`By: David L. Cavanaugh, Reg. No. 36,476
`
`Yung-Hoon Ha, Reg. No. 56,368
`
`Wilmer Cutler Pickering Hale and Dorr LLP
`
`1875 Pennsylvania Ave., NW
`
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: David.Cavanaugh@wilmerhale.com
`Yung-Hoon.Ha@wilmerhale.com
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________________________________
`
`The Gillette Company, Fujitsu Semiconductor Limited, and Fujitsu Semiconductor
`America, Inc.
`
`Petitioners,
`
`
`
`v.
`
`Zond, Inc.
`Patent Owner of U.S. Patent No. 6,896,773
`Trial No. IPR2014-005801
`
`
`
`PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION FOR
`OBSERVATION ON CROSS-EXAMINATION OF PETITIONER’S REPLY
`WITNESS DR. JOHN C. BRAVMAN
`
`
`1 Case IPR2014-01479 has been joined with the instant proceeding.
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`
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`Trial No. IPR2014-00580
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`TABLE OF CONTENTS
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`
`INTRODUCTION ........................................................................................... 1
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`RESPONSES TO OBSERVATIONS ON DR. BRAVMAN’S
`TESTIMONY .................................................................................................. 1
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`A. Observation 1 ........................................................................................ 1
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`B.
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`C.
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`Observation 2 ........................................................................................ 3
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`Observation 3 ........................................................................................ 5
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`D. Observation 4 ........................................................................................ 7
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`E.
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`F.
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`Observation 5 ........................................................................................ 8
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`Observation 6 ........................................................................................ 9
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`G. Observation 7 ...................................................................................... 10
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`H. Observation 8 ...................................................................................... 11
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`I.
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`J.
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`Observation 9 ...................................................................................... 11
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`Observation 10 .................................................................................... 12
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`
`
`i
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`I.
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`II.
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`Trial No. IPR2014-00580
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`INTRODUCTION
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`I.
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`Petitioner submits this response to Patent Owner Zond’s Motion for
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`Observation on Cross-Examination of Dr. Bravman, Paper No. 43
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`(“Observation”) . Patent Owner presents ten observations on Dr. Bravman’s
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`testimony. While Petitioner believes that the testimony will be appropriately
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`viewed and weighed by the Board, the specific observations presented by Patent
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`Owner mischaracterize the testimony of Dr. Bravman, as specified below and
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`therefore are not probative of any material issue before the Board.
`
`II. RESPONSES TO OBSERVATIONS ON DR. BRAVMAN’S
`TESTIMONY
`A. Observation 1
`Patent Owner contends that Dr. Bravman’s testimony indicates “that it
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`would not have been obvious to combined either Lantsman or Kawamata with the
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`other asserted prior art. . . .” Observation at 2. Patent Owner alleges that the cited
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`testimony is relevant because “it shows that the Petitioners did not identify
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`objective evidence tending to establish that the teachings of Lantsman’s dual
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`power supply or Kawamata could have been used in a system that uses a pulsed
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`power supply and generates a strongly-ionized plasma. . . .” Observation at 2.
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`These observations are not accurate.
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`Dr. Bravman does not contend that Lantsman or Kawamata should be
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`modified to apply voltage pulses and to generate a “strongly-ionized plasma,” as
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`1
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`Trial No. IPR2014-00580
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`the selected portions of the testimony misleadingly implies. Dr. Bravman’s
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`declaration states that it would have been obvious to use Lantsman’s “continuous
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`gas flow” and Kawamata’s “cooling” mechanisms with Mozgrin. See Bravman
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`Decl. ¶¶ 104-105 (“Mozgrin does, in fact, teach a continuous flow of gas. . . . Use
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`of Lantsman’s continuous gas flow within Mozgrin is a combination of old
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`elements in which each element behaved as expected.”; id. ¶ 91 (“Kawamata and
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`Mozgrin both avoid increasing the average temperature of the sputtering target by
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`cooling the target and … one of ordinary skill would have been motivated to
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`combine the teachings of Kawamata and Mozgrin.”). There is nothing inconsistent
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`in his deposition testimony. For example, he testified that “in these proceedings
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`what is strong and weak are relative terms, there is nothing to compare
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`qualitatively in Lantsman’s description, but it is also true that what a worker of
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`skill would understand by strongly ionized is the type of plasma that’s typically
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`used but Lantsman does not call that out.” Bravman ’773 Dep. at 12:15-13:2 (Ex.
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`1032). Similarly, he testified: “Again, strongly ionized is, in these proceedings, is a
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`relative term. It [Kawamata] does talk about specifically and successfully ejecting
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`material from sputtering and elsewhere in this matter that’s often associated with
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`strongly-ionized plasma.” Bravman ’773 Dep. at 18:3-13 (Ex. 1032). Thus, the
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`testimony the Patent Owner identifies, both by itself and also when viewed in
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`context of his other testimony, does not support the argument made by the Patent
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`Trial No. IPR2014-00580
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`Owner.
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`B. Observation 2
`Patent Owner contends that Dr. Bravman’s testimony indicates “that Fortov,
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`Mozgrin, and Kudryavtsev do not teach” the claim limitation “choosing an
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`amplitude and rise time of a voltage pulse to cause a sputtering yield to be
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`nonlinearly related to a temperature of a sputtering target. . . .” Observation at 4.
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`Patent Owner alleges that the cited testimony is relevant because “it undermines
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`the Petitioners’ position that this claim limitation is taught by the combination of
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`these references. . . .” Observation at 4. Patent Owner is incorrect.
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`Patent Owner cites testimony showing that neither Mozgrin nor Fortov
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`alone teaches the limitation “choosing an amplitude and rise time of a voltage
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`pulse to cause a sputtering yield to be nonlinearly related to a temperature of a
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`sputtering target.” Observation at 4. This issue has already been addressed by the
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`Board, and the Board rejected the approach. Decision at 21 (“[O]ne cannot show
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`nonobviousness by attacking references individually where the rejections are based
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`on combinations of references.”).
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`Dr. Bravman has testified throughout this proceeding that it is the
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`combination of Mozgrin and Fortov that render this limitation obvious. First, Dr.
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`Bravman testified that Mozgrin discloses controlling voltage pulses:
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`Q. Does -- does Mozgrin describe the control of voltage pulses?
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`Petitioner’s Response to Patent Owner’s Motion for Observation
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`A. He reports on at least page 402 what he calls oscillograms of
`voltage and current characteristics. . . . [H]e’s clearly indicating that
`those quantities must be known and I would opine controlled. . . . [S]o
`again my opinion is that a worker of skill would understand this in the
`context of plasma apparatus to be able to control voltage and current.
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`Bravman ’775 Dep. at 28:8-23 (Ex. 1032); Bravman Decl. ¶¶ 61-62 (Ex. 1028).
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`
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`Second, Dr. Bravman testified that Fortov explains precisely how to achieve
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`the temperature at which point the relationship to sputtering yield becomes non-
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`linear:
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`Q. Does Fortov describe the relationship between the sputtering
`yield and the temperature of the target?
`
`A. Yes.
`
`Fortov does not describe how to achieve a nonlinear
`Q.
`relationship between the sputtering yield and the target temperature; is
`that right? …
`
`A. Well, as I hear the question, it does, because it indicates and
`shows data for sputtering yield as a function of temperature, 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. . . .
`
`Bravman ’773 Dep. at 20:10-21:7 (Ex. 1032); see also Bravman Decl. ¶ 63 (“[F]or
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`a copper target … we can expect the nonlinear relationship to begin somewhere
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`around 0.7 Tm, the melting point of copper. . . .”) (Ex. 1028).
`
`
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`Finally, Dr. Bravman testified that the equation describing the nonlinear
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`relationship between sputtering yield and temperature in Fortov is directly
`
`applicable to Mozgrin:
`
`Q. What does equation 10.7 of Fortov describe? …
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`It describes what it calls the thermal sputtering yield capital Y
`A.
`sub T.
`
`Q. As a function of what?
`
`A.
`
`Temperature. …
`
`Q. What did you conclude regarding the applicability of equation
`10.7 of Fortov to Mozgrin’s sputtering regime? …
`
`A.
`
`That it is applicable.
`
`Bravman ’773 Dep. at 99:7-22 (Ex. 1032); see also Bravman Decl. ¶ 63
`
`(“Moreover, both Mozgrin and Fortov describe the use of copper targets.”) (Ex.
`
`1028). Accordingly, the combination of Fortov and Mozgrin teaches the claim
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`limitation “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
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`target. . . .”
`
`C. Observation 3
`Patent Owner contends that Dr. Bravman’s testimony indicates “that it
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`would not have been obvious to combine Mozgrin with Kudryavtsev. . . .”
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`Observation at 6. Patent Owner alleges that the cited testimony is relevant because
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`“it shows that the Petitioners did not identify objective evidence tending to
`
`establish that the teachings of the very different devices of Mozgrin and
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`Kudryavtsev would have led to predictable results. . . .” Observation at 6. The
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`Patent Owner mischaracterizes Dr. Bravman’s testimony.
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` Patent Owner cites testimony purporting to show that Dr. Bravman did not
`
`determine how the specific graphs in Kudryavtsev would change if Mozgrin’s
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`magnetron system had been physically substituted for that of Kudryavtsev.
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`Observation at 7-9. Patent Owner’s questions in this portion of the cross-
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`examination relate to an approach toward non-obviousness that the Board has
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`already considered and rejected . Decision at 21 (“It is well-established that a
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`determination of obviousness based on teachings from multiple references does not
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`require an actual, physical substitution of elements.”) (internal quotations and
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`citations omitted).
`
`Dr. Bravman testified that “a worker of skill understands, for instance, the
`
`difference between extrinsic and intrinsic parameters, things that are geometry
`
`dependent and things are basic physics and directly applicable across
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`experimental regimes.” Bravman ’773 Dep. at 33:16-34:15 (Ex. 1032). Indeed,
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`Dr. Bravman testified as follows:
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`6
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`Trial No. IPR2014-00580
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`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?
`
`They would be different in some regards that a worker of skill
`A.
`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.
`
`Bravman ’773 Dep. at 32:20-33:15 (Ex. 1032). Accordingly, Dr. Bravman’s
`
`testimony is consistent with the Petitioner’s position that it would have been
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`obvious to combine Mozgrin with Kudryavtsev.
`
`D. Observation 4
`Patent Owner contends that Dr. Bravman’s testimony indicates “that it
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`would not have been obvious to combine Mozgrin with Kudryavtsev. . . .”
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`Observation at 6. Patent Owner alleges that the cited testimony is relevant because
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`“it shows that the Petitioners did not identify objective evidence tending to
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`establish that the teachings of the very different devices of Mozgrin and
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`Petitioner’s Response to Patent Owner’s Motion for Observation
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`Kudryavtsev would have led to predictable results. . . .” Observation at 6. Patent
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`Owner’s arguments are misplaced for the same reasons discussed above in
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`connection with Observation 3.
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`Dr. Bravman did not purport to measure “electron fluxes”—a concept
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`mentioned nowhere in the ’773 patent. Dr. Bravman testified that “a worker of
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`skill understands, for instance, the difference between extrinsic and intrinsic
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`parameters, things that are geometry dependent and things are basic physics and
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`directly applicable across experimental regimes.” Bravman ’773 Dep. at 33:16-
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`34:15 (Ex. 1032).
`
`E. Observation 5
`Patent Owner contends that Dr. Bravman testified that “sputtering does not
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`occur in region 3” and “[t]he testimony is relevant because the Petitioner relied
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`upon region 3 of Mozgrin in its argument that Mozgrin teaches the sputtering that
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`is claimed in the ‘773 patent.” Observation at 10-11. Patent Owner’s observations
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`misleadingly imply that Dr. Bravman’s obviousness analysis somehow hinges on
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`whether or not Mozgrin performs sputtering in regime 3. Not so. Dr. Bravman
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`testified that Mozgrin expressly teaches a sputtering regime 2:
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`Q. Does Mozgrin disclose a sputtering regime?
`
`A.
`
`Yes it does.
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`Bravman ’773 Dep. at 98:22-25; emphases added (Ex. 1032).
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`Trial No. IPR2014-00580
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`The Patent Owner confuses Mozgrin’s region 3 in Figure 3 with the etching
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`regime 3 of Figure 4. Dr. Bravman’s testimony is consistent with his declaration,
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`which explained that “the oscillograms shown in Mozgrin’s Fig. 3 [which has
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`regions 1, 2 and 3] when taken as a whole corresponds to a point either in regimes
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`2 or 3 of Mozgrin’s Figs. 4 and 7.” Bravman Declaration at ¶60; see also
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`Bravman ’773 Dep. at 24:13-23 (“Q. … How many different regions does Mozgrin
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`disclose? … A. Well, in Figure 4, he -- and in the text, he describes four distinct
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`regions. In the [oscillograms] of Figure 3, he marks three regions, one of which,
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`region 2, is subdivided into two parts, 2(a) and 2(b). So depending on which data
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`set you are looking at, it is three or four regions.”) (Ex. 1032). Accordingly,
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`Mozgrin teaches sputtering in regime 2 of Figure 4, where each data point in the
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`sputtering regime 2 of Figure 4 is derived from the oscillograms of Figure 3 that
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`contains regions 1, 2 and 3.
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`F. Observation 6
`Patent Owner contends that Dr. Bravman’s testimony indicates “that
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`Petitioners’ invalidity argument with respect to the feed gas limitations are based
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`on a faulty claim construction” because “Petitioners’ invalidity grounds are based
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`on a claim construction that reads the claim term ‘feed’ out of the claims.”
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`Observation at 11, Paper No. 43, citing Bravman ’773 Dep. at 67:15-23 (Ex. 1032).
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`However, Dr. Bravman does not ignore the term “feed.” He merely
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`Trial No. IPR2014-00580
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`disagrees with Patent Owner’s argument—already rejected by the Board—that the
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`term “feed” requires the gas to “flow.” Dr. Bravman testified that a “feed gas in
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`the context of this matter is a gas that is subsequently ionized in part to become
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`part of a plasma. It is a thing, and in that regard, the word ‘feed’ does not
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`influence my answer.” Bravman ’773 Dep. at 68:5-9 (Ex. 1032); see also
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`Bravman ’773 Dep. at 67:3 – 68:9 (Ex. 1032). The Board agreed with this
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`interpretation of the term “feed gas.” See IPR2014-00578 Decision on Institution
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`at p. 9, Exhibit 1027 (“The recitation of ‘a feed gas’ … does not necessarily imply
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`the flow of gas.”).
`
`G. Observation 7
`Patent Owner contends that Dr. Bravman’s testimony indicates “that the
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`Petitioners’ invalidity argument against claim 10 is based on a faulty claim
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`construction.” Observation at 12, Paper No. 43, citing Bravman ’773 Dep. at
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`85:23-86:11 (Ex. 1032). However, the Patent Owner did not cross-examine Dr.
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`Bravman on his understanding of the term “electrode” recited in claim 10, which
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`Dr. Bravman already opined on in his declaration. See Bravman Declaration at ¶76
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`(“Hence, the ‘773 patent teaches that the ionization source can be either the anode,
`
`cathode assembly or a third electrode.”).
`
`Patent Owner’s cross-examination merely reaffirmed Dr. Bravman’s opinion
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`that “either the anode or cathode shown in Mozgrin’s FIG. 1 constitutes an
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`10
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`Trial No. IPR2014-00580
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`‘electrode’ as recited in claim 10.” Bravman Declaration at ¶74, Exhibit 1028.
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`H. Observation 8
`Patent Owner contends that Dr. Bravman’s testimony indicates “that
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`Mozgrin does not supply gas during the plasma generation process as required by
`
`the claim term ‘feed gas.’” Observation at 13, Paper No. 43, citing Bravman ’773
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`Dep. at 75:23-76:4 (Ex. 1032). Patent Owner alleges that because “the chamber of
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`Mozgrin is filled up with gas rather than supplied with gas during the plasma
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`generation… it shows that Mozgrin does not meet the term ‘feed gas.”
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`Observation at 13.
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`To the contrary, Dr. Bravman testified that “a worker of skill understand
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`when you introduce a gas to an otherwise evacuated space, a chamber, that natural
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`diffusion will rapidly equilibrate the density or pressure throughout that volume.”
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`Bravman ’773 Dep. at 74:23 – 75:7 (Ex. 1032). In other words, Dr. Bravman
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`testified that a gas can “fill up” a chamber through rapid diffusion that naturally
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`occurs, especially in an evacuated space. His testimony is consistent with his
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`opinion rejecting “Patent Owner’s position that Mozgrin does not teach a feed gas
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`because it uses a static gas.” Bravman Declaration at ¶49, Exhibit 1028.
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`Observation 9
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`I.
`Patent Owner contends that Dr. Bravman’s testimony indicates “that
`
`Mozgrin does not teach “a rise time of the voltage pulse is chosen to increase an
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`11
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`Trial No. IPR2014-00580
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`ionization rate of the strongly-ionized plasma,’ as recited in claim 11.”
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`Observation at 14. Patent Owner alleges that the cited “testimony is relevant
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`because the Petitioners’ relied on the mere increase in the number of ions to
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`support its argument that Mozgrin teaches an increase in the ionization rate.”
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`Observation at 13-14. In fact, Dr. Bravman’s cross-examination testimony is
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`consistent with his declaration.
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`In his declaration, Dr. Bravman noted that “application of the ‘voltage pulse
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`[to the weakly-ionized plasma] in Mozgrin will cause…the plasma density [to]
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`grow.’” Bravman Declaration at ¶ 114, citing Patent Owner’s own expert’s
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`testimony, Exhibit 1028. Patent Owner merely fails to acknowledge Dr.
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`Bravman’s further opinion that “ ‘if you have a quick increase in the plasma
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`density, … that indicate[s] a quick increase in the rate of ionization.’” Bravman
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`Declaration at ¶ 113, citing Patent Owner’s own expert’s testimony, Exhibit 1028.
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`J. Observation 10
`Patent Owner contends that Dr. Bravman’s testimony indicates “that
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`Mozgrin does not teach … “strongly-ionized plasma is substantially uniform
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`proximate to the cathode assembly,’ as recited in claim 13.” Observation at 14,
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`Paper No. 43, citing Bravman ’773 Dep. at 88:6-12 and 89:3-18 (Ex. 1032).
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`Patent Owner mischaracterizes Dr. Bravman’s testimony. Dr. Bravman
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`testified that while Figure 6(a)(1) of Mozgrin may have different plasma densities
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`Trial No. IPR2014-00580
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`in different parts of the image, the image indeed shows that the plasma is uniform
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`proximate to the cathode assembly of Mozgrin.
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`Q: Now, if you can turn to Figure 6 of Mozgrin on page 405
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`and focus on the figure at the top left labeled A-1?
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`A: I have it.
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`Q: What did you conclude regarding whether the plasma shown
`
`in that figure is substantially uniform approximate to the cathode?
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`MR. GONSALVES: Objection.
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`A: In the sputtering regime[,yes,] which [i]s exactly the type of
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`uniformity one would expect.
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`Bravman ’773 Dep. at 100:20 – 101:7 (Ex. 1032).
`
`Respectfully Submitted,
`
`/David L. Cavanaugh/
`
`David L. Cavanaugh
`Registration No. 36,476
`WILMER CUTLER PICKERING
`HALE AND DORR LLP
`1875 Pennsylvania Avenue, N.W.
`Washington, D.C. 20006
`david.cavanaugh@wilmerhale.com
`Tel.: 202-663-6000
`Fax: 202-663-6363
`
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`Dated: May 15, 2015
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`Trial No. IPR2014-00580
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`CERTIFICATE OF SERVICE
`
`I hereby certify that on May 15, 2015, I caused a true and correct copy of the
`
`foregoing materials:
`
` Petitioner’s Response to Patent Owner Zond’s Motion for Observation
`on Cross-Examination of Dr. Bravman
` Exhibit 1032
` Exhibit Appendix
`
`to be served via e-mail, as previously agreed by the parties, on the following
`
`attorneys of record:
`
`
`
`Dr. Gregory J. Gonsalves
`2216 Beacon Lane
`Falls Church, VA 22043
`(571) 419-7252
`gonsalves@gonsalveslawfirm.com
`
`Bruce Barker
`Chao Hadidi Start & Barker LLP
`176 East Mail Street, Suite 6
`Westborough, MA 01581
`bbarker@chsblaw.com
`
`
`
` /Yung-Hoon Ha/
` Yung-Hoon Ha
` Registration No. 56,368
`
`
`
`14
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`EXHIBIT APPENDIX
`Description
`U.S. Patent No. 6,896,773
`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
`(“Mozgrin”)
`U.S. Patent No. 6,413,382 (“Wang”)
`Certified Translation of Encyclopedia of Low-Temperature
`Plasma Physics, Introductory Vol. III, Section VI, Fortov,
`V.E., Ed., Nauka/Interperiodica, Moscow (2000); pp. 117-126
`(“Fortov”)
`Declaration of Richard DeVito (“DeVito”)
`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 (“Kudryavtsev”)
`U.S. Patent No. 6,306,265 (“Fu”)
`U.S. Patent No. 6,190,512 (“Lantsman”)
`U.S. Patent No. 5,958,155 (“Kawamata”)
`Encyclopedia of Low-Temperature Plasma Physics,
`Introductory Vol. III, Section VI, Fortov, V.E., Ed.,
`Nauka/Interperiodica, Moscow (2000); pp. 117-126 (in
`Russian)
`U.S. Patent No. 6,398,929 (“Chiang”)
`Gas Discharge Physics, by Raizer, Table of Contents, pp. 1-
`35, Springer 1997 (“Raizer”)
`File History of U.S. Pat. No. 6,896,773, Amendment mailed
`October 19, 2004 (“10/19/04 Amendment”)
`Catalogue Entry at the Russian State Library for the Mozgrin
`Thesis
`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)
`Thornton, J. and Hoffman, D.W. Stress related effects in thin
`films, Thin Sold Films, 171, 1989, 5-31
`
`Savvides and B. Window, Unbalanced magnetron ion‐assisted
`
`15
`
`Exhibit
`1001
`
`1002
`1003
`
`1004
`1005
`
`1006
`1007
`1008
`1009
`
`1010
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`1016
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`1017
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`1024
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