EXHIBIT 2013
`
`EXHIBIT 2013
`
`
`
`EXHIBIT 2013
`
`
`
`Page 1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`---------------------------------------------------------------X
`THE GILLETTE COMPANY, et al.,
`
` Patent No. 6,896,773
` Petitioners, IPR 2014-00580
` IPR 2014-00726
` -against-
`ZOND, LLC,
`
` PATENT OWNER.
`---------------------------------------------------------------X
`
` VIDEOTAPED DEPOSITION OF
` JOHN BRAVMAN, Ph.D.
` Lewisburg, Pennsylvania
` Wednesday, April 22, 2015
`
`Reported by:
`Rebecca Schaumloffel, RPR, CLR
`Job No: 92740
`
`TSG Reporting - Worldwide 877-702-9580
`
`1 2
`
`3
`
`4
`
`5
`
`6
`7
`8
`
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`
`
`Page 2
`
` April 22, 2015
` 8:07 a.m.
`
` Videotaped deposition of JOHN
`BRAVMAN, Ph.D., held at the BEST WESTERN PLUS
`COUNTRY CUPBOARD INN, 7701 West Branch
`Highway, Lewisburg, Pennsylvania, before
`Rebecca Schaumloffel, a Registered
`Professional Reporter, Certified Livenote
`Reporter and Notary Public of the States of
`New York, New Jersey, and Pennsylvania.
`
`TSG Reporting - Worldwide 877-702-9580
`
`1 2 3
`
`4
`
`5 6 7 8
`
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`
`
`Page 3
`
`A P P E A R A N C E S:
`
` WILMERHALE
` Attorneys for the Petitioner
` 7 World Trade Center
` 250 Greenwich Street
` New York, New York 10007
` BY: COSMIN MAIER, ESQ.
` YUNG-HOON HA, Ph.D., ESQ.
`
` GONSALVES LAW FIRM
` Attorneys for the Patent Owner, Zond
` 2216 Beacon Lane
` Falls Church, Virginia 22043
` BY: GREGORY GONSALVES, ESQ.
`
` ALSO PRESENT:
`
` Larry Moskowitz, Legal Videographer
`
` * * *
`
`TSG Reporting - Worldwide 877-702-9580
`
`1 2
`
`3 4
`
`5
`
`6
`
`7
`
`8 9
`
`10
`11
`
`12
`
`13
`14
`15
`16
`17
`
`18
`19
`20
`
`21
`22
`23
`24
`25
`
`
`
`Page 4
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
` THE VIDEOGRAPHER: Good morning,
`we are now on the record. This is the
`start of tape labeled number one of
`the videotaped deposition of John
`Bravman Ph.D., in the matter The
`Gillette Company versus Zond, Inc.
` This deposition is being held at
`the Best Western, 7701 West Branch
`Highway, Lewisburg, Pennsylvania on
`April 22, 2015, at approximately
`8:08 a.m. My name is Larry Moskowitz
`from TSG Reporting Inc., and I am the
`legal video specialist. The Court
`Reporter is Rebecca Schaumloffel,
`also, in association with TSG
`Reporting.
` Will counsel please introduce
`themselves for the record.
` MR. GONSALVES: My name is
`Dr. Gregory Gonsalves representing the
`patent owners, Zond.
` MR. MAIER: Cosmin Maier of
`WilmerHale on behalf of petitioner,
`Gillette Company; and with me is my
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 5
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
` colleague, Sam Ha.
`J O H N B R A V M A N, called as a
`witness, having been first duly sworn by a
`Notary Public of the State of New York, was
`examined and testified as follows:
`EXAMINATION BY
`MR. GONSALVES:
` Q. Dr. Bravman, have you been
`deposed before in this IPR proceedings with
`Zond?
` A. Yes.
` Q. How many times?
` A. Twice.
` Q. Have you been deposed in any
`other IPR or CBM proceedings with the Patent
`Office?
` A. What is CBM?
` Q. CBM stands for -- well, why don't
`we break the question into two parts to make
`it simple.
` Have you been deposed in relation
`to any other IPRs pending at the Patent
`Office other than the ones involving Zond?
` A. No.
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 6
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
` Q. Okay. Have you been deposed in
`any CBM which is called the Covered business
`method proceeding at the Patent Office?
` A. No.
` Q. Have you served as an expert in
`district litigations involving a patent?
` A. Yes.
` Q. About approximately how many
`times have you served as an expert in
`District Court proceedings?
` A. So I don't know the exact number.
`My ITC has a fairly extensive list. I have
`probably been retained in the order of 50
`times. This is, today, my 33rd deposition.
`I have been to trial probably in District
`Court approximately five or six times and
`probably five or six times been to trial in
`the ITC.
` Q. So at this point you are very
`familiar with the deposition proceedings but
`I will just go over a couple of ground rules,
`if that's okay with you?
` A. Certainly.
` Q. So the proceeding is, I will ask
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 7
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`you questions and if you don't understand the
`question, please let me know, and I will
`rephrase it.
` Is that okay?
` A. Yes.
` Q. If you do understand -- strike
`the question. Let me start over.
` If you do understand a question,
`I will take that to mean that you did
`understand it.
` Is that fair?
` A. Yes.
` Q. Dr. Bravman, I am going to hand
`you what was previously marked in this
`proceeding as exhibit Gillette 1008 and here
`is one for you.
` A. Thank you.
` Q. Do you recognize this exhibit?
` A. Yes.
` Q. What is it?
` A. It's U.S. Patent 6,190,512 to
`Lantsman, L-A-N-T-S-M-A-N.
` Q. So if it's okay with you, we will
`refer to this exhibit, Gillette 1008, as
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 8
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`Lantsman?
` A. Yes.
` Q. Does Lantsman teach a power
`supply which reduces oscillations generated
`upon ignition of a plasma within a processing
`chamber?
` MR. MAIER: Objection to form.
` A. That's close to the exact wording
`of the first sentence in the abstract.
` Q. So you would agree that Lantsman
`teaches what I just identified in my previous
`question?
` A. I haven't rendered an opinion
`about that aspect of Lantsman, but that's
`certainly what it purports to teach.
` Q. What does it mean "reduces
`oscillations"?
` A. When you ignite a plasma and
`that's the context that it is stating there,
`the plasma itself may oscillate with regard
`to several different parameters. In this
`matter, for instance, we have seen over and
`undershoot damped oscillations of, say, the
`voltage applied across the anode and the
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 9
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`cathode as the impedence of the plasma
`changes.
` Q. And in your answer you referred
`to undershoot damage?
` A. I must have misspoke or -- not
`damage. Undershoot or overshoots with regard
`to various physical attributes, for instance,
`the voltage measured across the anode cathode
`assembly.
` Q. Can you define what you mean by
`undershoot?
` MR. MAIER: Objection to form.
` A. So with regard to voltage, for
`instance, as we have seen in other aspects of
`this broader matter, there is the desired or
`target voltage pulse applied to the -- across
`the anode and cathode but then we see that
`the measured voltage can exceed or be under
`that target and, typically, as a function of
`time, you see a series of variations that may
`be periodic or aperiodic but are generally
`referred to as oscillations in that
`particular parameter.
` Q. Does Lantsman disclose a
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 10
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`secondary power supply that pre-ignites the
`plasma?
` A. That's one of its disclosures,
`yes.
` Q. And does this secondary power
`supply drive the cathode to a process
`initiation voltage?
` MR. MAIER: Object to form.
` A. I don't want to answer from
`memory. I think it is that particular one.
`Let me just check.
` Q. If you want, I will give you a
`hint to look at the first page.
` A. In the abstract?
` Q. Yes. I noticed you were flipping
`through the entire document. I figured I
`would just help you, save you --
` A. The last sentence in the abstract
`speaks to your question.
` Q. So would you agree with the
`characterization that the secondary power
`supply in Lantsman drives the cathode to a
`process initiation voltage?
` A. That's what it claims, yes.
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 11
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
` Q. Now, does Lantsman disclose --
`let me start over. Strike the question.
` Does Lantsman also disclose a
`primary power supply that electrically drives
`the cathode to generate plasma current?
` A. Yes. I mean, the power supplies
`are meant to drive the cathode relative to
`the anode.
` Q. Now, Lantsman does not teach a
`pulsed power supply; is that right?
` A. It does not -- it does not
`describe the power supplies as capable of
`pulsing, that's right.
` Q. And Lantsman does not teach any
`type of electrical pulse, right?
` MR. MAIER: Object to form.
` A. It teaches on and off which could
`be a pulse. For instance, in -- in Figures 2
`and 3, it is clearly turning on a voltage and
`turning it off. But in the sense that the
`other -- much of the other patents we have
`been looking at in this matter talk about
`pulsing to various degrees, no, it is not
`describing that. Figure 6 makes it clear
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 12
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`that the cathode DC negative voltage is
`turned on and then it is turned off.
` Q. Lantsman does not teach a
`strongly ionized plasma, correct?
` MR. MAIER: Object to form.
` A. Strongly ionized plasma, as we
`have seen, is a relative term, and when
`plasmas are used for etching or sputtering,
`which is a subject of Lantsman, it is -- the
`plasma is often in what's called a strongly
`ionized plasma but Lantsman does not draw the
`distinction between weakly ionized and
`strongly ionized.
` Q. Well, in your opinion, would you
`consider the device that's disclosed and is
`described in Lantsman to generate a strongly
`ionized plasma?
` A. Again, because, at least, in
`these proceedings what is strong and weak are
`relative terms, there is nothing to compare
`qualitatively in Lantsman's description, but
`it is also true that what a worker of skill
`would understand by strongly ionized is the
`type of plasma that's typically used but
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 13
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`Lantsman does not call that out.
` Q. Okay, I understood your answer to
`indicate that Lantsman doesn't mention the
`phrase "strongly ionized plasma."
` Is that a correct
`characterization of your testimony?
` A. Yes.
` Q. Okay. Now, although Lantsman
`doesn't explicitly mention "strongly ionized
`plasma," in your opinion, does the device
`that's disclosed in Lantsman generate a
`strongly ionized plasma?
` A. Well, if I look, for instance, at
`column 2, line 48 and forward, it says,
`quote, "This secondary power supply
`pre-ignites the plasma so that when the
`primary power supply is applied, the systems
`smoothly transitions to final plasma
`development and deposition. This design
`thereby avoids oscillations when the primary
`power supply is engaged and disengaged."
` So in that description there, he
`is describing, at least, something analogous
`to the weakly and strongly ionized plasma
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 14
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`states that we have read about in other
`places. But whether you can properly
`consider that pre-ignition and then the
`ignition weak or strong, it just doesn't say.
`I don't have an opinion today whether or not
`it constitutes a strongly ionized plasma.
` Q. Is one of Lantsman's power
`supplies a DC power supply that is identified
`by the reference number 10?
` A. Yes.
` Q. And is the other power supply in
`Lantsman a secondary DC power supply that is
`identified by the reference number 32?
` A. Yes.
` Q. Just excuse me a second. I am
`going to grab another reference.
` A. Sure.
` Q. Dr. Bravman, I am going to hand
`you a reference which is previously marked as
`exhibit Gillette 1009.
` A. Thank you.
` Q. Do you recognize this exhibit?
` A. Yes.
` Q. What is it?
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 15
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
` A. It's U.S. Patent 5,958,155 to
`Kawamata, K-A-W-A-M-A-T-A, et al.
` Q. So if it is okay with you, when I
`ask questions, I will refer to exhibit
`Gillette 1009 as Kawamata; is that correct?
` A. Yes.
` Q. Does Kawamata teach a process for
`producing a thin film?
` A. Yes.
` Q. And does Kawamata also teach a
`sputtering at a high speed?
` A. Yes. Although high is a relative
`term, but, yes.
` Q. Well, that leads me into my next
`question. What would one of ordinary skill
`in the art understand the term "sputtering at
`a high speed" to mean?
` MR. MAIER: Object to form.
` A. If a worker of skill read this,
`he or she would understand that the author
`was making a claim that at least within some
`bounded range of parameters such as the
`material to be deposited, the methodology
`used, that the deposition rate would be high
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 16
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`as understood by workers of skill in that day
`given that different chambers or systems
`using that particular technique had some
`established record of acceptable deposition
`rates. All that to say, there is not a
`numerical cutoff to what constitutes high.
` Q. Does Kawamata teach producing a
`thin fluoride film that's free of light
`absorption?
` A. The material described in
`Kawamata is exactly fluoride, MgF2.
` Q. What is the phrase "free of light
`absorption" mean to you?
` MR. MAIER: Object to form.
` A. I would have to review it, again.
`I didn't focus on that aspect of it. Free of
`light absorption generally means that the
`defect -- that the material in question is
`not fundamentally absorbed or highly
`absorptive of light and that second article,
`it doesn't have defects within it that would
`diminish its theoretical transmissivity. It
`is in -- Kawamata discusses optically
`important materials. So that's a
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 17
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`consideration in those classes of materials.
` Q. Does Kawamata teach sputtering
`surface of the film source material so at
`least a portion of that material is ejected
`in molecular form?
` MR. MAIER: Object to form.
` A. Yes.
` Q. And what does it mean to eject
`material in molecular form?
` A. So the material in the discussion
`in the patent principally is MgF2. So that
`is a molecule -- it is a stoichiometry of the
`material is one atom of magnesium Mg and two
`atoms of Fluorine. So MgF2. And that would
`be considered a molecule, MgF2. The
`distinction would be made between atomic
`sputtering where individual atoms would be
`ejected. So when it speaks of molecular
`sputtering or ejection, the sputtering
`process ejects physically from the source
`surface or near surface region a molecule of
`desirously, I am sure, MgF2.
` Q. Kawamata makes no mention of
`applying a voltage pulse, right?
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 18
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
` A. No, that's correct.
` Q. Kawamata makes no mention of
`generating strongly ionized plasma, correct?
` MR. MAIER: Object to form.
` A. Again, strongly ionized is, in
`these proceedings, is a relative term. It
`does talk about specifically and successfully
`ejecting material from sputtering and
`elsewhere in this matter that's often
`associated with strongly ionized plasma. But
`the phrase "strongly ionized plasma" does not
`-- is not found within the patent.
` Q. In your opinion, does the device
`that's described in Kawamata generate
`strongly ionized plasma?
` A. I haven't offered an opinion
`about that because, again, that's a matter of
`definitions. It would be my opinion that
`Kawamata is describing a successful
`application of sputtering technology to this
`particular material. But I have not offered
`an opinion about whether that would be called
`or that would happen through the application
`of high density plasma or not.
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 19
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
` Q. Does Kawamata teach applying
`power continuously?
` A. It talks about radio frequency
`sputtering so at the right time scale, it is
`not continuous. It is turning on and off
`millions of times per second. But it's not
`giving recipes that talk about -- it is not
`getting recipes that would allow me to answer
`your question in the affirmative.
` Q. Just bear with me. I will grab
`another exhibit.
` A. Sure.
` Q. Dr. Bravman, I am going to hand
`you an exhibit that was previously marked as
`Gillette 1004.
` A. Thank you.
` MR. MAIER: Thanks.
` Q. Do you recognize this exhibit?
` A. Yes.
` Q. What is it?
` A. It's an excerpt from a work
`called "Encyclopedia of Low Temperature
`Plasma" from the third volume. It is a
`translation from Russian.
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 20
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
` Q. Was the exhibit identified by
`Gillette 1004, was it edited by a person
`named Fortov, F-O-R-T-O-V?
` A. Yes.
` Q. So if it is okay with you, we
`will refer to exhibit Gillette 1004 as
`Fortov?
` A. Yes.
` Q. Does Fortov describe the
`relationship between the sputtering yield and
`the temperature of the target?
` A. Yes.
` Q. Fortov does not describe how to
`achieve a nonlinear relationship between the
`sputtering yield and the target temperature;
`is that right?
` MR. MAIER: Objection to form.
` A. Sorry, could you read back the
`question?
` (Record read.)
` MR. MAIER: Objection to form.
` A. Well, as I hear the question, it
`does, because it indicates and shows data for
`sputtering yield as a function of temperature
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 21
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`so that directs a worker of skill to first
`understand and then actually achieve
`nonlinear or enhanced sputtering yields by
`elevating the temperature of a target at
`least in the region where ejected matter is
`originating.
` Q. Does Fortov disclose a device
`that performs sputtering?
` A. No, this reference is more
`fundamental scientific work that is
`discussing sputtering yield as a function of
`many variables.
` Q. Does Fortov teach choosing an
`amplitude and rise time of a voltage pulse to
`cause a sputtering yield to be nonlinearly
`related to a temperature of a sputtering
`target?
` MR. MAIER: Objection to form;
` calls for a legal conclusion.
` A. From a technical viewpoint, no.
`Again, it is talking about various aspects of
`sputtering yield including temperature
`dependents.
` Q. Dr. Bravman, I am going to hand
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 22
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`to you an exhibit that was previously
`identified as Gillette Exhibit 1002.
` A. Thank you.
` Q. Dr. Bravman, do you recognize the
`exhibit that's identified as Gillette
`Exhibit 1002?
` A. Yes.
` Q. What is it?
` A. It is a translation of a paper by
`Mozgrin and others entitled, "High Current
`Low Pressure Quasi Stationary Discharge in
`the Magnetic Field: Experimental Research."
` Q. If it's okay with you, I will
`refer to Gillette 1002 as Mozgrin in my
`questions.
` Is that alright?
` A. Yes.
` Q. Does Mozgrin teach a high power
`quasi stationary low pressure discharge in
`the magnetic field?
` A. Yes.
` Q. What does quasi stationary mean
`to one of ordinary skill in the art?
` MR. MAIER: Object to form;
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 23
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
` calls for a legal conclusion.
` A. From a technical viewpoint, first
`of all, one would want to read how that
`phrase is used in context. But it's a state
`between what one might colloquially called
`truly stationary, meaning unchanging, over at
`least some material period of time and one
`that is highly transient. So it's achieving
`something close to static character over some
`material timeframe.
` Q. Now, in your answer, you referred
`to achieving something close to static
`character over some material timeframe?
` A. Yes.
` Q. What particular quantity or
`quantities in Mozgrin were you referring to
`in your answer?
` MR. MAIER: Objection to form.
` A. Well, the nature of the
`discharge, if we look on page 402 of Mozgrin,
`the title for section 3 is "Quasi Stationary
`Discharge Regimes" and in that it includes,
`for instance, Figure 3 and the text in the
`right-hand column of page 402 in the second
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 24
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`paragraph, approximately midway down, it uses
`the phrase, "and then both the discharge
`current and voltage attain their quasi
`stationary values (part 3)."
` So it is referring to the
`silograms in Figure 3, and the data there is
`clearly not absolutely fixed or static. It
`has some variation over the region labeled 3,
`and I think that's why he fairly called it
`quasi stationary and not a stationary or
`static region.
` Q. Now, you referred to regions in
`your response. How many different regions
`does Mozgrin disclose?
` MR. MAIER: Object to form.
` A. Well, in Figure 4, he -- and in
`the text, he describes four distinct regions.
`In the silograms of Figure 3, he marks three
`regions, one of which, region 2, is
`subdivided into two parts, 2(a) and 2(b). So
`depending on which data set you are looking
`at, it is three or four regions.
` Q. Now, Mozgrin also refers to
`regimes, R-E-G-I-M-E-S.
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
` Do you see that?
` A. Yes.
` Q. Does Mozgrin use the term "region
`and regimes" interchangeably so that they
`mean the same thing?
` MR. MAIER: Objection to form.
` A. I haven't offered an opinion
`about that. I understand your question. In
`the first paragraph on the right-hand column
`of page 402, the last sentence is, "As a
`result, we found out that a variety of
`regimes differing in discharge voltage,
`current range and discharge space structure
`occurred."
` I mean, there he is using regime,
`it seems to me, in a somewhat broader
`fashion. So it's a collection of or a range
`of data. So I don't mentally trip on that
`use. I understand that there he is using
`regime to describe, more or less, a
`collection of data sets. There may be other
`places where he uses it more interchangeably.
`But I think at least there and, of course, we
`have to recall this is a translation that he
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 26
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`is using regime there with a slightly
`different flavor of meaning.
` Q. Does Mozgrin teach studies using
`two different discharge device
`configurations?
` A. Sorry, I am not following what
`your question is pointing to.
` MR. GONSALVES: Could you repeat
` the question for him.
` (Record read.)
` A. Yes, he teaches two physical
`configurations of magnetrons, that is
`correct.
` Q. Is one of the physical
`configurations called a planar magnetron?
` A. Yes.
` Q. Is the other configuration called
`a shaped electrode configuration?
` A. Yes.
` Q. Does Mozgrin teach that the
`planar magnetron includes a plain cathode
`that is 120 millimeters in diameter?
` A. It teaches a planar cathode, and
`let me just find the description of it. Yes,
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 27
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`at the bottom of column 1, sorry, column 2 in
`the first page, he is in fact describing
`cathode 120 millimeters in diameter.
` Q. Does Mozgrin teach a
`ringed-shaped anode that is 160 millimeters
`in diameter?
` A. It does.
` Q. Mozgrin does not teach how far
`the cathode is separated from the anode in
`the planar magnetron structure, correct?
` MR. MAIER: Objection to form.
` A. It does not, in a text, call out
`in similar fashion a numeric value. It has
`illustration in Figure 1(a) that shows the
`gap to be less than the diameter by a
`significant degree which comports with a
`worker of skill's understanding of generally
`how these devices would be built.
` But, as I said, does not call out
`numerically, again.
` Q. In your answer, you referred to
`Figure 1(a); is that correct?
` A. Yes.
` Q. Is figure (a) drawn to scale?
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 28
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
` A. It doesn't say whether it's a
`scale figure or not. It's not a blueprint,
`on the one hand. On the other hand, it is
`meant to describe for a reader of skill the
`device in question; and again, since it
`comports with the configuration that would be
`familiar to a worker of skill, I think it's a
`reasonably accurate rendition.
` Q. Does Mozgrin teach that the
`system with shaped electrodes has two hollow
`axisymmetrical electrodes that are
`120 millimeters in diameter?
` A. It does.
` Q. What does axisymmetrical mean to
`one of ordinary skill in the art?
` A. If one looks at Figure 1(b), one
`sees what would be a cross-section cut. A
`worker of skill would understand that one
`sees a cross-section cut down through the
`radial axial symmetric magnetrons or magnets.
`So the cross-hatched rectangles four in
`number are where the cut that produces the
`view in Figure 1(b) is made, and that is
`cutting through the annular rings that
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 29
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`comprise the upper and lower magnets in this
`shaped configuration.
` Q. So in your answer, you referred
`to 1(c). Did you mean to refer to 1(b)?
` A. I am sorry, 1(b), yes.
` Q. That's what I figured. Mozgrin
`does not teach that an amplitude and a rise
`time of the voltage pulse chosen to cause a
`sputtering yield to be nonlinearly related to
`the temperature of the sputtering target,
`right?
` MR. MAIER: Objection to form.
` A. Mozgrin does not teach
`specifically that there is a nonlinear
`dependence of sputtering yield with
`temperature of the target.
` Q. And Mozgrin does not mention any
`relation between sputtering yield and the
`temperature of the sputtering target, right?
` MR. MAIER: Object to form.
` A. I believe that's correct.
` Q. Dr. Bravman, I am going to hand
`you an exhibit that was previously marked as
`Gillette 1006.
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 30
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
` A. Thank you.
` Q. Dr. Bravman, do you recognize
`this exhibit that was marked as Gillette
`1006?
` A. Yes.
` Q. And what is it?
` A. It's an article entitled,
`"Ionization Relaxation in a Plasma Produced
`By Pulsed Inner Gas Discharge" by Kudryavtsev
`and others.
` Q. If it is okay, I will referred to
`the exhibit marked Gillette 1006 by the first
`author's last name Kudryavtsev.
` Is that okay?
` A. Yes.
` Q. Now, you referred to, when you
`read the title of Kudryavtsev, you referred
`to "ionization relaxation"?
` A. Yes.
` Q. What is that term, "ionization
`relaxation," mean to one of ordinary skill in
`the art?
` A. It is a paper that develops a
`model or theoretical approach to both
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 31
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`ionization and relaxation. Ionization one
`understands is the ejection of electrons from
`atoms or from ions; and relaxation is a broad
`term that describes when you have atomic --
`when you have atoms in an excited or ionized
`state, what subsequently happens in time.
`Reflecting the fact that excited or ionized
`atoms are generally not the stable form of
`atomic matter.
` Q. Was Kudryavtsev mainly interested
`in analyzing the buildup of the electron
`density and the behavior of the spacial
`distribution of the electron to density
`during the relaxation process?
` MR. MAIER: Objection to form.
` A. He certainly very directly
`involves -- interested in the changes in
`electron to density. He also talks about the
`temporal and spacial components of those
`changes so I think the answer -- the fair
`answer to your question is yes.
` Q. Does Kudryavtsev also disclose
`performing experimental ionization relaxation
`and comparing the experimental results with
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 32
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`the model?
` A. Yes, although it is a theoretical
`or modeling paper, he does have an
`experimental section in which he describes
`one type of ionization. And then goes on to
`show how the data that he collected in those
`experiments comports with his theoretical or
`modeling work.
` Q. Could Kudryavtsev have used a
`device including electrodes and a cylindrical
`tube having a diameter of 2.5 centimeters to
`perform the experiments?
` A. That's the description in part
`that he gives of his test apparatus, yes.
` Q. The distance between the
`electrodes in Kudryavtsev's test apparatus
`was 52 centimeters; is that correct?
` A. Yes.
` Q. Now, the experimental results
`that were determined from Kudryavtsev's
`experiments with his device would be
`different than the results that would be
`obtained with, for example, Mozgrin as planar
`magnetic device; is that right?
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 33
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
` MR. MAIER: Objection to form.
` A. They would be different in some
`regards that a worker of skill would know
`would be related to the particularities of
`the plasma generating system but in other
`ways, this is the principal contribution of
`the Kudryavtsev paper. They would comport
`with the modeling therein, and as the author
`of the paper himself states, even in the last
`sentence of the paper, and certainly the last
`paragraph, he has developed a general model
`for pulsed inert gas discharge -- discharges,
`and how this is important work for a variety
`of applications.
` Q. You mentioned in your answer that
`some of the results obtained from
`Kudryavtsev's device would differ than the
`results that would be obtained with Mozgrin's
`planar magnetron device.
` What results would b
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
