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`Trial No. IPR2014-00578
`Docket No. 0110198-00193 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. 6,896,775
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`IPR Trial No. IPR2014-00578
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`PETITIONER’S REPLY
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`Claims 1-29
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`Trial No. IPR2014-00578
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`TABLE OF CONTENTS
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`I.
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`INTRODUCTION ........................................................................................ 1
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`II.
`ZOND CONCEDES THAT INDEPENDENT CLAIMS 1 AND 15
`ARE TAUGHT BY THE PRIOR ART ................................................................. 2
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`III. ONE SKILLED IN THE ART WOULD HAVE COMBINED THE
`CITED REFERENCES WITH PREDICTABLE RESULTS ............................ 5
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`IV. DEPENDENT CLAIMS ARE ALSO OBVIOUS ...................................... 8
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`Dependent Claims 16 and 17 ........................................................ 8
`A.
`Dependent Claims 2 and 18 .......................................................... 9
`B.
`Dependent Claims 21 and 24 ...................................................... 10
`C.
`Dependent Claims 4, 5 and 9 ..................................................... 12
`D.
`CONCLUSION ............................................................................................ 14
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`V.
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`CASES
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`Trial No. IPR2014-00578
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`TABLE OF AUTHORITIES
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`Page(s)
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`In re Mouttet, 686 F.3d 1322, 1332 (Fed. Cir. 2012)…………….….……………7
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`KSR, 550 US at 420-21………………………………………………………..7
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`Boehringer Ingelheim Vetmedica, Inc. v. Schering-Plough Corp., 320 F.3d 1339, 1345
`(Fed. Cir. 2003)…………………………………………………………..14
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`Pronova BioPharma Norge AS v. Teva Pharms. USA, Inc. 549 Fed. Appx. 934, 938
`(Fed. Cir. 2013)…………………...……………………………………...14
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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 1-29 should be cancelled. See
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`IPR2014-578 DI at p. 25. None of the arguments raised by Zond provides any
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`reason to alter the determination of the Board in the Decision on Institution.
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`First, Zond interprets the claim term “adjacent” very narrowly, despite failing
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`to proffer such a construction earlier. Regardless, the cross examination testimony of
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`Zond’s declarant, Dr. Hartsough, demonstrates that the cited references meet the
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`claim term “adjacent” even under Zond’s narrower interpretation.
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`Second, Zond attempts to require a particular ordering of the method claims in
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`a manner that is inconsistent with the patent specification, and which is refuted by
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`Zond’s own expert, Dr. Hartsough.
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`Third, Zond argues that a number of dependent claims (i.e., claims 2, 4, 5, 9,
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`16, 17, 18, 21 and 24) add patentable subject matter. However, Dr. Hartsough’s cross
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`examination testimony demonstrates that Zond’s arguments as to these dependent
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`claims likewise are wrong.
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`The Petition, supported by Mr. DeVito’s declaration, demonstrates why one of
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`ordinary skill in the art would have combined the teachings of the cited references.
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`The cross examination testimony of Dr. Hartsough further demonstrates that the
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`references would have been combined. Petitioner also provides the declaration of
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`Dr. John Bravman, who reached the same conclusion: that the references would have
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`been combined by one of ordinary skill in the art and that the challenged claims are
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`unpatentable.1
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`II.
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`ZOND CONCEDES THAT INDEPENDENT CLAIMS 1 AND 15
`ARE TAUGHT BY THE PRIOR ART
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`Zond’s declarant, Dr. Hartsough, explicitly conceded that just about all of the
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`limitations recited in the independent claims were well known before the effective
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`date of the ‘775 patent. See Ex. 1030 (“’775 Hartsough Depo.”) at 42:4 – 45: 18.
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`Zond nevertheles argues that the cited references do not suggest “a cathode
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`that is positioned adjacent to the anode and forming a gap there between,” (IPR2014-
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`578, Patent Owner’s Response (“PO Resp.”) at pp. 43-48), and that method claim 15
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`requires a specific order. IPR2014-578, PO Resp. at pp. 39-42. However, both of
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`these arguments are also refuted by the cross examination testimony of Dr.
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`Hartsough.
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`Wang teaches “a cathode that is positioned adjacent to the anode and forming a gap
`therebetween”
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`Zond’s expert, Dr. Hartsough, argues that the term “adjacent” must mean
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`“next to and with nothing in between.” Ex. 2006 (Hartsough Dec.) at p. 48. Zond
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`then argues that “Wang cannot teach the claimed gap of the ‘775 patent … [because]
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`Wang teaches an important feature placed intermediate these two electrodes, namely a
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`1 Mr. DeVito is no longer available to provide testimony.
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`2
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`floating shield.” IPR2014-578 PO Resp. at p. 44.2
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`Dr. Hartsough’s testimony demonstrates otherwise. A slightly modified Figure
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`3 from Dr. Hartsough’s declaration (Ex. 2006) was presented to Dr. Hartsough during
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`his deposition as Exhibit 1029 (reproduced
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`right). As shown, an electrode (colored
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`red) was introduced only partially between
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`an anode and a cathode, and Dr.
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`Hartsough was asked to whether the anode
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`and cathode still meet the meaning of
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`“adjacent.” Dr. Hartsough conceded that,
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`in this configuration, some portions of the anode and cathode (i.e., portions bounding
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`the region colored purple) can still be adjacent to one another within the context of
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`the ‘775 patent claims. See ’775 Hartsough Depo. at 74:7-76:8 (“Q: Is the anode and
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`cathode depicted in Exhibit 1029 adjacent to one another? … A: In that depiction,
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`there are portions that are adjacent.”).
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`Wang also has portions of an anode and a cathode that are “adjacent” within
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`the context of the ‘775 patent claims, in addition to a floating shield. As shown on
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`right in annotated Figure 1 of Wang (above right), portions of the anode 24 (colored
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`2 Dr. Hartsough indicated that a gas or plasma can exist between an anode and a
`cathode and the anode and cathode can still be “adjacent” within the scope of the
`‘775 claims. See ’775 Hartsough Depo. at 70:8-71:1.
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`orange) and cathode 14 (colored green) do not
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`intersect the floating shield 26 (colored red). One
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`exemplary such “adjacent” region is shown using
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`the purple diagonal dotted line above.
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`Accordingly, Wang teaches “a cathode that
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`is positioned adjacent to the anode and forming a
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`gap therebetween,” even under Zond’s narrow
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`interpretation of the claim term. See Bravman
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`Dec. at ¶¶ 81-86.
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`Claim 15 does not require a specific order
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`Zond also asserts that method claim 15 requires the step of “ionizing a feed
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`gas…” to occur before “generating a magnetic field…” IPR2014-578 PO Resp. at
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`pp. 39-42. However, Dr. Hartsough unequivocally concedes that this is not the case,
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`in the testimony shown below:
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`Q: In Claim 15 of the ‘775 patent, the step of ionizing a feed gas
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`does not have to occur before the generation of a magnetic field; right?
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`A: Correct.
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`Q: Because, as we said, Figure 2 has a permanent magnet, so the
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`magnetic field will already be on; right?
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`A: In that embodiment, yeah.
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`Q: And that’s an embodiment of Claim 15; right?
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`A: Yes.
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`’775 Hartsough Depo. at 87:6-18.
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`The flowcharts in Figures
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`12A and 13A of the ‘775 patent,
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`partially reproduced on the right,
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`confirm that the step of generating
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`magnetic field 614 occurs before
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`the step of ionizing the feed gas to generate weakly-ionized plamsa 618. Ex.
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`1001 (’775 Patent) at Figs. 12A and 13A. See also Ex. 1031 (Bravman Dec.) at
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`¶¶ 97-100.
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`III. ONE SKILLED IN THE ART WOULD HAVE COMBINED THE
`CITED REFERENCES WITH PREDICTABLE RESULTS
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`As Dr. Hartsough concedes, it was well known to a person skilled in the art
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`that it would be desirable to increase the sputter etching rate. See ‘775 Hartsough
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`Depo. at 49:7-24 (“Q: So in – in general, it’s desirable, and the person of ordinary skill
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`would be motivated, to increase the sputter etching rate; right? … A: Yes.”). See also
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`Bravman Dec. at ¶ 68.
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`It was also well-known that one of skill in the art could achieve such an
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`increased etching rate by increasing the ionization rate. See ‘775 Hartsough Depo. at
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`50:2-12 (“Q: What are the ways in which a person of ordinary skill would have known
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`how to increase the etch rate? A: I’m not sure I could recite all of them. … Q: It
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`could increase the ionization rate? A: It could increase the – the flux of ions that
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`would be – you know, that would bombard the substrate.”). See also Bravman Dec.at ¶
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`69.
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`It was also well known that high density plasma is desirable because it results in
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`a high etch rate. See IPR2014-578, Petition at p. 53 (“As taught in Mozgrin, high
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`plasma density is desirable because it results in a high etch rate.”); Ex. 1002
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`(“Mozgrin”) at 409, left col, ¶5 (“The high-current diffuse discharge (regime 3) is
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`useful… Hence, it can enhance the efficiency of ionic etching in microelectronics and
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`provide a means for controlled pulsed etching of layers.”). See also Bravman Dec.at ¶
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`70.
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`Wang, Mozgrin and Kudryavtsev are all directed to generating a high plasma
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`density with the application of a pulse. Bravman Dec. at ¶ 71. Wang teaches “[a]
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`magnetron sputter reactor having a target that is pulsed…whereby a very high plasma
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`density is produced.” Ex. 1008 (“Wang”) at Abstract. Mozgrin teaches that
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`“[b]ecause of the need for greater discharge power and plasma density, pulse or quasi-
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`stationary regimes appear to be of interest.” Mozgrin at p. 400, left col, ¶3.
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`Kudryavtsev teaches an explosive growth in the plasma density. Ex. 1003
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`(“Kudyravtsev”) at Abstract (“[I]n a pulsed inert-gas discharge plasma at moderate
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`pressures … [i]t is shown that the electron density increases explosively in time due to
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`accumulation of atoms in the lowest excited states.” Accordingly, as noted in the
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`Petition, all of these cited references are directed to the common goal of increasing
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`plasma density using pulsed systems, and one skilled in the art would have been
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`motivated to combine the teachings of Wang, Mozgrin and Kudryavtsev. Bravman
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`Dec.at ¶ 71.
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`Zond contends that Wang, Mozgrin and Kudryavtsev cannot be combined,
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`relying on essentially the same arguments that the Board previously considered and
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`found as unpersuasive in instituting these proceedings. IPR2014-578 DI at pp. 16-19.
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`Zond continues to argue that combining Wang with Kudryavtsev would not have
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`yielded predictable results because of the differences in reactor geometry/electrode
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`spacing, power supply design, magnetic field and pressure conditions. IPR2014-578
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`PO Resp at pp. 25-35.
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`However, as the Board already articulated, (IPR2014-578, DI at p. 17), “[i]t is
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`well-established that a determination of obviousness based on teachings from multiple
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`references does not require an actual, physical substitution of elements.” In re Mouttet,
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`686 F.3d 1322, 1332 (Fed. Cir. 2012). Moreover, a person of ordinary skill is “a
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`person of ordinary creativity, not an automaton,” and “in many cases . . . will be able
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`to fit the teachings of multiple patents together like pieces of a puzzle.” KSR, 550 US
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`at 420-21.
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`In fact, as the Board already recognized, IPR2014-578 DI at p. 18, Mozgrin
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`demonstrated that the teachings of Kudryavtsev can be successfully applied in a
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`completely different system that added a magnetron, and used different reactor
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`geometry/electrode spacing, power supplies and pressure conditions. One skilled in
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`the art would have been able to combine Wang, Kudryavtsev and Mozgrin in a similar
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`fashion. Bravman Dec. at ¶¶ 71-77.
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`IV. DEPENDENT CLAIMS ARE ALSO OBVIOUS
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`Zond is silent regarding dependent claims 3, 6-8, 10-14, 19, 20, 22, 23 and 25-
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`29, thereby conceding these dependent claims do not add any patentable subject
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`matter. However, Zond asserts that dependent claims 2, 4, 5, 9, 16, 17, 18, 21 and 24
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`add patentable subject matter. As explained below, they do not.
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`A. Dependent Claims 16 and 17
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`Zond asserts that “one can expect that the power is not constant” (IPR2014-
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`578 PO Resp. at p.59)(original emphasis), while simultaneously arguing that
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`“Petitioners’ contention that Wang teaches the use of constant power, precludes the
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`use of constant voltage given the dynamic nature of the plasma ionization.” IPR2014-
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`578 PO Resp. at p. 60 (emphases in original). Both assertions are factually incorrect.
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`Dr. Hartsough conceded that the typical power supplies described by Wang
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`operate exactly as shown in Figure 5 of the ‘775 patent. ‘775 Hartsough Depo. at
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`149:17-150:20 (“Q: So we can agree that Wang is explaining how a typical pulsed
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`power supply operates; right? A: Yes … Q: And that’s exactly what Figure 5 of the
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`‘775 patent is showing; right? … A: Yes.”). See also Bravman Dec. at ¶ 104.
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`As conceded by Dr. Hartsough,
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`Figure 5 of the ‘775 patent shows
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`regions of constant power and constant
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`voltage for each power pulse. Ex. 1030
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`at 135:19 -136:1. Specifically, the
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`region between t5 and t6 show both a
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`constant power (orange) and a constant
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`voltage (green). Accordingly, Wang
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`teaches both a constant voltage and
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`constant power regions, meeting the
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`limitations of claims 16 and 17. See also Bravman Dec. at ¶¶ 105-106.
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`B. Dependent Claims 2 and 18
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`Zond asserts that “[t]here is no indication in Wang that the voltage is constant
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`during any part of the power pulse ….” IPR2014-578 PO Resp. at p. 50. However,
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`as explained above with respect to claims 16 and 17, this is factually incorrect. Dr.
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`Hartsough conceded that Wang’s power supply delivers a voltage profile that is
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`represented by Figure 5 of the ‘775 patent. Figure 5 shows a constant voltage
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`between t5 and t6. ‘775 Hartsough Depo. at 149:17-150:20 and 135:19-136:1. The
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`region between t5 and t6 also represents the power pulse duration. The region
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`between t4 and t5 corresponds to Wang’s “actual” rise time of the power pulse.
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`Bravman Dec. at ¶¶ 107-111.
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`Dr. Hartsough also conceded that if the region between t5 and t6 in Figure 5 of
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`the ‘775 is longer than the collision time for electrons, that would meet the ‘775
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`patent’s definition of a quasi-static electric field recited in claims 2 and 18. ‘775
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`Hartsough Depo. at 137:25 – 138:8.
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`Accordingly, the determination that the power pulse width (i.e., 50 µs) is much
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`greater than the calculated collison time (i.e., 1.88 µs), as was explained in the Petition,
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`is correct. IPR2014-578, Petition at pp. 46-47. Bravman Dec. at ¶¶ 107-111.
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`C. Dependent Claims 21 and 24
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`Zond asserts that Wang’s high density plasma region would be non-uniform
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`due to the presence of an unbalanced magnetic field. IPR2014-578 PO Resp. at p. 55.
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`However, this argument merely represents the state of plasma at a single instant in
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`time, and fails to take into account the uniformity of the plasma near the
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`cathode/target over time. Bravman Dec. ¶ 114.
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`There is nothing in the claim that requires the uniformity to occur at only a
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`single instant in time. Rather, as Dr. Hartsough concedes, the magnet in Wang rotates
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`about a central axis. Hence, the location of the high-density plasma region 42 also
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`rotates over time. ‘775 Hartsough Depo. at 128:14-22. As Dr. Hartsough further
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`concedes, this is carried out to cause a more uniform erosion of the target over time.
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`‘775 Hartsough Depo. at 129:23-130:10; see also Wang at 1:64-66. This is schematically
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`illustrated in the figure below showing that the plasma (red), follows the rotation of
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`the magnet (green). Averaged over time (bottom of figure), the plasma (red) will be
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`uniform near the cathode surface. Bravman Dec. at ¶¶ 115-117.
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`With the generation of a uniform plasma near the cathode surface over time,
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`Dr. Hartsough further concedes that Wang teaches the formation of a uniform
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`plasma near the wafer 20 over time as well. ‘775 Hartsough Depo. at 130:11-20 (“Q:
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`So Wang does teach over time the formation of a uniform plasma of the wafer 20;
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`right? … A: And that would occur over many, many pulses of the – of the power. Q:
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`But it would occur; right? … A: It would occur.”). See also Bravman Dec. at ¶ 118.
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`Accordingly, over time, Wang teaches “selecting at least one of a pulse amplitude and
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`a pulse width of the electrical pulse in order to cause the strongly-ionized plasma to be
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`substantially uniform in an area adjacent to the surface of the substrate,” as required
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`by claim 21. Wang also teaches “the strongly ionized plasma is substantially uniform
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`proximate to a surface of the substrate,” as recited in claim 24. Bravman Dec. at ¶¶
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`119-120.
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`D. Dependent Claims 4, 5 and 9
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`Zond does not dispute that Wang teaches “a rise time of the electric field” or
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`“a volume between the anode or the cathode,” as recited in claims 4, 5 and 9. Nor
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`does Zond dispute that Wang teaches an “increase [in the] ionization rate of the
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`excited atoms [and molecules] in the weakly-ionized plasma” or “an increase [in the]
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`etch rate of the surface of the substrate” recited in claims 4, 5 and 9.
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`Rather, Zond’s only argument is whether the prior art teaches choosing the
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`“rise time” and the “volume” for the particular purpose of achieving an “increase
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`[in the] ionization rate of the excited atoms [and molecules] in the weakly-ionized
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`plasma” or “an increase [in the] etch rate of the surface of the substrate,” as recited in
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`claims 4, 5 and 9. IPR2014-578 PO Resp. at pp. 51-53 and 57. For example, Dr.
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`Hartsough argues that if the prior art teaches choosing “a rise time of the electric
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`field,” or “a volume between the anode and the cathode,” for a different purpose than
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`what is recited in the claims, it does not invalidate the claim even if there is an
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`“increase in the ionization rate of the excited atoms [and molecules] in the weakly-
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`ionized plasma” or “an increase in the etch rate of the surface of the substrate.” ‘775
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`Hartsough Depo. at 96:3-17 (“Q: And if one chooses a rise time of a voltage pulse for
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`a purpose other than to increase the ionization rate, but as a result the ionization rate
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`nevertheless increases, does it satisfy Claim 4? … A: It all depends on, you know, if –
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`if somebody could show that they chose it to do some other purpose, then it would
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`not. Q: All right. Because the claim requires a specific purpose here; right? … A: It
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`requires it, yes, and a demonstration of that purpose.”); 98:12-17 (“Q: In Claim 9, if
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`the volume of a system is chosen for a purpose other than increasing the ionization
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`rate, but the ionization rate increases nevertheless, it would not meet the claim;
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`correct? … A: Yes.”); 104:5-11 (“Q: If one chooses a rise time of a voltage pulse for a
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`purpose other than to increase an etch rate, but an increase etch rate results
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`nevertheless, does it meet Claim 5? … A: Does it meet Claim 5? So the answer is
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`no.”).
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`However, a person of ordinary skill in the art would readily recognize from the
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`teachings of Wang that various experimental variables, such as rise time of a voltage
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`pulse, and the volume between the anode and the cathode assembly, were chosen for
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`the particular purpose of achieving a higher plasma density. See Wang at 1:5-8 and
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`1:30-41; see also Bravman Dec. at ¶ 125. Wang selected pulse characteristics and
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`reactors with the goal of “producing a high fraction of ionized sputtered particles,”
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`Ex. 1008 at 1:7-8, which “has long been exploited in high-density plasma.” Ex. 1008
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`at 1:30-35. Wang is attempting to achieve such high-density plasma at a commercial
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`scale. Wang at 2:58 – 3:13; see also Bravman Dec. at ¶ 125.
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`Moreover, as conceded by Dr. Hartsough, “if you have a quick increase in the
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`plasma density … that indicate[s] a quick increase in the rate of ionization.” Ex. 1032
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`(’184 Hartsough Depo.) at 88:19-89:6. Accordingly, a person of ordinary skill will
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`readily recognize that because it was desirable to increase the plasma density, it also
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`would be desirable to “increase an ionization rate.” ’184 Hartsough Depo. at 88:19-
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`89:6. See also Bravman Dec. at ¶ 126.
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`Zond’s argument is also legally flawed. It is well settled that “[a]n intended use
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`or purpose usually will not limit the scope of the claim because such statements
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`usually do no more than define a context in which the invention operates.” Boehringer
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`Ingelheim Vetmedica, Inc. v. Schering-Plough Corp., 320 F.3d 1339, 1345 (Fed. Cir. 2003);
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`see also Pronova BioPharma Norge AS v. Teva Pharms. USA, Inc. 549 Fed. Appx. 934, 938
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`(Fed. Cir. 2013).
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`Accordingly, Zond’s arguments are both factually and legally incorrect and
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`Wang teaches the added limitations of claims 4, 5 and 9.
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`V. CONCLUSION
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`Board correctly found that there was a reasonable likelihood that the claims
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`should be cancelled based on the Petition and the supporting declaration. None of
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`the arguments raised by Zond provides any reason to alter the determination of the
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`Board in the Decision on Institution. Based on the foregoing, Petitioners have
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`demonstrated beyond a preponderance of the evidence that the claims are
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`unpatentable and request cancellation of the the challenged claims 1-29.
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`Trial No. IPR2014-00578
`Docket No. 0110198-00193 US1
`
`Customer Number:
`Tel: (202) 663-6025
`Fax: (202) 663-6363
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`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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`Trial No. IPR2014-00578
`Docket No. 0110198-00193 US1
`CERTIFICATE OF SERVICE
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`I hereby certify that, on March 27, 2015, I caused a true and correct copy of the
`
`foregoing materials:
`
` Petitioner’s Reply
`
` Exhibits 1028-1033
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` Exhibit Appendix
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`to be served via email, as previously agreed between the parties, on the following
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`counsel of record for Patent Owner:
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`Date of service March 27, 2015
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`Manner of service
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`Persons Served
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`Email: tarek.fahmi@ascendalaw.com;
`gonsalves@gonsalveslawfirm.com;
`bbarker@chsblaw.com
`
`Tarek Fahmi
`84 W. Santa Clara St. Suite 550
`San Jose, CA 95113
`
`Gregory J. Gonsalves
`2216 Beacon Lane
`Falls Church, Virginia 22043
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`
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`
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`/Yung-Hoon Ha/
`Yung-Hoon Ha
`Registration No. 56,368
`7 World Trade Center
`250 Greenwich Street
`New York, NY10007
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`Trial No. IPR2014-00578
`Docket No. 0110198-00193 US1
`EXHIBIT APPENDIX
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`Exhibit
`Gillette 1001
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`Gillette 1002
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`Gillette 1003
`Gillette 1004
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`Gillette 1005
`Gillette 1006
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`Gillette 1007
`Gillette 1008
`Gillette 1009
`
`Gillette 1010
`Gillette 1011
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`Gillette 1012
`Gillette 1013
`Gillette 1014
`Gillette 1015
`Gillette 1016
`Gillette 1017
`Gillette 1018
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`Gillette 1019
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`Gillette 1020
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`Gillette 1021
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`Description
`Chistyakov, U.S. Patent No. 6,896,775
`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
`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
`Kouznetsov, U.S. Patent Publication 2005/0092596
`Certified translation of D.V. Mozgrin, High-Current Low-
`Pressure Quasi-Stationary Discharge in a Magnetic Field:
`Experimental Research, Thesis at Moscow Engineering Physics
`Institute, 1994 (“Mozgrin Thesis”)
`Mozgrin Thesis (Original Russian)
`Catalogue Entry at the Russian State Library for the Mozgrin
`Thesis
`Wang, U.S. Pat. No. 6,413,382
`Lantsman, U.S. Pat. No. 6,447,655
`N. Li et al., Enhancement of Aluminum Oxide Physical Vapor
`Deposition with a Secondary Plasma, Surface and Coatings,
`Tech. 149 (2002)
`Declaration of Richard DeVito
`Raizer, Gas Discharge Physics, Table of Contents pp. 1-35,
`Springer 1997 (“Raizer”)
`Pan, U.S. Pat. No. 6,679,981
`Fu, U.S. Pat. No. 6,306,265
`Holland, U.S. Pat. No. 6,319,355
`Hauzer, U.S. Pat. No. 5,306,407
`Bobbio, U.S. Pat. No. 5,045,166
`Gopalraja, U.S. Pat. No. 6,277,249
`Thornton, J. and Hoffman, D.W. Stress related effects in thin
`films, Thin Solid Films, 171, 1989, 5-31.
`
`N. Savvides and B. Window, Unbalanced magnetron ion‐
`
`assisted deposition and property modification of thin films, J.
`Vac. Sci. Technol. A 4 , 504, 1986
`Grove, T.C., Arcing problems encountered during sputter
`deposition of aluminum, White Papers, ed: Advanced Energy,
`
`1
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`Trial No. IPR2014-00578
`Docket No. 0110198-00193 US1
`
`Exhibit
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`Description
`
`2000
`Sellers, J., Asymmetric bipolar pulsed DC: the enabling
`technology for reactive PVD, Surface & Coatings Technology,
`vol. 98, issue 1-3, January, 1998.
`Rossnagel, S. M., & Hopwood, J., Magnetron sputter deposition
`with high levels of metal ionization. Applied Physics Letters,
`63(24), 3285-3287, 1993.
`Manos, et al., Etching: An Introduction, Academic Press, 1989.
`Lantsman, U.S. Pat. No. 6,190,512
`Declaration of Mark Matuschak in support of Unopposed
`Motion for Admission Pro Hac Vice
`Declaration of Cosmin Maier in support of Unopposed Motion
`for Admission Pro Hac Vice
`Figure 7 of the ‘775 Patent with handwriting by Larry
`Hartsough, Ph.D. identifying “Gap”
`Annotated Figure 3 from Larry Hartsough, Ph.D.’s Declaration
`
`Deposition Transcript of Larry D. Hartsough Ph.D. for U.S.
`Patent No. 6,896,775 (February 19, 2015)
`Declaration of John C. Bravman
`Deposition Transcript of Larry D. Hartsough Ph.D. for U.S.
`Patent No. 7,808,184 (February 11, 2015)
`Deposition Transcript of Larry D. Hartsough Ph.D. for U.S.
`Patent No. 8,125,155 (February 12, 2015)
`
`Gillette 1022
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`Gillette 1023
`Gillette 1024
`Gillette 1025
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`Gillette 1026
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`Gillette 1027
`Gillette 1028
`(Deposition)
`Gillette 1029
`(Deposition)
`Gillette 1030
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`Gillette 1031
`Gillette 1032
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`Gillette 1033
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`2
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