC and SAS admit that
`in some processes for fabricating semiconductor products, they use a nitrogen gas, a target, and a substrate.”)).
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`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`As a further example, Samsung uses Samsung Accused Products configured according to the ’276 Patent for
`depositing TaN in certain of its semiconductor products. In such configurations, tantalum is the source material
`(i.e., the metal target). The reactors as configured include a target area (indicated as “target” in the image
`below) for receiving the tantalum:
`
`DEMSAM00003188–3240 (for example, see specifically at DEMSAM00003232 (Fig. 1)) (annotated).
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`As an example, the target and target area in an Endura PVD reactor is shown below:
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`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`[b] a substrate area
`opposite the target
`area for receiving a
`substrate;
`
`The Samsung Accused Products comprise a substrate area opposite the target area for receiving a substrate and
`Samsung uses such reactors configured as required in a variety of infringing ways in the production of Samsung
`semiconductor products.
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`As an example, for Samsung Accused Products a substrate is “[t]he material upon which thin films are
`manipulated. Silicon is most commonly used for semiconductors ....” DEMSAM00003378; see Dkt. No. 21
`(Answer) (for example, see specifically ¶ 54 (“SEC and SAS admit that in some processes for fabricating
`semiconductor products, they use a nitrogen gas, a target, and a substrate.”)).
`
`As a further example, the substrate in Samsung Accused Products configured according to the ’276 Patent for
`deposition of a TaN barrier layer in Samsung’s DDR4 SDRAM products, for instance, is a silicon wafer. The
`reactors as configured include a substrate area is opposite the target area for receiving the silicon substrates
`(indicated as “wafer”) as illustrated below:
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 18 of 62
`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`See DEMSAM00003188–3240 (for example, see specifically at DEMSAM00003232 (Fig. 1)) (annotated).
`
`As an example, the substrate area in an Endura PVD reactor is shown below:
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`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`[c] a pulsed DC power
`supply coupled to the
`target area, the pulsed
`DC power supply
`providing alternating
`negative and positive
`voltages to the target;
`
`The Samsung Accused Products comprise a pulsed DC power supply coupled to the target area, the pulsed DC
`power supply providing alternating negative and positive voltages to the target and Samsung uses such reactors
`configured as required in a variety of infringing ways in the production of Samsung semiconductor products.
`
`For example, in Samsung Accused Products configured according to the ’276 Patent a power source is coupled
`to the target area as illustrated below:
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 20 of 62
`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`See DEMSAM00003188–3240 (for example, see specifically at DEMSAM00003232 (Fig. 1)) (annotated).
`
`As a further example, the presence of a DC power unit in a reactor for RMS deposition (e.g., TaN when using a
`tantalum target and a process gas that includes nitrogen) is illustrated below:
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 21 of 62
`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`See DEMSAM00003161–79 (for example, see specifically at DEMSAM00003169 (“DC” power supply in 1st
`generation iPVD products).
`
`As an example, a pulsed DC power unit in an Endura reactor configured for RMS deposition (e.g., TaN, when
`using a tantalum target and a process gas that includes nitrogen) is shown below:
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 22 of 62
`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
`
`[d] an RF bias power
`supply coupled to the
`substrate; and
`
`The Samsung Accused Products comprise an RF bias power supply coupled to the substrate and Samsung uses
`such reactors configured as required in a variety of infringing ways in the production of Samsung
`semiconductor products.
`
`For example, in Samsung Accused Products configured according to the ’276 Patent a power supply is coupled
`to the substrate area to bias the substrate as illustrated below:
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 23 of 62
`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
`
`See DEMSAM00003188–3240 (for example, see specifically at DEMSAM00003232 (Fig. 1)) (annotated).
`
`As an example, the presence of an RF bias power supply in an Endura reactor for RMS deposition (e.g., TaN,
`when using a tantalum target and a process gas that includes nitrogen) is shown below:
`
`[e] a narrow band-
`rejection filter that
`rejects at a frequency
`of the RF bias power
`supply coupled
`between the pulsed
`DC power supply and
`the target area.
`
`The Samsung Accused Products comprise a narrow band-rejection filter that rejects at a frequency of the RF
`bias power supply coupled between the pulsed DC power supply and the target area and Samsung uses such
`reactors configured as required in a variety of infringing ways in the production of Samsung semiconductor
`products.
`
`For example, in Samsung Accused Products configured according to the ’276 Patent, a narrowband filter is
`coupled between the pulsed DC power supply and the target area in a reactor for deposition of tantalum nitride
`(when using a tantalum target and a process gas that includes nitrogen). A narrowband filter is used in the
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 24 of 62
`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`Samsung Accused Products as configured to, for example, protect the pulsed DC power supply from feedback
`from the RF bias power supply.
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 25 of 62
`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 26 of 62
`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 27 of 62
`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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`Case 5:20-cv-05676-EJD Document 42-8 Filed 12/07/20 Page 28 of 62
`Exhibit A – Claim Chart for U.S. Patent No. 7,544,276
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