`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2014-00580 and 726
`Patent 6,896,773
`
`PATENT OWNER ZOND LLC’S
`DEMONSTRATIVE EXHIBIT
`
`1
`
`
`
`OBVIOUSNESS
`Claims 1-20 and 34-40 Are Not Obvious Over Mozgrin
`and Fortov
`Mozgrin and Fortov would not have
`taught:
`“an ionization source that generates
`a weakly-ionized plasma from a feed
`gas proximate to the anode and the
`cathode assembly,” as recited in
`independent claim 1 and as similarly
`recited in independent claim 34
`
`2
`
`
`
`OBVIOUSNESS
`Claims 1-20 and 34-40 Are Not Obvious Over Mozgrin
`and Fortov
` Petitioners relied on Mozgrin alone for this limitation and
`Mozgrin does not teach a weakly ionized plasma
`proximate to both the anode and the cathode assembly:
`
`“For pre-ionization, we used a stationary magnetron
`discharge; the discharge current ranged up to 300 mA. We
`measured the discharge current-voltage characteristics (CVC)
`in a 10^-3 – 10 torr pressure range and plasma parameters of
`the discharge at the symmetry center of the shaped-
`electrode system using a probe technique. We found out
`that only the regime with magnetic field strength not lower
`than 400 G provided the initial plasma density in the 10^9 –
`10^11 cm-3 range (Mozgrin at 401, right col, ¶ 2 (emphasis
`added)).
`
`3
`
`
`
`OBVIOUSNESS
`Claims 1-20 and 34-40 Are Not Obvious Over Mozgrin
`and Fortov
`
`4
`
`
`
`OBVIOUSNESS
`Claims 1-20 and 34-40 Are Not Obvious Over Mozgrin
`and Fortov
` Mozgrin does not teach a weakly ionized plasma
`proximate to both the anode and the cathode assembly:
`
`As shown by Fig. 1(b) on the previous slide, the axis of
`symmetry (i.e., the place where Mozgrin measured the
`density of the plasma) is as far away from both the cathode
`(1) and anode (2) as it possibly can be while still being
`between the cathode and anode.
`only the area at the perimeters of the anode and cathode
`along the r-axis of Fig. 1(b) reproduced above (i.e., high
`positive and negative values of r at z = 0) are close to both
`the anode and cathode. That is, the only area that is close to
`both the anode and cathode is not the area where Mozgrin
`measured the density of the plasma.
`
`5
`
`
`
`OBVIOUSNESS
`Claims 1-20 and 34-40 Are Not Obvious Over Mozgrin
`and Fortov
`Mozgrin does not teach generating a weakly
`ionized plasma from a feed gas:
`
`Mozgrin does not teach a feed gas, let alone
`generating a weakly-ionized plasma from a flowing
`feed gas.
`
`Rather, Mozgrin discloses “… the discharge gap …
`was filled up with either neutral or pre-ionized
`gas.” (Mozgrin, p. 401, left col, ¶¶ 3-4).
`
`6
`
`
`
`OBVIOUSNESS
`Claims 21-33 and 40 Are Not Obvious Over Mozgrin
`and Fortov
`Mozgrin and Fortov would not have
`taught:
`““ionizing a feed gas to generate a
`weakly-ionized plasma proximate to a
`cathode assembly that comprises a
`sputtering target,” as recited in
`independent claim 21, and as
`similarly recited in independent claim
`40
`
`7
`
`
`
`OBVIOUSNESS
`Claims 21-33 and 40 Are Not Obvious Over Mozgrin
`and Fortov
`Mozgrin does not teach generating a weakly
`ionized plasma from a feed gas:
`
`Mozgrin does not teach a feed gas, let alone
`ionizing a feed gas to generate a weakly-ionized
`plasma.
`
`Rather, Mozgrin discloses “… the discharge gap …
`was filled up with either neutral or pre-ionized
`gas.” (Mozgrin, p. 401, left col, ¶¶ 3-4).
`
`8
`
`
`
`OBVIOUSNESS
`Claim 28 Is Not Obvious Over Mozgrin and Fortov
`
`Mozgrin and Fortov would not have
`taught:
`“ionizing the feed gas comprises
`exposing the feed gas to one of a static
`electric field, an AC electric field, a
`quasi-static electric field, a pulsed
`electric field, UV radiation, X-ray
`radiation, an electron beam, and an ion
`beam,” as recited in independent claim
`28
`
`9
`
`
`
`OBVIOUSNESS
`Claim 28 Is Not Obvious Over Mozgrin and Fortov
`
`Mozgrin does not teach generating a weakly
`ionized plasma from a feed gas:
`
`Mozgrin does not teach a feed gas, let alone
`ionizing the feed gas by exposing the feed gas to
`various types of electric fields or radiation.
`
`Rather, Mozgrin discloses “… the discharge gap …
`was filled up with either neutral or pre-ionized
`gas.” (Mozgrin, p. 401, left col, ¶¶ 3-4).
`
`10
`
`
`
`OBVIOUSNESS
`Claims 1-20 and 34-40 Are Not Obvious Over Mozgrin
`and Fortov
`Mozgrin and Fortov would not have taught:
`“an amplitude and a rise time of the voltage
`pulse being chosen to increase a density of
`ions in the strongly ionized plasma enough
`to generate sufficient thermal energy in the
`sputtering target to cause a sputtering yield
`to be non-linearly related to a temperature
`of the sputtering target,” as recited in
`independent claim 1 and as similarly recited
`in independent claims 21, 34, and 40.
`
`11
`
`
`
`OBVIOUSNESS
`Claims 1-40 Are Not Obvious Over Mozgrin and Fortov
`
` With respect to Mozgrin:
`
`“Mozgrin does not even mention any attempt to achieve a
`sputtering yield to be non-linearly related to a temperature
`of the sputtering target, let alone achieving this goal by
`choosing an amplitude or rise time of the applied voltage
`pulse.” (Dr. Hartsough’s Declaration, ¶ 90).
`Mozgrin does not mention a temperature of the target
`material during the pulse. (Dr. Hartsough’s Declaration, ¶ 90).
`
`Indeed, Mozgrin teaches that the voltage pulse was designed
`in an entirely different manner (i.e., to address ionization-
`overheating instability) than that required by the claims of
`the ‘773 patent.
`
`12
`
`
`
`OBVIOUSNESS
`Claims 1-40 Are Not Obvious Over Mozgrin and Fortov
`
`Mozgrin teaches that the voltage pulse was
`designed in an entirely different manner (i.e., to
`address ionization-overheating instability) than
`that required by the claims of the ‘773 patent:
`
`“we allowed for the fact that the development time
`for the ionization-overheating instability was about
`10^-3 – 3 x 10^-3 s in the pressure range up to 0.5 torr
`[9]. Thus, the supply unit was made proving square
`voltage and current pulses with [rise] times (leading
`edge) of 5 – 60 μs and durations of as much as 1.5 ms”
`(Mozgrin at 401, right col, ¶ 1).
`
`13
`
`
`
`OBVIOUSNESS
`Claims 1-40 Are Not Obvious Over Mozgrin and Fortov
`
` Fortov does not make any mention of how to generate
`sufficient target thermal energy to cause the sputtering
`yield to be non-linear with target temperature. (Dr.
`Hartsough’s Declaration, ¶¶ 91-92).
` Fortov does not teach the claim limitation at issue, which
`requires
`
`(i) choosing the amplitude and rise time of the voltage pulse
`to
`(ii) increase ion density in the strongly-ionized plasma to
`(iii) generate sufficient target thermal energy to
`(iv) cause the sputtering yield to be non-linear with target
`temperature.
`
`14
`
`
`
`OBVIOUSNESS
`Claim 10 Is Not Obvious Over Mozgrin and Fortov
`
`Mozgrin and Fortov would not have taught:
`“wherein the ionization source is chosen
`from the group comprising an electrode
`coupled to a DC power supply, an electrode
`coupled to an AC power supply, a UV source,
`an X-ray source, an electron beam source,
`an ion beam source, an inductively coupled
`plasma source, a capacitively coupled
`plasma source, and a microwave plasma
`source,” as recited by dependent claim 10.
`
`15
`
`
`
`OBVIOUSNESS
`Claim 10 Is Not Obvious Over Mozgrin and Fortov
`
`The Petitioners argued that Mozgrin
`teaches one and only one of the
`alternatives listed in the claim limitation
`quoted above:
`an electrode coupled to a DC power
`supply.
`“either the anode or cathode shown in
`Mozgrin’s FIG. 1 constitutes an
`‘electrode’ as recited in claim 10.”
`(Petition, p. 22).
`
`16
`
`
`
`OBVIOUSNESS
`Claim 10 Is Not Obvious Over Mozgrin and Fortov
`
` The Petitioners’ argument is not persuasive because:
`the claim term “an electrode” recited in claim 10 must be a component other than the
`cathode assembly or the anode that are recited in claim 1, from which claim 10
`depends.
`
`The Specification of the ’773 patent confirms this meaning by stating that the cathode
`assembly, the anode, and the electrode are three distinct components (’773 patent at
`20:14-22. ).
`
`the Petitioner’s expert, Mr. DeVito, explicitly stated that Mozgrin does not teach a
`third electrode in addition to the anode and the cathode:
`Q. Does the Mozgrin reference disclose a third electrode in its -- in the system?
`MR. MAIER: Object to form.
`A. A third electrode?
`Q. Uh-huh.
`A. I mean, I don't see a third electrode.
`Q. Have you offered an opinion in your declaration that the Mozgrin reference
`includes a third electrode, other than the anode and the cathode?
`A. No, I don't see one, no (DeVito Deposition (1/20/15), p. 205, ll. 6-16).
`
`17
`
`
`
`OBVIOUSNESS
`Claim 11 Is Not Obvious Over Mozgrin and Fortov
`
`Mozgrin and Fortov would not have taught:
`“a rise time of the voltage pulse is chosen to
`increase an ionization rate of the strongly-ionized
`plasma,” as recited in claim 11.
`Petitioners conflate an increase in the density of ions
`with an increase in the ionization rate
`Petitioners did not even attempt to show that the
`rate at which ions are created in Mozgrin increases.
`(Petition, p. 22).
`
`18
`
`
`
`OBVIOUSNESS
`Claim 11 Is Not Obvious Over Mozgrin and Fortov
`
`Petitioners’ expert, Mr. DeVito admitted that
`Mozgrin does not teach choosing a rise time of a
`voltage pulse to increase an ionization rate, as
`required by claim 11:
`Q. So Mozgrin nowhere says I choose a particular
`rise time of the pulsed voltage to increase the
`ionization rate of the strongly-ionized plasma, right?
`MR. MAIER: Object to form.
`A. He doesn't explicitly state it, no. (DeVito
`Deposition (1/20/15), p. 231, l. 25 – p. 232, l. 6.)
`
`19
`
`
`
`OBVIOUSNESS
`Claim 13 Is Not Obvious Over Mozgrin and Fortov
`
`Mozgrin and Fortov would not have taught that the:
`“strongly-ionized plasma is substantially uniform
`proximate to the cathode assembly,” as recited in
`claim 13.
`The portion of Mozgrin cited by the Petitioners
`merely compares the discharges in two different
`regions; it does not disclose any specific uniformity
`details about the strongly ionized plasma in either of
`the two regions.
`
`20
`
`
`
`OBVIOUSNESS
`Claim 13 Is Not Obvious Over Mozgrin and Fortov
`
`Mozgrin instead teaches that the strongly-ionized
`plasma is not substantially uniform near the cathode:
`the plasma in the high-current regime is depicted in
`Fig. 6(a)1 as “the discharge occupied either the ring
`area beyond the circular region of max Br or the disk
`area bounded by the circle of max Br; the area
`depended on the magnetic field configuration.”
`Fig. 6(a)1 shows a non-uniform discharge proximate
`to the cathode surface.
`
`21
`
`
`
`OBVIOUSNESS
`Claim 13 Is Not Obvious Over Mozgrin and Fortov
`
` Mozgrin instead teaches that the strongly-ionized plasma is not
`substantially uniform near the cathode:
`the other portion of Mozgrin cited by Petitioners is referring to a
`different region (i.e., region 3). Region 3 is depicted in Mozgrin as Fig.
`6(a)2 and described by Mozgrin as exhibiting no cathode sputtering.
`Indeed, Mozgrin explicitly states that region 3 is not a region exhibiting a
`strongly-ionized plasma because strongly-ionized plasma causes
`sputtering:
`“the positively charged ions in the strongly-ionized plasma accelerate at
`high velocity towards the sputtering target 220. The accelerated ions
`impact the surface of the sputtering target 220, causing the target
`material to be sputtered.”
`That is, the figures and text in Mozgrin related to region 3 cannot possibly
`teach that the “strongly-ionized plasma is substantially uniform
`proximate to the cathode assembly,” as required by claim 13 because
`Mozgrin teaches that there is no strongly ionized plasma in region 3.
`
`22
`
`
`
`OBVIOUSNESS
`Claim 14 Is Not Obvious Over Mozgrin and Fortov
`
`Mozgrin and Fortov would not have taught that the:
`“distance between the anode and the cathode
`assembly is chosen to increase an ionization rate of
`strongly-ionized plasma,” as recited in claim 14.
`Petitioners conflate an increase in the density of ions
`with an increase in the ionization rate.
`Petitioners did not even attempt to show that the
`rate at which ions are created in Mozgrin increases.
`(Petition, pp. 22 and 24).
`
`23
`
`
`
`OBVIOUSNESS
`Claim 14 Is Not Obvious Over Mozgrin and Fortov
`
` “Mozgrin makes no mention of how to achieve an
`increase in an ionization rate of the strongly ionized
`plasma, let alone teach how to achieve such an ionization
`rate increase by choosing a distance between the anode
`and the cathode.” (Dr. Hartsough’s Declaration, ¶ 113).
` Mozgrin discloses numerous experiments such as
`determining the effect of displacing the magnetic field on
`the plasma: “[t]o control the magnetic field strength at
`the cathode surface, we displaced the magnetic system
`along the axis z (Fig. 1).” (Mozgrin at 401, left col, ¶ 1.)
` Mozgrin, however, does not disclose any experiments
`whatsoever about determining the effect of varying the
`distance between an anode and a cathode assembly on
`the plasma.
`
`24
`
`
`
`OBVIOUSNESS
`Claim 18 Is Not Obvious Over Mozgrin and Fortov
`
` Mozgrin and Fortov would not have taught that the:
`“the ionization source and the power supply comprise a
`single power supply,” as recited in claim 18.
` Claim 18, when read in conjunction with claim 1, requires
`i) the ionization source that generates a weakly ionized
`plasma and ii) the power supply that generates a voltage
`pulse to create a strongly ionized plasma to comprise a
`single power supply.
` Mozgrin teaches no such single power supply:
`Mozgrin instead teaches two distinct power supplies: a
`pulsed discharge supply unit and a system for pre-
`ionization. (Mozgrin at 401, left col, ¶ 5.)
`
`25
`
`
`
`OBVIOUSNESS
`Claims 18 Is Not Obvious Over Mozgrin and Fortov
`
`26
`
`
`
`OBVIOUSNESS
`Claims 5 and 36 Are Not Obvious Over Mozgrin and
`Kawamata
` Mozgrin and Kawamata would not have taught that the:
`“the thermal energy generated in the sputtering target does not
`substantially increase an average temperature of the sputtering target,”
`as recited in claim 5, and as similarly recited in claim 36.
` Neither Mozgrin nor Kawamata mention that cooling is performed to the
`extent that the average temperature of the sputtering target does not
`increase. (See e.g., Exhibit 1005, Mozgrin, p. 401, left col, ¶ 1 and
`Kawamata, col. 7, ll. 36-40).
` Kawamata teaches the opposite to what is recited in claims 5 and 36 by
`stating that the temperature of the sputtering target is deliberately
`increased to weaken interatomic bonds:
`“[i]n the present invention, the temperature of the film source material
`as a target material is raised to thereby weaken interatomic bonds of the
`target prior to the collision of ions with the target. Therefore, most of
`the energy of the accelerated ions is used in the sputtering, so that
`sputtering yield is enhanced.” (Kawamata, col. 4, ll. 4-9).
`
`27
`
`
`
`OBVIOUSNESS
`Claims 3 and 35 Are Not Obvious Over Mozgrin and
`Lantsman
` Mozgrin and Lantsman would not have taught:
`“a gas flow controller that controls a flow of the feed gas
`so that the feed gas diffuses the strongly-ionized
`plasma,” as recited in claims 3 and 35.
` Mozgrin does not disclose a feed gas (i.e., a gas that
`flows into the chamber during the sputtering process):
`“ … the discharge gap … was filled up with either neutral
`or pre-ionized gas.” (Mozgrin, p. 401, left col, ¶ 4)
` “Lantsman does not provide any details as to the
`configuration of a gas supply in its apparatus. Lantsman
`is also silent with regard to controlling the flow of feed
`gas with a controller to diffuse strongly ionized-
`plasma.”(Dr. Hartsough’s Declaration, ¶ 181).
`
`28
`
`
`
`OBVIOUSNESS
`Claims 3 and 35 Are Not Obvious Over Mozgrin and
`Lantsman
` Neither the Petitioners nor their expert addresses the
`fact that Mozgrin discloses a static gas system, let alone
`explain why or how one of ordinary skill in the art would
`have changed Mozgrin’s system from a static gas system
`to a feed gas system. (Dr. Hartsough’s Declaration, ¶
`124).
` The Petitioners failed to provide experimental data or
`other objective evidence indicating that a skilled artisan
`would have been motivated to combine Lantsman’s feed
`gas in Mozgrin’s static gas system to achieve the claimed
`invention of the ‘773 patent and would have had a
`reasonable expectation of success of doing so.
`
`29
`
`
`
`OBVIOUSNESS
`Claims 4 and 34 Are Not Obvious Over Mozgrin and
`Lantsman
` Mozgrin and Lantsman would not have taught that the:
`“the feed gas allows additional power to be absorbed by the
`strongly ionized plasma, thereby generating additional
`thermal energy in the sputtering target,” as recited in claim 4
`and as similarly recited in claim 34.
` Mozgrin does not disclose a feed gas (i.e., a gas that flows into
`the chamber during the sputtering process):
`“ … the discharge gap … was filled up with either neutral or
`pre-ionized gas.” (Mozgrin, p. 401, left col, ¶ 4)
` “Lantsman does not teach how the flow of feed gas is
`controlled to allow additional power to be absorbed by the
`strongly ionized plasma or to generate additional thermal
`energy in the sputtering target.” (Dr. Hartsough’s Declaration,
`¶ 128).
`
`30
`
`
`
`OBVIOUSNESS
`Claim 25 Is Not Obvious Over Mozgrin and Lantsman
`
` Mozgrin and Lantsman would not have taught:
`“diffusing the strongly-ionized plasma with a volume of the
`feed gas while applying the voltage pulse to the cathode
`assembly to generate additional strongly-ionized plasma
`from the volume of the feed gas” as recited in claim 25.
` Mozgrin does not disclose a feed gas (i.e., a gas that flows into
`the chamber during the sputtering process):
`“ … the discharge gap … was filled up with either neutral or
`pre-ionized gas.” (Mozgrin, p. 401, left col, ¶ 4)
` “Lantsman does not provide any details as to the
`configuration of a gas supply in its apparatus. Lantsman is
`also silent with regard to controlling the flow of feed gas with
`a controller to diffuse strongly ionized-plasma.”(Dr.
`Hartsough’s Declaration, ¶ 181).
`
`31
`
`
`
`OBVIOUSNESS
`Claim 25 Is Not Obvious Over Mozgrin and Lantsman
`
` Lantsman does not teach applying a voltage pulse to
`anything:
`Lantsman instead discloses two DC power supplies.
`“Lantsman does not teach a strongly ionized plasma.”
`(Dr. Hartsough’s Declaration, ¶ 150).
`Indeed, the Petitioners’ expert, Mr. DeVito, agrees with
`Dr. Hartsough:
`Q. But he [Lantsman] doesn't use strongly-ionized
`plasma, right?
`A. He doesn't call it strongly-ionized, correct (DeVito
`Deposition (1/20/15), p. 268, l. 25 – p. 269, l. 4.)
`
`32
`
`
`
`OBVIOUSNESS
`Claim 25 Is Not Obvious Over Mozgrin and Lantsman
`
`The Petitioners failed to explain how it would have
`been obvious to modify Mozgrin to
`i) diffuse strongly ionized plasma with a feed gas
`ii) while applying a voltage pulse from the
`combination of Mozgrin and Lantsman
`given that Mozgrin does not even mention a feed
`gas and Lantsman does not disclose a strongly
`ionized plasma or a pulse of any kind (e.g., a voltage,
`power, or current pulse).
`
`33
`
`
`
`OBVIOUSNESS
`Claim 24 Is Not Obvious Over Mozgrin and Lantsman
`
` Mozgrin and Lantsman would not have taught:
`“diffusing the weakly-ionized plasma with a volume of the
`feed gas while ionizing the volume of the feed gas to create
`additional weakly-ionized plasma,” as recited in claim 24.
` Mozgrin does not disclose a feed gas (i.e., a gas that flows into
`the chamber during the sputtering process):
`“ … the discharge gap … was filled up with either neutral or
`pre-ionized gas.” (Mozgrin, p. 401, left col, ¶ 4)
` “Lantsman does not provide any details as to the
`configuration of a gas supply in its apparatus. Lantsman is
`also silent with regard to controlling the flow of feed gas with
`a controller to diffuse strongly ionized-plasma.”(Dr.
`Hartsough’s Declaration, ¶ 181).
`
`34
`
`
`
`OBVIOUSNESS
`Claim 23 Is Not Obvious Over Mozgrin and Kudryavtsev
`
` Mozgrin and Kudryavtsev would not have taught that:
`“the voltage pulse applied to the cathode assembly generates
`excited atoms in the weakly-ionized plasma and generates
`secondary electrons from the sputtering target, the secondary
`electrons ionizing the excited atoms, thereby creating the strongly-
`ionized plasma,” as recited in claim 23.
` Mozgrin states that sputtering (e.g., the impacting of ions to the
`target) does not occur in the region relied upon by the Petitioners
`(i.e., region 3):
`“the parameters of the shaped-electrode discharge transit to
`regime [region] 3, as well as the condition of its transit to arc
`regime [region] 4, could be well determined for every given set of
`the discharge parameters. … Chemical analysis of the collector
`surface layer was done; the cathode material was not detected
`there. Hence, there was no cathode sputtering in these regimes
`[regions].” Mozgrin at 404, left col, ¶ 4-5 (emphasis added).
`
`35
`
`
`
`OBVIOUSNESS
`Claim 23 Is Not Obvious Over Mozgrin and Kudryavtsev
`
` “[w]ithout sputtering in these regions of Mozgrin, the
`secondary electrons from the target cannot possibly be
`generated and therefore, the high density plasma could not
`have possibly been generated by secondary electrons ionizing
`the excited atoms.” (Dr. Hartsough’s Declaration, ¶ 155).
` “Kudryavtsev’s apparatus is not a sputtering apparatus and
`therefore, does not teach secondary electrons [from the
`target] generating the strongly ionized plasma. Accordingly,
`combining the teachings of Kudryatsev with Mozgrin cannot
`possibly overcome Mozgrin’s failure to teach that its high
`density plasma is generated from secondary electrons ionizing
`the excited atoms.” (Dr. Hartsough’s Declaration, ¶ 155).
`
`36
`
`
`
`OBVIOUSNESS
`Claim 29 Is Not Obvious Over Mozgrin and Fortov
`
`Mozgrin and Fortov would not have taught that:
`“the ions in the strongly-ionized plasma cause at
`least a portion of a surface layer of the sputtering
`target to evaporate,” as recited in claim 29.
`The Petitioners’ own expert explicitly admitted that
`Mozgrin does not teach that evaporation occurs
`during sputtering:
`Q. Is it your opinion that Mozgrin teaches
`simultaneous sputtering and evaporation?
`A. Well, Mozgrin doesn't teach it, per se. (DeVito
`Deposition (1/20/15), p. 63. l. 27 – p. 64, l. 3.)
`
`37
`
`
`
`OBVIOUSNESS
`Claim 29 Is Not Obvious Over Mozgrin and Fortov
`
` Petitioners argued that Fortov teaches that sputtering is a
`form of evaporation solely because Fortov states that “[i]n the
`model of thermal evaporation the sputtering is reviewed as
`evaporation.”
` But this statement from Fortov merely indicates that
`sputtering was reviewed as evaporation in a particular model
`of thermal evaporation; it does not indicate that sputtering is
`a form of evaporation or that evaporation occurs during
`sputtering, as alleged by the Petitioner.
` Petitioners’ expert, Mr. DeVito, testified that evaporation
`need not necessarily occur during sputtering:
`Q. So you can sputter without evaporation, right?
`A. Yes, you can. (DeVito Deposition (1/20/15), p. 60. l. 24 –
`p. 61, l. 3).
`
`38
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2014-00580 and 726
`Patent 6,896,773
`
`END
`
`39