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Case 5:20-cv-09341-EJD Document 145-4 Filed 04/01/22 Page 1 of 5
`Case 5:20-cv-09341-EJD Document 145-4 Filed 04/01/22 Page 1of5
`
`EXHIBIT C
`EXHIBIT C
`
`
`
`
`
`

`

`
`
`Case 6:20-cv-00634-ADA Document 106 Filed 08/17/21 Page 1 of 4Case 5:20-cv-09341-EJD Document 145-4 Filed 04/01/22 Page 2 of 5
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`
`DEMARAY LLC,
` Plaintiff
`
`-v-
`
`INTEL CORPORATION,
` Defendant
`
`
`
`DEMARAY LLC,
` Plaintiff
`
`-v-
`
`SAMSUNG ELECTRONICS CO., LTD.
`(A KOREAN COMPANY), SAMSUNG
`ELECTRONICS AMERICA, INC.,
`SAMSUNG SEMICONDUCTOR, INC.,
`SAMSUNG AUSTIN
`SEMICONDUCTOR, LLC,
` Defendants
`








`













`
`
`
`W-20-CV-00634-ADA
`
`
`
`
`
`
`
`
`W-20-CV-00636-ADA
`
`
`
`
`CLAIM CONSTRUCTION ORDER
`
`The Court held a Markman hearing on August 17, 2021. During that hearing, the Court
`
`provided its final constructions. The Court now enters those claim constructions.
`
`
`
`SIGNED this 17th day of August, 2021.
`
`
`
`
`
`
`
`ALAN D ALBRIGHT
`UNITED STATES DISTRICT JUDGE
`
`

`

`
`
`Case 6:20-cv-00634-ADA Document 106 Filed 08/17/21 Page 2 of 4Case 5:20-cv-09341-EJD Document 145-4 Filed 04/01/22 Page 3 of 5
`
`Term
`
`“Substrate”
`
`U.S. Patent Nos. 7,381,657,
`Claims 1, 2, 7, 11; 7,544,276,
`Claims 1, 2, 6, 10
`
`Proposed by Defendants
`
`
`“A method of depositing a film
`on an insulating substrate,
`comprising”
`
`U.S. Patent No. 7,381,657,
`Claim 1
`
`Proposed by Defendants
`
`“Providing pulsed DC power”
`
`U.S. Patent No. 7,381,657,
`Claims 1, 2, 11
`
`Proposed by Defendants
`
`“Pulsed DC power supply”
`
`7,544,276 Patent, Claims 1, 6
`
`Proposed by Defendants
`
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning,
`
`or “material that provides the
`surface on which something is
`deposited or inscribed, for
`example a silicon wafer used
`to manufacture integrated
`circuits”
`
`Preamble is not limiting
`
`
`Defendants’ Proposed
`Construction
`“base support structure”
`
`or “base support structure that
`provides the surface on which
`something is deposited, for
`example the entirety of a wafer
`and all layers on that wafer”
`
`
`Court’s Final
` Construction
`Plain-and-ordinary meaning,
`which includes, but is not
`limited to a wafer coated with
`an insulator
`
`
`Preamble is limiting.
`
`“insulating substrate” means
`“insulating [substrate]”
`
`
`Preamble is not limiting,
`except for “insulating
`substrate”
`
`
`Plain and ordinary meaning,
`
`or “pulsed DC power” means
`“direct current power that
`oscillates between positive and
`negative voltages”
`
`“providing DC power in the
`form of a square wave at a set
`frequency, reverse time,
`and amplitude”
`
`
`“direct current power that
`oscillates between positive and
`negative voltages”
`
`
`Plain and ordinary meaning
`
`or “supply for providing
`[pulsed DC power]”
`
`
`“power supply, which provides
`DC power in the form of a
`square wave at a set frequency,
`reverse time, and amplitude”
`
`
`“supply for providing pulsed
`DC power”
`
`
`

`

`
`
`Case 6:20-cv-00634-ADA Document 106 Filed 08/17/21 Page 3 of 4Case 5:20-cv-09341-EJD Document 145-4 Filed 04/01/22 Page 4 of 5
`
`Term
`
`“Narrow band rejection filter”
`
`U.S. Patent Nos. 7,381,657,
`Claims 1, 2, 20; 7,544,276,
`Claims 1, 6
`
`Proposed by Defendants
`
`
`“Reconditioning the target”
`
`U.S. Patent No. 7,381,657,
`Claim 1
`
`Proposed by Defendants
`
`(a) “Metallic mode”
`
`U.S. Patent No. 7,381,657,
`Claims 1, 2
`
`(b) Poison mode”
`
`U.S. Patent No. 7,381,657,
`Claims 1, 2
`
`Proposed by Plaintiff
`
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning,
`
`or “filter which rejects a
`narrow band of frequencies”
`
`
`Plain and ordinary meaning, or
`“cleaning and conditioning the
`target”
`
`
`(a): “mode of operation in
`which the surface of the target
`is substantially metallic”
`
`(b): “mode of operation in
`which the rate of the thin film
`formation on the surface of the
`target equals or exceeds the
`rate of sputter removal of the
`surface of the target”
`
`
`Defendants’ Proposed
`Construction
`“filter which rejects a narrow
`band of frequencies (but passes
`[substantially] all frequencies
`outside of the narrow band)”
`
`or “filter that rejects a narrow
`band of frequencies centered
`on one RF bias frequency”
`
`“conditioning the target
`between depositions”
`
`
`Court’s Final
` Construction
`Plain-and-ordinary meaning
`
`
`Plain-and-ordinary meaning
`
`
`Plain and ordinary meaning for
`each
`
`
`Metallic mode: Plain-and-
`ordinary meaning
`
`Poison mode: Plain-and-
`ordinary meaning
`
`
`

`

`
`
`Case 6:20-cv-00634-ADA Document 106 Filed 08/17/21 Page 4 of 4Case 5:20-cv-09341-EJD Document 145-4 Filed 04/01/22 Page 5 of 5
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning,
`
`or “substantially constant”
`means “within about 10°C”
`
`
`Defendants’ Proposed
`Construction
`“the substrate temperature to
`be within about 10 °C of the
`set temperature”
`
`
`Court’s Final
` Construction
`Plain-and-ordinary meaning
`
`
`Term
`
`“the temperature of the
`substrate substantially
`constant”
`
`U.S. Patent Nos. 7,381,657,
`Claim 7; 7,544,276, Claim 10
`
`Proposed by Defendants
`
`
`
`
`

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