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`Trial No. IPR2014-00477
`Docket No. 0110198-00195 US1
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`Filed on behalf of The Gillette Company
`By: David L. Cavanaugh, Reg. No. 36,476 (Lead Counsel)
`Yung-Hoon Ha, Reg. No. 56,368 (Back-up Counsel)
`Wilmer Cutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Avenue NW
`Washington, DC 20006
`Tel: (202) 663-6025
`Email: David.Cavanaugh@wilmerhale.com
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________________________________
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`THE GILLETTE COMPANY
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`Petitioner
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`v.
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`ZOND, LLC
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`Patent Owner of
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`U.S. Patent No. 8,125,155
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`IPR Trial No. IPR2014-00477
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`PETITIONER’S REPLY
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`Claims 1-16
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`Trial No. IPR2014-00477
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`TABLE OF CONTENTS
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`I.
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`INTRODUCTION ......................................................................................... 1
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`ZOND CONCEDES THAT INDEPENDENT CLAIM 1 AND ITS
`II.
`DEPENDENT CLAIMS ARE TAUGHT BY THE PRIOR ART ...................... 2
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`III. ZOND’S NEWLY PROPOSED CONSTRUCTION IS ERRONEOUS .. 4
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`IV. WANG TEACHES THE CLAIM LIMITATIONS EVEN UNDER
`ZOND’S NEWLY PROPOSED CONSTRUCTION ............................................ 7
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`THE ALLEGED “INCOMPATIBILITIES BETWEEN
`V.
`KUDRYAVTSEV AND WANG” ARE BASED ON MISUNDERSTANDINGS
`OF BOTH FACT AND LAW ............................................................................... 10
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`VI. ZOND’S ALLEGED EVIDENCE OF SECONDARY
`CONSIDERATIONS OF NON-OBVIOUSNESS IS FLAWED ....................... 13
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`VII. DEPENDENT CLAIMS 9, 15 AND 16 ARE OBVIOUS ......................... 13
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`Dependent Claim 9 ..................................................................... 14
`A.
`Dependent Claim 15 and 16 ....................................................... 14
`B.
`VIII. CONCLUSION ............................................................................................ 15
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`Trial No. IPR2014-00477
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`TABLE OF AUTHORITIES
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`CASES
`In re Mouttet, 686 F.3d 1322, 1332 (Fed. Cir. 2012) ……………………..12
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` Page(s)
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`In re Etter, 756 F.2d 852, 859 (Fed. Cir. 1985) (en banc)…………………12
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`I.
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`INTRODUCTION
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`In its Decision on Institution (“DI”), the Board recognized there is a
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`reasonable likelihood that the challenged claims 1-16 are unpatentable. See
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`IPR2014-477 DI at pp. 24-25. In fact, the Board reached its conclusion after
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`adopting the constructions proposed by Zond. Belatedly recognizing that the
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`Board correctly reached its conclusion even under Zond’s earlier proposed
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`construction, Zond now attempts to distinguish the prior art by proposing a new,
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`but flawed, construction. In fact, Zond failed to even address why the challenged
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`claims are valid under the previous construction adopted by the Board, effectively
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`conceding that the challenged claims are unpatentable under the construction
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`adopted by the Board.
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`None of the arguments raised by Zond is sufficient to alter the
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`determination of the Board in its Decision on Institution. First, Zond’s newly
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`proposed construction is not supported by the patent specification itself and
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`therefore should not be adopted. Even if the newly proposed construction were
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`adopted, the cited prior art nevertheless render the claims unpatentable.
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`The Petition, supported by Mr. DeVito’s declaration, demonstrates why one
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`of ordinary skill in the art would have combined the teachings of the cited
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`references. The cross examination testimony of Dr.Hartsough, Zond’s declarant,
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`further confirms that the references were in the same art and would have been
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`combined. Petitioner also provides the declaration of Dr. John Bravman, who
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`reached the same conclusion: that the references would have been combined by
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`one of ordinary skill in the art and that the challenged claims are unpatentable.1
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`II.
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`ZOND CONCEDES THAT INDEPENDENT CLAIM 1 AND ITS
`DEPENDENT CLAIMS ARE TAUGHT BY THE PRIOR ART
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`Zond’s expert, Dr. Hartsough concedes that all limitations recited in
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`independent claim 1 were well known before the effective date of the ‘155 patent.
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`See Ex. 1023 (“’155 Hartsough Depo.”) at 80:23-81:18; 84:25-86:23; 87:15-21;
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`82:17-23; 196:19-197:1; and 200:19-21. Zond does not challenge that dependent
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`claims 2-8 and 10-14 are unpatentable.
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`The only dispute remaining as to independent claim 1 is whether the cited
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`references “teach the claimed control of voltage amplitude or rise time to avoid arc
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`when rapidly forming a strongly ionized plasma.” IPR2014-477, Patent Owner
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`Response (“PO Resp.”) at p. 27. However, it is clear from Dr. Hartsough’s
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`concessions that this was well-known.
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`Avoiding Arcing
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`Wang teaches that “the chamber impedance changes relatively little
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`between the two power levels PB, PP since a plasma always exist in the chamber.”
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`Ex. 1002 (“Wang”) at 7:49-51.
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`1 Mr. DeVito is no longer available to provide testimony.
`2
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`Dr. Hartsough conceded as follows:
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`Q: But if impedance changes relatively little during the
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`transition from a low-to a high-density plasma, then it’s indicative of
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`no short circuit or arcing; right?
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`…
`A: That’s indicative of no – certainly no unipolar arc…”)
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`Ex. 1024 (“’775 Hartsough Depo.”) at 89:8-24 (emphases added). Accordingly,
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`Wang, which explicitly teaches that impedance changes relatively little between PB
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`and PP, therefore teaches the avoidance of arcing when strongly-ionized plasma is
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`generated with the application of peak power pulses PP.
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`Control of Voltage Amplitude or Rise Rime when Rapidly Forming a
`Strongly Ionized Plasma
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`It is undisputed that controlling voltage amplitude or rise time when rapidly
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`forming a strongly-ionized plasma was well-known long before the ‘155 patent.
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`See IPR2014-477, Petition at pp. 15-18 and Ex. 1005 (“DeVito Dec.”) at ¶¶ 104-
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`111. As conceded by Dr. Hartsough, the ‘155 patent itself admits this limitation as
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`being prior art.
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`Q: And Figure 10 is prior art; right?
`…
`A: So as Figure 10 is illustrated – or described as prior art.
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`So he’s saying that it can generate voltage pulses.”
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`Q: Choosing a voltage pulse rise time was well known before
`the alleged ‘155 invention; correct?
`…
`A: Again, Dr. Chistyakov says that these pulses are according
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`to the present invention, and -- so I will use my understanding of
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`what he said there, since a controlled rise time is part of his present
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`invention, that these power supplies could do that.”
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`’155 Hartsough Depo. at 84:25-86:23 (emphases added).
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`Zond also does not challenge that this limitation is met by Wang under the
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`construction adopted by the Board in the Decision on Institution. Accordingly,
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`Zond has conceded that this limitation is taught by the cited prior art under the
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`construction adopted by the Board.
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`III. ZOND’S NEWLY PROPOSED CONSTRUCTION IS ERRONEOUS
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`Zond seeks to modify the construction adopted by the Board, effectively
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`conceding that the challenged claims are invalid under the Board’s construction.
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`In particular, Zond seeks to add the additional requirements underlined below:
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`Claim Language at Issue
`“Generating at the output a voltage
`pulse having at least one of a
`controlled amplitude and a
`controlled rise time that increases an
`ionization rate of sputtered ion
`material atoms so that a rapid increase
`in electron density and a formation of
`a strongly ionized plasma occurs
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`Newly Proposed Construction
`Generating at the output a voltage pulse
`whose amplitude and/or rise time are
`controlled variables that are directed or
`restrained to a target voltage level and/or
`a rise time level to increase an ionization
`rate of sputtered ion material atoms so that
`a rapid increase in electron density and a
`formation of a strongly ionized plasma
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`occurs without forming an arc.
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`without forming an arc…”
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`However, this newly proposed construction is inconsistent with the patent’s
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`specification. For example, Zond asserts that the newly proposed construction
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`requires the use of a feedback control system, such as those disclosed by the
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`Eronini reference. But the Eronini reference has no apparent relationship to the
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`‘155 patent. Ex. 2015 (“Hartsough Dec.”) at ¶¶ 37-40. Indeed, Dr. Hartsough was
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`unable to identify any teaching in the ‘155 patent that would suggest such a
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`feedback control system exists in the claimed invention. Ex. 1025 (“’184
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`Hartsough Depo.”) at 177:21-178:5 (“Q: Can you show me anywhere in the 184
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`patent any reference to a feedback loop that’s connected to a sensor?…A: No.”).
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`See also Ex. 1026 (“Bravman Dec.”) at ¶¶ 64-70.
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`Unsurprisingly, without the teaching of any such feedback control system,
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`none of the examples provided in the patent specification shows the actual ouput
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`voltage amplitude and/or rise time that are “directed or restrained to a target
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`voltage level and/or a rise time level.” For example, Zond touts Fig. 8 of the ‘155
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`patent as an “example [that] demonstrates the compelling advantages of
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`combining voltage amplitude control with voltage rise time control…” IPR2014-
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`477, PO Resp. at p. 16 (emphasis added). Fig. 8 is also compared with Fig. 3,
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`which Zond assert “is NOT an example of the claimed controlled pulse,”
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`(IPR2014-477 PO Resp. at p. 18) (emphasis added), but which the Board relied on
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`in adopting the previous construction proposed by Zond. IPR2014-477 DI at 9-10.
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`Zond’s arguments distort what is shown in these figures. In both figures, the
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`“target” voltage profiles (overlaid with red) are square. See Ex. 1001 (“’155
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`Patent”) at 6:12-13 and 18:19-20. However, the actual voltage pulses (overlaid
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`with green), are clearly different in shape. See ’155 Patent at 6:14-7:4 and 18:28-
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`67. Specifically, in both figures, the actual output voltage amplitude and rise time
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`(in green) is not “directed or restrained” to the target value because there are
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`numerous fluctuations that exceed and/or undershoot the target voltage level, and a
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`lag in rise time is observed as compared to the target value. Accordingly, the ‘155
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`patent specification fails to support Zond’s newly proposed construction that the
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`“voltage pulse … amplitude and/or rise time … are directed or restrained to a
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`target voltage level and/or a rise time level.” In fact, such a construction would
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`effectively read out what Zond calls its most “compelling” embodiment from the
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`claims, IPR2014-477, PO Resp. at p. 16, as well as all of Zond’s other
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`embodiments. See ’155 Patent at Figs. 4-7. See also Bravman Dec. at ¶¶ 53-61.
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`Moreover, the reason why a high-density plasma was formed in Fig. 8, and
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`not in Fig. 3, is not because the “voltage pulse … amplitude and/or rise time … are
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`directed or restrained to a target voltage level and/or a rise time level.” This fact
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`is explained by a completely different reason: because the power supply in Fig. 8
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`“operates in a high-power mode throughout the duration of the voltage pulse 452,”
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`(’155 Patent at 18:20-22), whereas the power supply in Fig. 3 “operat[es] in a low-
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`power voltage mode.” ’155 Patent at 5:63-65. See also Bravman Dec. at ¶ 59. As
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`Dr. Hartsough declares, this difference in power modes is reflected in power that
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`“varies from about 1.2 to 13 kW” for the prior art low-current plasma and “100 to
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`several hundred kW” for the high-current plasma shown in Fig. 2. Hartsough Dec.
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`at ¶¶ 73-74. Simply put, in Fig. 8, the power supply “suppl[ies] a sufficient
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`amount of uninterrupted power to drive the plasma from the transient non-steady
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`state to a strongly-ionized state ….” ’155 Patent at 13:44-56 (emphasis added).
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`See also Bravman Dec. at ¶ 59.
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`Accordingly, Board’s originally adopted construction is correct. The
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`Board’s construction is consistent with the requirements of the ‘155 patent
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`specification that the voltage pulse amplitude and/or rise time is directed or
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`restrained by supplying a sufficient amount of uninterrupted power to drive the
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`plasma to a strongly-ionized state.
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`IV. WANG TEACHES THE CLAIM LIMITATIONS EVEN UNDER
`ZOND’S NEWLY PROPOSED CONSTRUCTION
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`Zond does not dispute that Wang meets the limitation under the construction
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`adopted by the Board. Rather, Zond argues that “Wang makes no mention
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`whatsoever of controlling the voltage amplitude,” (IPR2014-477 PO Resp. at 42),
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`based on Zond’s newly proposed construction. However, even under this newly
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`propsoed construction, Wang discloses the limitation to those skilled in the art.
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`Zond’s own declarant, Dr. Hartsough, concedes that Wang teaches the
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`application of negative voltage pulses during the application of peak power pulses.
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`’155 Hartsough Depo. at 152:17-154:17 (“Q: The negative voltage pulses that
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`correspond to PP are shown in Figure 7; correct?…A: Yes.”). Wang further
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`explains that a typical “pulsed power supply will output relative high voltage and
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`almost no current in the ignition phase and a lower voltage and substantial current
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`in the maintenance phase.” Wang at 5:32-35. As Dr. Hartsough conceded during
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`his deposition regarding the ‘775 patent, Figure 5 of the ‘775 patent illustrates a
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`typical power supply described by Wang, reproduced below with colored
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`annotations. ’775 Hartsough Depo. at 149:22-150:20 (“Q. So we can agree that
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`Wang is explaining how a typical pulsed power supply operates; right? A: Yes. …
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`Q: And that’s exactly what Figure 5 of the ‘775 patent is showing; right?…A:
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`Yes.”).
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`As shown above at left, in Fig. 5 of the ‘775 patent, when the voltage pulse
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`is initially applied (red region), voltage (green region) is initially higher with low
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`current (purple region). Then, when the strongly-plasma is generated (blue
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`region), the voltage (green regionb) becomes lower with the corresponding rise in
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`current (purple region). This is exactly how Zond’s “compelling example” of Fig.
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`8 also operates shown above at right. Specifically, the ‘155 patent explains that
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`“[t]he single voltage pulse 452 includes a voltage 456 that is sufficient to ignite an
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`initial plasma [see red region]… and a voltage 472 that is sufficient to sustain the
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`strongly-ionized plamsa [see blue region].” ’155 Patent at 18:57-61 (emphases
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`added). Both figures behave nearly identically -- the difference is that the figure
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`on the left is “a depiction of a – of an idealized state” for typical power supplies
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`described in Wang and “variations” will exist in actual measured data as shown on
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`the right, ’775 Hartsough Depo. at 132:10-16 and 136:12-25, both figures behave
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`nearly identically to one another.
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`Accordingly, to the extent that Fig. 8 meets Zond’s newly proposed
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`construction, Wang also meets Zond’s newly proposed construction. The
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`challenged claims are therefore invalid under both constructions.
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`V. THE ALLEGED “INCOMPATIBILITIES BETWEEN
`KUDRYAVTSEV AND WANG” ARE BASED ON
`MISUNDERSTANDINGS OF BOTH FACT AND LAW
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`The Petition and Mr. DeVito’s declaration provide ample rationale to
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`combine the references. See, e.g., IPR2014-477, Petition at pp.16-18; DeVito Dec.
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`at ¶¶ 106-111. As explained therein, one of ordinary skill would have been
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`motivated to use Kudryavtsev’s explosive ionization in Wang, so as to increase
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`plasma density and thereby increase the sputtering rate. Use of Kudryavtsev’s
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`teaching in Wang would have been a combination of old elements yielding the
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`predictable result of rapidly increasing the ionization rate and electron density,
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`which is known to be a desirable result. See Bravman Dec. at ¶¶ 85-90.
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`Zond, however, argues that the references are incompatible with one another
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`and that one skilled in the art would not have been able to combine them.
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`IPR2014-477 PO Resp. at pp. 52-55. These arguments are wrong as matter of both
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`fact and law.
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`In particular, Zond argues that both Wang and Kudryavtsev teach arcing,
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`contrary to the claims. This is factually incorrect. As explained above, Dr.
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`Hartsough conceded that Wang does not have arcing. ’775 Hartsough Depo. at
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`89:8-24. Moreover, Kudryavtsev teaches conditions where uniform plasma, which
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`is indicative of no arcing, can be obtained. Bravman Dec. at ¶¶ 83-84.
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`Zond further contends that Kudryavtsev and Wang would not be combined
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`because they are “not even in the same field.” IPR2014-477 PO Resp. at p. 53.
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`This is also factually incorrect, and indeed contrary to the ‘155 patent itself. That
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`is, the ‘155 patent cites to Kudryavtsev, confirming that Kudryavtsev is indeed in
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`the same field. This is consistent with Kudryavtsev’s teaching that “the effects
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`studied in this work are characteristic of ionization whenever a field is suddenly
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`applied to a weakly ionized gas, they must be allowed for when studying emission
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`mechanisms in pulsed gas lasers, gas breakdown, laser sparks, etc.” Ex. 1008
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`(“Kudryavtsev”) at p. 34, right col., last ¶ (emphasis added). Moreover,
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`Kudryavtsev had long been considered by others in the field of pulsed magnetron
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`sputtering when designing pulsed magnetron sputter reactors. For example,
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`Mozgrin, which studied “high-current magnetron discharge (regime 2) in
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`sputtering or layer deposition technologies,” (Ex. 1004 (“Mozgrin”) at p. 409, left
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`col., ¶3; p. 403, right col., ¶3), took into account the dependences which had been
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`obtained in [Kudryavtsev] of ionization relaxation on pre-ionization parameters,
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`pressure, and pulse voltage amplitude.” Mozgrin at p. 401, right col. ¶1.
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`Zond’s own expert retreated from his position that a person of ordinary skill
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`in the art would not look to Kudryavtsev “at all,” effectively narrowing his
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`argument to the technical nuances of physical substitution:
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`Q: Sir, it’s pretty strong language that you used to say a person
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`would not refer to Kudryavtsev at all when designing a plasma
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`generator whose purpose is to form a strongly-ionized plasma without
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`forming an arc.
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`A: Yes, that’s what I said.
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`Q: And my question is: Do you want to revise that language or
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`do you stand by the strong language today?
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`A: … So I would revise that statement --…
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`’155 Hartsough Depo. at 230:11 – 235:7.
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`As Dr. Bravman explains, a person of ordinary skill in the art would have
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`combined the teachings of Wang with Kudryavtsev, despite the physical
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`differences that may exist, just as Mozgrin had done in applying Kudryavtsev in
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`designing his magnetron sputtering system. Bravman Dec. at ¶¶ 85-90.
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`Moreover, such technical nuances of physical substitution have been
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`rejected by the Board. IPR2014-477, DI at p. 16. As the Board explained, “[i]t is
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`well-established that a determination of obviousness based on teachings from
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`multiple references does not require an actual, physical substitution of elements.”
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`In re Mouttet, 686 F.3d 1322, 1332 (Fed. Cir. 2012) (citing In re Etter, 756 F.2d
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`852, 859 (Fed. Cir. 1985) (en banc).
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`Accordingly, Zond’s argument is both factually incorrect and applies the
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`wrong standard. For these reasons, it should be rejected.
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`VI. ZOND’S ALLEGED EVIDENCE OF SECONDARY
`CONSIDERATIONS OF NON-OBVIOUSNESS IS FLAWED
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`Although Zond’s Response makes a fleeting and unsupported statement
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`about “secondary consideration,” IPR2014-477 PO Resp. at p. 55, it does not
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`provide any substantive argument or evidence of secondary considerations of non-
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`obviousness. The sole argument rests on the alleged admission of Mr. DeVito that
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`“one skilled in art would require much experimentation (six months to a year).”
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`IPR2014-477 PO Resp. at p. 56.
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`However, as Mr. DeVito explained, this estimate was based on his
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`assumption that one “would have to build a prototype system first which would
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`take up the marjority of the – that would take obviously the majority of the time.”
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`Ex. 2014 (“’155 DeVito Depo.”) at 306:2-6. With that assumption removed, that
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`is, “if the system already existed,” Mr. DeVito testified that he and a team of
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`engineers/technicians could carry out “routine engineering experiments” and “do
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`all the experiments in maybe less than a month.” ’155 DeVito Depo.at 307:1-13.
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`See also Bravman Dec. at ¶ 90.
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`Thus, Zond has not presented any evidence of secondary considertaions to
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`rebut the prima facie case of obviousness.
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`VII. DEPENDENT CLAIMS 9, 15 AND 16 ARE OBVIOUS
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`A. Dependent Claim 9
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`Zond asserts that “energy storage device” 147 must be separate from the
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`pulsed power supply and that capacitors found in power supply 80 cannot meet this
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`limitation. IPR2014-477 PO Resp. at pp. 57-58.
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`However, the ‘155 patent specifically teaches that “the energy storage device
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`147 includes a capacitor bank.” ’155 Patent at 3:46-47 (emphasis added).
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`Similarly, the prior art power supplies shown in Figs. 10-13 teaches “a bank of
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`capacitors 556,” with a “parallel bank of high-power solid state switches 558” that
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`“release energy stored in the capacitors 556.” ’155 Patent at 21:15-24.
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`As one skilled in the art would readily recognize, a “capacitor bank” teaches
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`a plurality of capacitors, each coupled with switches that would output the desired
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`voltage, when needed. Bravman Dec. at ¶¶ 100-105. As such, Zond’s argument
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`fails. The claimed pulsed power supply can be considered to include any number
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`of these capacitors and switches and the energy storage device can be considered to
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`include the remaining capacitors and switches found in the pulsed power supply.
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`B. Dependent Claim 15 and 16
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`Zond points to the sustained current 446 of Fig. 7A of the ‘155 patent as an
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`example of a pulse that “sustains the plasma for the duration of the pulse,”
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`(IPR2014-477 PO Resp. at pp. 58-59), to meet the limitations “the voltage pulse
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`sustains the strongly-ionized plasma” and “a lifetime of the strongly-ionized
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`plasma is greater than about 200 µsec,” recited in
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`claims 15 and 16. Figure 7A of the ‘155 patent
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`is also reproduced (right) with annotations.
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`Zond’s only argument is that “since Wang
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`does not show the current, there is no way to
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`determine whether Wang’s pulses sustain the
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`plasma for the duration of his pulse.” IPR2014-
`
`477 PO Resp. at p. 59. However, as discussed
`
`above, Dr. Hartsough admitted that Wang’s
`
`typical power supplies can be schematically
`
`represented by Fig. 5 of the ‘775 patent, (Ex.
`
`1027), reproduced (right) with annotations. As shown, Wang’s typical power
`
`supply sustains the current (purple) throughout the duration of Wang’s power
`
`pulse, just as shown in Figure 7A of the ‘155 patent. Bravman Dec. at ¶ 106-110.
`
`Accordingly, Wang teaches the added limitations of claims 15 and 16.
`
`VIII. CONCLUSION
`
`Board correctly found that there was a reasonable likelihood that the claims
`
`were unpatentable. None of Zone’s arguments undermine that conclusion. As set
`
`forth in the Petition and the supporting declarations, claims 1-16 are unpatentable,
`
`under either construction proposed by Zond.
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`15
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`Customer Number:
`Tel: (202) 663-6025
`Fax: (202) 663-6363
`
`
`
`Trial No. IPR2014-00477
`Docket No. 0110198-00195 US1
`Respectfully submitted,
`
`Petitioner
`By: /David L. Cavanaugh/
`David L. Cavanaugh
`Registration No. 36,476
`Wilmer Cutler Pickering
`Hale and Dorr, L.L.P.
`
`
`
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`16
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`
`
`Trial No. IPR2014-00477
`Docket No. 0110198-00195 US1
`CERTIFICATE OF SERVICE
`
`I hereby certify that, on March 23, 2015, I caused a true and correct copy of
`
`the foregoing materials:
`
` Petitioner’s Reply
`
` Exhibits 1023-1027
`
` Exhibit Appendix
`
`to be served via email, as previously agreed between the parties, on the following
`
`counsel of record for Patent Owner:
`
`Date of service March 23, 2015
`
`Manner of service Email: gonsalves@gonsalveslawfirm.com;
`bbarker@chsblaw.com; kurt@rauschenbach.com
`
`
`Persons Served Dr. Gregory J. Gonsalves
`2216 Beacon Lane
`Falls Church, Virginia 22043
`
`Bruce Barker
`Chao Hadidi Stark & Barker LLP
`176 East Mail Street, Suite 6
`Westborough, MA 01581
`
`
`
`
`
`
`/Yung-Hoon Ha/
`Yung-Hoon Ha
`Registration No. 56,368
`7 World Trade Center
`250 Greenwich Street
`New York, NY10007
`
`
`
`
`17
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`Trial No. IPR2014-00477
`Docket No. 0110198-00195 US1
`EXHIBIT APPENDIX
`
`Description
`Exhibit
`Gillette 1001 U.S. Patent No. 8,125,155
`
`Gillette 1002 Wang, U.S. Patent No. 6,413,382
`
`Gillette 1003 Kouznetsov, U.S. Patent Publication 2005/0092596, filed June
`14, 2002
`Gillette 1004 D.V. Mozgrin, et al., High-Current Low-Pressure Quasi-
`Stationary Discharge in a Magnetic Field: Experimental
`Research, Plasma Physics Reports, Vol. 21, No. 5, 1995
`Gillette 1005 Declaration of Richard DeVito
`
`Gillette 1006
`
`Fu, U.S. Patent No. 6,306,265
`
`Gillette 1009
`
`Gillette 1010
`
`Gillette 1007 Communication from the Patent Owner to the EPO, mailed July
`23, 2009, in file history of EP 1 556 882
`Gillette 1008 A. A. Kudryavtsev, et al., Ionization relaxation in a plasma
`produced by a pulsed inert-gas discharge, Sov. Phys. Tech.
`Phys. 28(1), January 1983
`J.A. Thornton, Magnetron sputtering: basic physics and
`application to cylindrical magnetrons, J. Vac. Sci. Technol.,
`15(2), March/April 1978
`J.M. Schneider, et al., Recent developments in plasma assisted
`physical vapour deposition, Phys. D: Appl. Phys. 33 (2000),
`R173-R186
`J.T. Gudmundsson, et al., Evolution of the electron energy
`distribution and plasma parameters in a pulsed magnetron
`discharge, App. Phys. Lett. 78, 3427 (2001)
`Gillette 1012 Yoon, U.S. Patent No. 6,740,585
`
`Gillette 1011
`
`Gillette 1013 U.S. Patent No. 6,806,652
`
`Gillette 1014
`
`Etching: An Introduction, by Manos et al, Academic Press
`(1989) (“Manos”)
`Gillette 1015 U.S. Patent No. 7,147,759
`
`Gillette 1016 Grove TC. Arcing problems encountered during sputter
`deposition of aluminum. White Papers, ed: Advanced Energy,
`
`1
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`
`
`
`
`
`
`
`
`Trial No. IPR2014-00477
`Docket No. 0110198-00195 US1
`
`2000
`Sellers, J., Asymmetric bipolar pulsed DC: the enabling
`technology for reactive PVD. Surface & Coatings Technology
`vol. 98 issue 1-3 January, 1998. p. 1245-1250.
`Thornton, J. and Hoffman, D.W. Stress related effects in thin
`films. Thin Solid Films, 171, 1989, 5-31.
`
`Gillette 1017
`
`Gillette 1018
`
`Gillette 1019 N. Savvides and B. Window, Unbalanced magnetron ion‐
`
`assisted deposition and property modification of thin films, J.
`Vac. Sci. Technol. A 4 , 504, 1986.
`Gillette 1020 Rossnagel, S. M., & Hopwood, J., Magnetron sputter deposition
`with high levels of metal ionization. Applied Physics Letters,
`63(24), 3285-3287, 1993.
`Gillette 1021 Declaration of Mark Matuschak in Support of Unopposed
`Motion for Admission Pro Hac Vice
`Gillette 1022 Declaration of Cosmin Maier in Support of Unopposed Motion
`for Admission Pro Hac Vice
`Gillette 1023 Deposition Transcript of Larry D. Hartsough Ph.D. for U.S.
`Patent No. 8,125,155 (February 12, 2015)
`Gillette 1024 Deposition Transcript of Larry D. Hartsough Ph.D. for U.S.
`Patent No. 6,896,775 (February 19, 2015)
`Gillette 1025 Deposition Transcript of Larry D. Hartsough Ph.D. for U.S.
`Patent No. 7,808,184 (February 11, 2015)
`Gillette 1026 Declaration of John C. Bravman
`
`Gillette 1027 U.S. Patent No., 6,896,775
`
`
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`
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`2
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