UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________
`
`THE GILLETTE COMPANY, TAIWAN SEMICONDUCTOR
`MANUFACTURING COMPANY, LTD., TSMC NORTH AMERICA CORP.,
`FUJITSU SEMICONDUCTOR LIMITED, and FUJITSU SEMICONDUCTOR
`AMERICA, INC.
`
`Petitioners
`
`v.
`
`ZOND, LLC
`Patent Owner
`
`______________________
`Case No. IPR2014-005781
`
`Patent 6,896,775 B2
`
`______________________
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`DECLARATION OF LARRY D. HARTSOUGH, PH.D.
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`
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`                                                                                                                          
`1 Case IPR 2014-01494 has been joined with the instant proceeding.
`
`Gillette et al. v. Zond
`IPR2014-00578 Zond Ex. 2006
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`

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`
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`Table of Contents
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`I. Education and Professional Background .............................................................. 1
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`II. Summary ............................................................................................................. 5
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`III. Legal Standards ................................................................................................. 9
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`A. Level of Ordinary Skill in the Art. ................................................................ 10
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`B. Claim Interpretation. ..................................................................................... 10
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`C. Legal Standards for Anticipation. ................................................................. 13
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`D. Legal Standards for Obviousness. ................................................................. 13
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`IV. Background TOPICS ....................................................................................... 15
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`A. Voltage, current, impedance and power. ....................................................... 16
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`B. Control systems. ............................................................................................ 19
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`C. Set point (Controlled Parameter). ................................................................. 21
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`D. Power Control vs. Voltage Control. .............................................................. 22
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`E. Plasmas. ......................................................................................................... 24
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`F. Plasma ignition. ............................................................................................. 27
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`G. High-Density Plasmas. .................................................................................. 28
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`V. Scope and content of The prior art. ................................................................... 35
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`A. Wang. ............................................................................................................ 35
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`B. Kudryavtsev. ................................................................................................. 39
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`C. Mozgrin. ........................................................................................................ 41
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`D. Lantsman. ...................................................................................................... 41
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`VI. Claim Analysis vis-à-vis the Cited References ............................................... 43
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`A. It Would Not Have Been Obvious To Combine the Teachings of
`Wang, Mozgrin and Kudryavtsev To Achieve the Invention Claimed
`in the ’775 Patent. ................................................................................................ 43
`
`B. It Would Not Have Been Obvious To Combine the Teachings of Wang,
`Mozgrin and Lantsman To Achieve the Invention Claimed in the ’775 Patent. . 50
`
`C. The Combination of Wang, Mozgrin and Kudryavtsev Does Not Suggest
`“a cathode that is positioned adjacent to the anode and forming a gap there
`between,” as Recited in Independent Claim 1. .................................................... 52
`
`D. The Combination of Wang, Mozgrin and Kudryavtsev Does Not
`Suggest the Electric Field Across the Gap is “a quasi-static electric field,”
`as Recited in Dependent Claims 2 and 18. .......................................................... 59
`
`E. The Combination of Wang, Mozgrin and Kudryavtsev Does Not
`Suggest “a rise time of the electric field is chosen to increase an ionization
`rate of the excited atoms in the weakly-ionized plasma,” as Recited in
`Dependent Claim 4. ............................................................................................. 60
`
`F. The Combination of Wang, Mozgrin and Kudryavtsev Does Not
`Suggest “a rise time of the electric field is chosen to increase an etch rate
`of the surface of the substrate,” as Recited in Dependent Claim 5. .................... 63
`
`G. The Combination of Wang, Mozgrin and Kudryavtsev Does Not
`Suggest “selecting at least one of a pulse amplitude and a pulse width
`of the electrical pulse in order to cause the strongly-ionized plasma to be
`substantially uniform in an area adjacent to the surface of the substrate,” as
`required by dependent claim 21 or “the strongly ionized plasma is substantially
`uniform proximate to a surface of the substrate,” as recited in claim 24. ........... 65
`
`H. The Combination of Wang, Mozgrin and Lantsman Does Not Suggest
`“selecting at least one of a pulse amplitude and a pulse width of the electrical
`pulse that causes the strongly-ionized plasma to be substantially uniform in an
`area adjacent to the surface of the substrate,” as required by dependent
`claim 33. .............................................................................................................. 67
`
`I. The Combination of Wang, Mozgrin and Kudryavtsev Does Not
`Suggest “a volume between the anode and the cathode is chosen to increase
`an ionization rate of the excited atoms and molecules in the weakly-ionized
`
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`iii  
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`plasma,” as Required by Dependent Claim 9 ...................................................... 68
`
`J. The Combination of Wang, Mozgrin and Kudryavtsev Does Not Teach
`“applying the electric field at a constant power,” as recited in dependent
`claim 16 ............................................................................................................... 71
`
`K. The Combination of Wang, Mozgrin, Kudryavtsev and Lantsman
`Does Not Teach “applying the electric field at a constant voltage,” as
`recited in Dependent Claim 17 ............................................................................ 72
`
`VII. DECLARATION ........................................................................................... 73
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`iv  
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`I, Larry D. Hartsough, do hereby declare:
`
`1.
`
`I am making this declaration at the request of patent owner Zond, LLC, in
`
`connection with the Inter Partes Reviews (IPRs) of U.S. Patent No. 6,896,775 (the
`
`“‘775 patent”), set forth in the above caption.
`
`2.
`
`I am being compensated for my work in this matter at the rate of $300 per
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`hour. I have no interest in the ‘775 patent and my compensation in no way
`
`depends on the outcome of this proceeding.
`
`3.
`
`In forming the opinions set forth in this declaration I reviewed a number of
`
`materials, including the ‘775 patent, the file history of the ‘775 patent, the Petitions
`
`for Inter Partes Review and the cited references discussed below, the Patent Trial
`
`and Appeal Board’s (PTAB’s) Institution Decisions in these IPR proceedings, the
`
`transcripts of the depositions of Mr. Richard DeVito concerning the ‘775 patent,
`
`and the additional materials discussed herein.
`
`
`
`I. EDUCATION AND PROFESSIONAL BACKGROUND
`4. My formal education is as follows. I received a Bachelors of Science degree
`
`in 1965, Master of Science degree in 1967, and Ph.D. in 1971, all in Materials
`
`Science/Engineering from the University of California, Berkeley.
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`5.
`
`I have worked in the semiconductor industry for approximately 30 years. My
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`experience includes thin film deposition, vacuum system design, and plasma
`
`processing of materials. I made significant contributions to the development of
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`magnetron sputtering hardware and processes for the metallization of silicon
`
`integrated circuits. Since the late 1980s, I have also been instrumental in the
`
`development of standards for semiconductor fabrication equipment published by
`
`the Semiconductor Equipment and Materials International (“SEMI”) trade
`
`organization.
`
`6.
`
`From 1971-1974, I was a research metallurgist in the thin film development
`
`lab of Optical Coating Laboratory, Inc. In 1975 and 1976, I developed and
`
`demonstrated thin film applications and hardware for an in-line system at Airco
`
`Temescal. During my tenure (1977-1981) at Perkin Elmer, Plasma Products
`
`Division, I served in a number of capacities from Senior Staff Scientist, to
`
`Manager of the Advanced Development activity, to Manager of the Applications
`
`Laboratory. In 1981, I co-founded a semiconductor equipment company, Gryphon
`
`Products, and was VP of Engineering during development of the product. From
`
`1984-1988, I was the Advanced Development Manager for Gryphon, developing
`
`new hardware and process capabilities. During 1988-1990, I was Project Manager
`
`at General Signal Thinfilm on a project to develop and prototype an advanced
`
`cluster tool for making thin films. From 1991-2002, I was Manager of PVD
`
`
`
`
`  
`
`2
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`(physical vapor deposition) Source Engineering for Varian Associates, Thin Film
`
`Systems, and then for Novellus Systems, after they purchased TFS. Since then, I
`
`have been consulting full time doing business as UA Associates, where my
`
`consulting work includes product development projects, film failure analysis,
`
`project management, technical presentations and litigation support.
`
`7.
`
`Throughout my career, I have developed and/or demonstrated processes and
`
`equipment for making thin films, including Al, Ti-W, Ta, and Cu metallization of
`
`silicon wafers, RF sputtering and etching, and both RF and DC magnetron reactive
`
`sputtering, for example SiO2, Al2O3, ITO (Indium-Tin Oxide), TiN, and TaN. I
`
`have been in charge of the development of two sputter deposition systems from
`
`conception to prototype and release to manufacturing. I have also specialized in the
`
`development and improvement of magnetically enhanced sputter cathodes. I have
`
`experience with related technology areas, such as wafer heating, power supply
`
`evaluation, wafer cooling, ion beam sources, wafer handling by electrostatics,
`
`process pressure control, in-situ wafer/process monitoring, cryogenic pumping,
`
`getter pumping, sputter target development, and physical, electrical and optical
`
`properties of thin films.
`
`8.
`
`I am a member of a number of professional organizations including the
`
`American Vacuum Society, Sigma Xi (the Scientific Research Society), and as a
`
`
`
`
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`3
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`

`referee for the Journal of Vacuum Science & Technology. I have been a leader in
`
`the development of SEMI Standards for cluster tools and 300mm equipment,
`
`including holding various co-chair positions on various standards task forces. I
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`have previously served as a member of the US Department of Commerce’s
`
`Semiconductor Technical Advisory Committee.
`
`9.
`
`I have co-authored many papers, reports, and presentations relating to
`
`semiconductor processing, equipment, and materials, including the following:
`
`a. P. S. McLeod and L. D. Hartsough, "High-Rate Sputtering of
`Aluminum for Metalization of Integrated Circuits", J. Vac. Sci.
`Technol., 14 263 (1977).
`
`b. D. R. Denison and L. D. Hartsough, "Copper Distribution in
`Sputtered Al/Cu Films", J. Vac. Sci. Technol., 17 1326 (1980).
`
`c. D. R. Denison and L. D. Hartsough, "Step Coverage in Multiple
`Pass Sputter Deposition" J. Vac. Sci. Technol., A3 686 (1985).
`
`d. G. C. D’Couto, G. Tkach, K. A. Ashtiani, L. Hartsough, E.
`Kim, R. Mulpuri, D. B. Lee, K. Levy, and M. Fissel; S. Choi,
`S.-M. Choi, H.-D. Lee, and H. –K. Kang, “In situ physical
`vapor deposition of ionized Ti and TiN thin films using hollow
`cathode magnetron plasma source” J. Vac. Sci. Technol. B
`19(1) 244 (2001).
`
`10. My areas of expertise include sputter deposition hardware and processes,
`
`
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`4
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`thin film deposition system design and thin film properties. I am a named inventor
`
`on twelve United States patents covering apparatus, methods or processes in the
`
`fields of thin film deposition and etching. A copy of my CV is attached as
`
`Attachment A.
`
`
`
`II. SUMMARY
`11. My opinions in this proceeding are set forth in detail below. Briefly, it is my
`
`opinion that none of apparatus or methods recited claims 1-29 of the ‘775 patent
`
`would have been obvious to a person of ordinary skill in the art at the time of the
`
`invention in view of the combined teachings of Wang, Mozgrin and Kudryavtsev.
`
`It is further my opinion that none of the methods or apparatus recited in claims 30-
`
`37 of the ‘775 patent would have been obvious to a person of ordinary skill in the
`
`art at the time of the invention in view of the combined teachings of Wang and
`
`Mozgrin or Wang, Mozgrin and Lantsman.
`
`12. Wang discusses a magnetron sputter reactor in which DC power pulses are
`
`applied to a plasma in order to sputter material from a target. While Wang
`
`describes controlling aspects of these power pulses, Wang does not teach
`
`controlling voltage amplitude or pulse width when generating a high-density
`
`plasma to perform the sputtering. Nor does Wang explain any of the
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`5
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`electrodynamics of the high-density plasma. As I explain below, control of a
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`pulse’s power level (as in Wang) is very different from controlling the voltage
`
`amplitude and rise time of a pulse and even Wang acknowledges this distinction.1
`
`Any voltage pulses disclosed by Wang are merely a consequence of the system
`
`attempting to deliver the desired power level, i.e., the voltage (and current) are
`
`driven by the power supply of Wang based upon the desired power level but are
`
`determined by the plasma impedance.
`
`13. Kudryavtsev describes a flash tube, which is designed to apply a high
`
`voltage greater than the breakdown voltage across an inert gas resulting in a
`
`brilliant flash of light for a short duration. Flash tubes apply a voltage greater than
`
`the breakdown voltage, which may initiate the flash by an arc between the cathode
`
`and the anode. Kudryavtsev describes a voltage pulse that causes an “explosion” in
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`electron density that appears to cause an arcing condition as shown in his measured
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`voltage and current waveforms. A person of ordinary skill in the art would
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`therefore not refer to Kudryavtsev at all when designing a plasma generator, where
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`arcing is an undesirable characteristic.2
`
`                                                                                                                          
`1 Ex. 1008 at 5:52-54 (“Where chamber impedance is changing, the power pulse
`
`width is preferably specified rather than the current or voltage pulse widths.”).
`
`2 Ex. 1001 at 3:54-56.
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`6
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`14.
`
`In my opinion, it would not have been obvious to combine the teachings of
`
`Wang and Kudryavtsev. As I explain further below, there are significant
`
`differences between the experimental apparatus of Kudryavtsev and the magnetron
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`sputter reactor described by Wang. Consequently, a person of ordinary skill in the
`
`art would not have expected that applying the teachings of Kudryavtsev in a Wang-
`
`type system would have yielded predictable results or would have performed in an
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`expected way. Behaviors of charged particles (such as electrons and ions) in
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`magnetic fields (as in systems such as those discussed by Wang) are vastly
`
`different from their behaviors in the absence of magnetic fields (as in systems
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`reported by Kudryavtsev). Petitioners and their expert, Mr. DeVito, fail to account
`
`for these differences in their analyses.
`
`15. My conclusions regarding Wang and Kudryavtsev are not changed when one
`
`further considers the teachings of Mozgrin. While Mozgrin purports to have
`
`considered certain dependencies reported by Kudryavtsev, Mozgrin determined that
`
`for systems employing a magnetic field, a supply unit “providing square voltage
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`and current pulses with rise times (leading edge) of 5 – 60 µs and durations as
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`much as 1.5 ms” was needed.3 Wang, on the other hand, was concerned with
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`systems that used magnetic filed but considered it important that pulses have
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`                                                                                                                          
`3 Ex. 1002 at p. 401, rt. col. ¶ 1.
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`7
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`“significant” rise times and pulse widths preferably less than 200 µs and no more
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`than 1 ms.4 Given these important distinctions in the nature of the supply unit, the
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`teachings of Mozgrin would be of little value to a person of ordinary skill in the art
`
`when considering the system of Wang. Significant experimentation would still be
`
`required in order to adapt any teachings of Mozgrin to the new regime of Wang.
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`16.
`
`It is also my opinion it would not have been obvious to combine the
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`teachings of Wang and Lantsman. Lantsman differs substantially from Wang.
`
`Whereas Wang describes the application of “narrow pulses of negative DC power
`
`supplied from a pulsed DC power supply,”5 Lantsman employs two separate power
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`supplies: “[a] secondary power supply [that] pre-ignites the plasma by driving the
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`cathode to a process initiation voltage[, and] a primary power supply [that
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`thereafter] electrically drives the cathode to generate plasma current and deposition
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`on a wafer.”6 Lantsman does not disclose a pulsed power supply, any type of
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`electrical pulse, or a strongly-ionized plasma. Consequently, a skilled artisan
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`would not have been motivated to modify Wang’s pulsed power magnetron
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`                                                                                                                          
`4 Ex. 1008 at 5:26-27, 43-48; 8:41-42.
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`5 Id. at 5:18-22.
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`6 Ex. 1025, Abstract.
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`8
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`sputtering system with a system that employs separate, continuous DC power
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`supplies, such as that discussed by Lantsman.
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`17. My opinions in this regard do not change when one considers the additional
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`teachings of Mozgrin. Irrespective of any teachings Lantsman may or may not
`
`provide concerning the provision of a constant voltage, it remains the case that
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`Mozgrin disclosed the use of a supply unit “providing square voltage and current
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`pulses with rise times (leading edge) of 5 – 60 µs and durations as much as 1.5 ms .
`
`. . .”7 A system that uses a pulsed discharge supply unit and a voltage pulse, like
`
`that of Mozgrin, would operate very differently if it were modified to use two DC
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`power supplies and a continuous application of power during deposition, as taught
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`by Lantsman. Accordingly, it would not have been obvious to combine the
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`teachings of Wang, Mozgrin, and Lantsman.
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`
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`III. LEGAL STANDARDS
`18.
`
`In this section I describe my understanding of certain legal standards. I have
`
`been informed of these legal standards by Zond’s attorneys. I am not an attorney
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`and I am relying only on instructions from Zond’s attorneys for these legal
`
`standards.
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`                                                                                                                          
`7 Ex. 1002 at p. 401, rt. col. ¶ 1.
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`A. Level of Ordinary Skill in the Art.
`19.
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`I understand that a person of ordinary skill in the art provides a reference
`
`point from which the prior art and claimed invention should be viewed. This
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`reference point prevents one from using his or her own insight or hindsight in
`
`deciding whether a claim is obvious.
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`20.
`
`In my opinion, given the disclosure of the ‘775 patent and the disclosure of
`
`the prior art references considered here, I consider a person of ordinary skill in the
`
`art at the time of filing of the ‘775 patent to be someone who holds at least a
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`bachelor of science degree in physics, material science, or electrical/computer
`
`engineering with at least two years of work experience or equivalent in the field of
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`development of plasma-based processing equipment. I met or exceeded the
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`requirements for one of ordinary skill in the art at the time of the invention and
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`continue to meet and/or exceed those requirements.
`
`
`
`B. Claim Interpretation.
`21.
`
`I understand that the Board has construed the term “strongly ionized plasma”
`
`as “a plasma with a relatively high peak density of ions” and has construed the
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`10
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`term “weakly ionized plasma” as “a plasma with a relatively low peak density of
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`ions.” In rendering the opinions set forth herein I have applied these constructions.
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`22.
`
`I also understand that a means plus function claim limitation must be
`
`construed to cover the corresponding structure, material, or acts described in the
`
`specification and equivalents thereof. To that end, I understand the Board has
`
`adopted the following constructions of means plus function terms in the claims of
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`the ‘775 patent.
`
`Construction
`Term
`a power supply electrically connected to
`“means for ionizing a [volume of] feed
`a cathode, an anode, and/or an electrode
`gas”
`“means for generating a magnetic field” a magnet assembly having either a
`permanent magnet or a current source
`coupled to one or more electro-magnets
`a pulsed power supply electrically
`connected to a cathode, an anode, and/or
`an electrode
`a gas flow control system and structures
`for supplying the gas to the strongly-
`ionized plasma
`a bias voltage source electrically
`coupled to substrate
`
`“means for applying an electrical field
`[or pulse]”
`
`“means for exchanging”
`
`“means for applying a bias voltage”
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`11
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`In rendering the opinions set forth herein I have applied the above constructions,
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`with the exception of the Board’s construction for “means for ionizing a [volume
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`of] feed gas.” In my opinion, the Board’s construction of this term is flawed
`
`inasmuch as it fails to account for the important cathode-anode arrangement that is
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`described by Dr. Chistyakov. According to the ‘775 patent, the anode 238 is
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`positioned adjacent to the cathode assembly “so as to form a gap 244 between the
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`anode 238 and the cathode 216 that is sufficient to allow current to flow through a
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`region 245 between the anode 238 and the cathode 216.”8 “The dimensions of the
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`gap 244 and the total volume of region 245 are parameters in the ionization process
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`. . . .”9 Because the gap (and the volume resulting therefrom) between the anode
`
`and cathode is specifically called out as being a parameter in the ionization
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`process, in my opinion a person of ordinary skill in the art would consider the gap
`
`to be a part of the structure of the recited “means for ionization.” Therefore, in
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`rendering the opinions set forth herein I have construed the “means for ionizing a
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`[volume of] feed gas” as “a power supply electrically connected to a cathode
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`separated from an anode, and/or an electrode, by a gap there between.”
`
`                                                                                                                          
`8 Ex. 1001 at 5:15-18.
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`9 Id. at 5:21-24.
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`C. Legal Standards for Anticipation.
`23.
`
`I understand that a claim is anticipated if (i) each and every element and
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`limitation of the claim at issue is found either expressly or inherently in a single
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`prior art reference, and (ii) the elements and limitations are arranged in the prior art
`
`reference in the same way as recited in the claims at issue.
`
`
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`D. Legal Standards for Obviousness.
`24.
`
`I understand that even if a patent is not anticipated, it may still be invalid if
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`the differences between the claimed subject matter and the prior art are such that
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`the subject matter as a whole would have been obvious at the time the invention
`
`was made to a person of ordinary skill in the pertinent art.
`
`25.
`
`I understand that obviousness must be analyzed from the perspective of a
`
`person of ordinary skill in the relevant art at the time the invention was made. In
`
`analyzing obviousness, I understand that it is important to understand the scope of
`
`the claims, the level of skill in the relevant art, the scope and content of the prior
`
`art, the differences between the prior art and the claims, and any secondary
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`considerations of non-obviousness. I have not been asked to study or analyze any
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`secondary considerations of non-obviousness. As discussed further below, the prior
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`art references describe systems that are so different from what is claimed that these
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`13
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`do not form a basis for an obviousness determination of the claimed subject matter.
`
`26.
`
`I also understand that a party seeking to invalidate a patent as obvious must
`
`demonstrate that a person of ordinary skill in the art would have been motivated to
`
`combine the teachings of the prior art references to achieve the claimed invention,
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`that the person of ordinary skill in the art would have had a reasonable expectation
`
`of success in doing so, and that such determinations are evaluated as of the time
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`the invention was made. I understand that this temporal requirement prevents the
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`forbidden use of hindsight. I also understand that rejections for obviousness cannot
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`be sustained by mere conclusory statements and that Petitioners must show some
`
`reason why a person of ordinary skill in the art would have thought to combine
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`particular available elements of knowledge, as evidenced by the prior art, to reach
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`the claimed invention. I also understand that the motivation to combine inquiry
`
`focuses heavily on the scope and content of the prior art and the level of ordinary
`
`skill in the pertinent art.
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`27.
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`In arriving at the opinions set forth herein, I have considered questions of
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`obviousness from the perspective of a person of ordinary skill in the relevant art at
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`the time the invention was made and have given consideration to (1) the scope and
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`content of the prior art; (2) the differences between the prior art and the asserted
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`claims; and (3) the level of ordinary skill in the pertinent art. I have been informed
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`and understand that the obviousness analysis requires a comparison of the properly
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`construed claim language to the prior art on a limitation-by-limitation basis.
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`IV. BACKGROUND TOPICS
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`28. The ‘775 patent relates to “[m]agnetically enhanced plasma processing
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`methods and apparatus.”10 I understand that IPR2014-00578 was instituted to
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`consider the obviousness of claims 1-7, 9-16, 18-26, 28, and 29 of the ‘775 patent
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`in view of the combined teachings of Wang, et al., U.S. Patent 6,413,382 (Ex.
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`1008) (“Wang”), Mozgrin et al., High-Current Low-Pressure Quasi- Stationary
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`Discharge in a Magnetic Field: Experimental Research, Plasma Physics Reports,
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`Vol. 21, No. 5, 1995 (Ex. 1002) (“Mozgrin”), and Kudryavtsev, et al, Ionization
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`relaxation in a plasma produced by a pulsed inert-gas discharge, Sov. Phys. Tech.
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`Phys. 28(1), January 1983 (Ex. 1003) (“Kudryavtsev”); of claim 8 in view of the
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`combined teachings of Wang, Mozgrin, Kudryavtsev, and Kouznetsov, U.S
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`PGPUB 2005/0092596 (Ex. 1004) (“Kouznetsov”); of claim 17 in view of the
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`combined teachings of Wang, Mozgrin, Kudryavtsev, and Lantsman, U.S. Patent
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`6,190,512 (Ex. 1025) (“Lantsman”); and of claim 27 in view of the combined
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`teachings of Wang, Mozgrin, Kudryavtsev, and Li et al., Enhancement of
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`10 Ex. 1001 at Abstract.
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`Aluminum Oxide Physical Vapor Deposition with a Secondary Plasma, 149
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`Surface and Coatings Tech. pp. 161–170 (2002) (Ex. 1010) (“Li”). I also
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`understand that IPR2014-00604 was instituted to consider the obviousness of
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`claims 30-34 and 37 of the ‘775 patent in view of the combined teachings of Wang,
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`Mozgrin, and Lantsman, of claim 35 in view of the combined teachings of Wang,
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`Mozgrin, Lantsman, and Kudryavtsev; and of claim 36 in view of the combined
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`teachings of Wang and Mozgrin. In this section I provide some background
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`information useful to understanding these cited references and the subject matter
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`claimed in the ‘775 patent.
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`A. Voltage, current, impedance and power.
`29. As is commonly known, when a voltage “V” is applied across an impedance
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`“I,” an electric field is generated that forces a current I to flow through the
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`impedance. For purely resistive impedance, the relation between the voltage and
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`the resultant current is given by: V = I * R.
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`30. A common analogy is that voltage is like a pressure that causes charged
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`particles like electrons and ions to flow (i.e., current), and the amount of current
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`depends on the magnitude of the pressure (voltage) and the amount of resistance or
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`impedance that inhibits the flow. The ‘775 patent and the cited references
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`considered here involve the flow of current through an assembly having a pair of
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`electrodes with a plasma in the region between them. The effective impedance of
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`such an assembly varies greatly with the density of charged particles in the region
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`between the electrodes. Although such an impedance is more complex than the
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`simple resistive impendence of the above equation, the general relation is similar: a
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`voltage between the electrode assembly forces a current to flow through the
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`plasma, such that the amount of current is determined by the amplitude of the
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`voltage and the impedance of the plasma. Thus, the current through the electrode
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`assembly increases with the electrode voltage and, for a given electrode voltage,
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`the current will increase with a drop in the impedance of the plasma.
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`31. The impedance varies with the charge density of the plasma: With a high
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`density of charged particle the impedance is relatively small, and with a low
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`density of charged particles the impedance is relatively large. Simply, the more
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`ions and electrons to carry the charge, the less resistance. However, the charges
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`and fields react with each other in a very complicated manner.
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`32.
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`In response to the electric field in the region between the electrodes (i.e., the
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`voltage across the electrodes), all charged particles in the region (the electrons and
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`positive ions) feel a force that propels them to flow. This flow is an electric current
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`“I.” The amount of current depends upon the number of charged particles. When
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`there are no charged particles (i.e., no plasma), there is no current flow in response
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`to the electric field. In this condition, the impendence of the assembly is extremely
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`high, like that of an open circuit. But when there is a dense plasma between the
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`electrodes (with many charged particles), a substantial current will flow in
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`response to the electric field. In this condition, the impendence of the electrode
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`assembly is very low. Thus, in general, the impedance of an electrode assembly
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`varies greatly with the charge density of the plasma: The impedance is effectively
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`infinite (an open circuit) when there is no plasma, and is very low when the charge
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`density of the plasma is very high.
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`33.
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`It is also well known that electric power (P) is the product of voltage (V) and
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`current (I): P = V * I. Thus, for a given voltage across an electrode assembly, the
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`amount of power will depend on the amount of corresponding current flowing
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`through the electrode assembly. If there is no c