Trial No. IPR2014-00604
`Docket No. 0110198-00193 US2
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`Filed on behalf of The Gillette Company
`By: David L. Cavanaugh, Reg. No. 36,476 (Lead Counsel)
`Yung-Hoon Ha, Reg. No. 56,368 (Back-up Counsel)
`Wilmer Cutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Avenue NW
`Washington, DC 20006
`Tel: (202) 663-6025
`Email: David.Cavanaugh@wilmerhale.com
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________________________________
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`THE GILLETTE COMPANY
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`Petitioner
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`v.
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`ZOND, LLC
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`Patent Owner of
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`U.S. Patent No. 6,896,775
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`IPR Trial No. IPR2014-00604
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`PETITIONER’S REPLY
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`Claims 30-37
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`Trial No. IPR2014-00604
`Docket No. 0110198-00193 US2
`TABLE OF CONTENTS
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`I. 
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`INTRODUCTION ........................................................................................ 1 
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`II. 
`ZOND CONCEDES THAT INDEPENDENT CLAIMS 30, 36 AND 37
`ARE TAUGHT BY THE PRIOR ART ................................................................. 2 
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`III.  ONE SKILLED IN THE ART WOULD HAVE BEEN ABLE TO
`COMBINE THE CITED REFERENCES WITH PREDICTABLE
`RESULTS .................................................................................................................. 8 
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`IV.  DEPENDENT CLAIMS ARE ALSO OBVIOUS .................................... 11 
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`Dependent Claim 33 ................................................................... 11 
`A. 
`CONCLUSION ............................................................................................ 13 
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`V. 
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`CASES
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`Trial No. IPR2014-00604
`Docket No. 0110198-00193 US2
`TABLE OF AUTHORITIES
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`Page(s)
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`In re Mouttet, 686 F.3d 1322, 1332 (Fed. Cir. 2012)………………………….....10
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`KSR, 550 US at 420-21…………………………………………………...….10
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`I.
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`INTRODUCTION
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`In its Decision on Institution (“DI”), the Board recognized there is a
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`reasonable likelihood that the challenged claims 30-37 should be cancelled. See
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`IPR2014-604 DI at p. 22. None of the arguments raised by Zond provides any
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`reasonto alter the determination of the Board in the Decision on Institution.
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`First, Zond attempts to require a particular ordering of the method claims in a
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`manner which is not consistent with the patent specification, and which is refuted by
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`Zond’s own expert, Dr. Hartsough.
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`Second, Zond attempts to import the structural feature of a “gap” in the claim
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`limiation “means for ionizing.” However, the cross examination of Dr. Hartsough
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`reveals the “gap” is indeed taught by the prior art.
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`Third, Zond argues that one dependent claim (i.e., claim 33) adds patentable
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`subject matter. However, Dr. Hartsough’s cross examination testimony demonstrates
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`that Zond’s arguments are wrong.
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`The Petition, supported by Mr. DeVito’s declaration, demonstrates why one of
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`ordinary skill in the art would have combined the teachings of the cited references.
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`The cross examination testimony of Dr.Hartsough further demonstrates that the
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`references would have been combined. Petitioner also provides the declaration of
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`Dr. John Bravman, who reached the same conclusion that references would have
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`been combined by one of ordinary skill in the art and that the challenged claims are
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`1
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`unpatentable. 1
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`Trial No. IPR2014-00604
`Docket No. 0110198-00193 US2
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`II.
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`ZOND CONCEDES THAT INDEPENDENT CLAIMS 30, 36 AND 37
`ARE TAUGHT BY THE PRIOR ART
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`Zond’s own declarant, Dr. Larry Hartsough, explicitly conceded that just about
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`all the limitations recited in the independent claims were well known before the
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`effective date of the ‘775 patent. See Ex. 1119 (“’775 Hartsough Depo.”) at 42:4 – 45:
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`18.
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`Zond nevertheless argues that method claim 30 requires a specific order, and
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`that the cited references do not suggest “a means for ionizing.” Both of these
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`arguments are refuted by the cross examination testimony of Dr. Hartsough.
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`Claim 30 does not require a specific order
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`Zond asserts that method claim 30 requires the step of “ionizing a feed gas…”
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`to occur before “generating a magnetic field…”2 IPR2014-604 PO Resp. at pp. 34-
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`37. However, Dr. Hartsough unequivocally concedes that this is not the case, as
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`reproduced below:
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`Q: In Claim 15 of the ‘775 patent, the step of ionizing a feed gas
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`does not have to occur before the generation of a magnetic field; right?
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`1 Mr. DeVito is no longer available to provide testimony.
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`2 Zond argues that “Mr. DeVito’s comments concerning claim 15 apply equally to
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`claim 30.” IPR2014-604, PO Resp. at p. 36.
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`2
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`A: Correct.
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`Q: Because, as we said, Figure 2 has a permanent magnet, so the
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`magnetic field will already be on; right?
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`A: In that embodiment, yeah.
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`Q: And that’s an embodiment of Claim 15; right?
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`A: Yes.
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`’775 Hartsough Depo. at 87:6-18.
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`The flowcharts in Figures 12A and
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`13A of the ‘775 patent, partially
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`reproduced on the right, similarly show the
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`step of generating magnetic field 614 to
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`occur before the step of ionizing the feed
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`gas to generate weakly-ionized plamsa 618. Ex. 1101 (“’775 Patent”) at Figs.
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`12A and 13A. See also Ex. 1120 (“Bravman Dec.”) at ¶¶ 97-100. Accordingly,
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`the independent claims do not require a particular order as argued by Zond.
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`Wang teaches “a means for ionizing”
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`Zond argues that the “Board’s preliminary construction … failed to account
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`for this gap … [which] is an important consideration of the cathode-anode
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`arrangement.” IPR2014-604 at p.39. Zond now requests the Board to construe this
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`limitation to explicitly include the recitation of a “gap.”
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`3
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`Dr. Hartsough was
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`asked to clarify what
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`constitutes a “gap” during his
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`deposition. As shown on the
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`right, he marked on Figure 7
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`of the ‘775 patent (Exhibit
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`1121, marked as Exhibit 1028
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`during Dr. Hartsough’s ‘775
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`patent deposition) the
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`locations between the anode
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`and cathode that form “a
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`gap.” ’775 Hartsough Depo.
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`at 18:9 – 21:3. The diagonal lines (annotated in dotted purple lines) between the
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`anode 238 and cathode 216 meet the requirements of a “gap,” according to Dr.
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`Hartsough.
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`Dr. Hartsough further noted that the claims do not require any particular
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`distance between the anode and the cathode in order to meet the alleged “gap”
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`requirement. Ex. 1119 at 64:8-16 (“Now, the claims – do the claims of the ‘775
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`patent require a certain gap size? A: They give a range. Q: Not the claims. A: not – oh,
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`the claims, no. Q: But you’re right, the ‘775 patent does give a range; right? A: The
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`
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`claims don’t – don’t require a gap size.”).
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`Even if the “means for ionizing” includes a “gap,” and even if that “gap” is
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`defined as Dr. Hartsough defines it, Wang clearly teaches just such a “gap.” Bravman
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`Dec. at ¶¶ 87-91. As shown in
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`annotated Figure 1 of Wang at right,
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`high density plasma 42 is positioned
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`between anode 24 (colored orange)
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`and cathode 14 (colored green).
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`One exemplary “gap” is shown
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`using the purple diagonal dotted
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`line below. Bravman Dec. at ¶ 92.
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`In addition to requesting the
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`Board to include the “gap” in the
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`“means for ionizing,” Zond appears
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`to further require that the “gap” is
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`arranged such that the cathode is
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`“adjacent” to an anode. For
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`example, Zond argues that “[t]he inclusion of the floating shield precludes the
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`cathode from being positioned ‘adjacent to the anode’ across the gap.” IPR2014-604
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`PO Resp. at p. 41 (emphasis added). This argument is based on Dr. Hartsough’s
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`
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`interpretation of the term “adjacent” to mean “next to and with nothing in between.”
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`Ex. 2006 (Hartsough Dec.) at p. 48.
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`However, Dr. Hartsough testimony demonstrates otherwise. A slightly
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`modified Figure 3 from Dr. Hartsough’s declaration (Ex. 2006) was presented to him
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`during his deposition as Exhibit 1029 (reproduced below and included as Exhibit
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`1122 in this proceeding). As shown below, an electrode (colored red) was introduced
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`only partially between an anode and a cathode, and Dr. Hartsough was asked whether
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`the anode and cathode still meet his view of the meaning of “adjacent.” Dr.
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`Hartsough conceded that, in this configuration, some portions of the anode and
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`cathode (i.e., portions bounding the region colored purple) are adjacent to one
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`another in the context of the ‘775 patent claims. See ’775 Hartsough Depo. at 74:7-
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`76:8 (“Q: Is the anode and cathode depicted in Exhibit 1029 adjacent to one another?
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`… A: In that depiction, there are portions that are adjacent.”).
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`6
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`Wang similarly has portions of anode and cathode that are “adjacent” within
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`the context of the ‘775 patent claims, despite the presence of a floating shield. As
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`shown above in annotated Figure 1 of Wang, there are portions of the anode 24
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`(colored orange) and cathode 14 (colored green), which do not intersect the floating
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`shield 26 (colored red). One exemplary such “adjacent” region is shown using the
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`purple diagonal dotted line above.
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`Accordingly, even under Zond’s construction and argument, Wang teaches the
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`claimed “means for ionizing,” including the “gap” that Zond asserts must be part of
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`it. Bravman Dec. at ¶¶ 93-96.
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`7
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`III. ONE SKILLED IN THE ART WOULD HAVE BEEN ABLE TO
`COMBINE THE CITED REFERENCES WITH PREDICTABLE
`RESULTS
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`
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`Dr. Hartsough concedes that it was well known to a person skilled in the art
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`that it was desirable to increase the sputter etching rate. See ‘775 Hartsough Depo. at
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`49:20-24 (“Q: So in – in general, it’s desirable, and the person of ordinary skill would
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`be motivated, to increase the sputter etching rate; right? … A: Yes.”). See also
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`Bravman Dec. at ¶ 68.
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`He also agrees it was well-known that one could achieve such increased etching
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`rate by increasing the ionization rate. See ‘775 Hartsough Depo. at 50:2-12 (“Q: What
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`are the ways in which a person of ordinary skill would have known how to increase
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`the etch rate? A: I’m not sure I could recite all of them. … Q: It could increase the
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`ionization rate? A: It could increase the – the flux of ions that would be – you know,
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`that would bombard the substrate.”). See also Bravman Dec.at ¶ 69.
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`Moreover, it is undisputed that it was also well known that high density plasma
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`is desirable because it results in a high etch rate. See IPR2014-578, Petition at p. 53
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`(“As taught in Mozgrin, high plasma density is desirable because it results in a high
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`etch rate.”); Ex. 1102 (“Mozgrin”) at 409, left col, ¶5 (“The high-current diffuse
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`discharge (regime 3) is useful…. Hence, it can enhance the efficiency of ionic etching
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`in microelectronics and provide a means for controlled pulsed etching of layers.”). See
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`also Bravman Dec.at ¶ 70.
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`Wang, Mozgrin and Kudryavtsev are all directed to generating a high plasma
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`density with the application of a pulse. Bravman Dec. at ¶ 71. Wang teaches “[a]
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`magnetron sputter reactor having a target that is pulsed…whereby a very high plasma
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`density is produced.” Ex. 1108 (“Wang”) at Abstract. Mozgrin teaches “[b]ecause of
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`the need for greater discharge power and plasma density, pulse or quasi-stationary
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`regimes appear to be of interest.” Mozgrin at p. 400, left col, ¶3. Kudryavtsev
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`teaches an explosive growth in the plasma density. Ex. 1103 (“Kudryavtsev”) at
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`Abstract (“[I]n a pulsed inert-gas discharge plasma at moderate pressures … [i]t is
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`shown that the electron density increases explosively in time due to accumulation of
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`atoms in the lowest excited states.”). Accordingly, as previously noted in the Petition,
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`all of these cited references are directed to the common goal of increasing plasma
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`density using pulsed systems, and one skilled in the art would have been motivated to
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`combine them. Bravman Dec. at ¶ 71.
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`Zond contends that Wang, Mozgrin and Kudryavtsev cannot be combined,
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`relying on essentially the same arguments that the Board previously considered and
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`found as unpersuasive in instituting these proceedings. IPR2014-604 DI at pp. 19-22.
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`Zond continues to argue that combining Wang with Kudryavtsev would not have
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`yielded predictable results because of the differences in reactor geometry/electrode
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`spacing, power supply design, magnetic field and pressure conditions. IPR2014-604
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`PO Resp. at pp. 29-34.
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`However, as the Board already articulated, (IPR2014-604 DI at p. 20), “[i]t is
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`well-established that a determination of obviousness based on teachings from multiple
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`references does not require an actual, physical substitution of elements.” In re Mouttet,
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`686 F.3d 1322, 1332 (Fed. Cir. 2012). Moreover, a person of ordinary skill is “a
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`person of ordinary creativity, not an automaton,” and “in many cases . . . will be able
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`to fit the teachings of multiple patents together like pieces of a puzzle.” KSR, 550 US
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`at 420-21.
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`In fact, as the Board already recognized, DI at p. 18, Mozgrin demonstrated
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`that the teachings of Kudryavtsev can be successfully applied in a completely different
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`system that added a magnetron, and used different reactor geometry/electrode
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`spacing, power supplies and pressure conditions. One skilled in the art would have
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`been able to combine Wang, Kudryavtsev and Mozgrin in a similar fashion. Bravman
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`Dec. at ¶¶ 71-77.
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`Zond also argues that one skilled in the art would not have been able to
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`combine Lantsman with Wang and Mozgrin because “[s]ystems that use a pulsed
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`discharge supply unit, like those of Wang and Mozgrin, would operate very differently
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`if modified to use two DC power supplies as taught by Lantsman.” IPR2014-604, PO
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`Resp. at p. 32. This is incorrect.
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`Both Mozgrin and Wang incorporated a constant DC power supply with a
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`pulsed DC supply. Mozgrin states: “Figure 2 presents a simplified scheme of the
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`discharge supply system. The supply unit involved a pulsed discharge supply unit and
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`
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`a system for pre-ionization.” Mozgrin at p. 401, left col, ¶ 4. Wang also shows, in
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`Figure 7, a “DC power supply 100” and a “pulsed DC power supply 80.” Wang at
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`7:56-63. See also Bravman Dec. at ¶ 79.
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`In fact, Dr. Hartsough conceded that a person of ordinary skill in the art
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`would have been able to combine a constant DC supply with a pulsed DC supply.
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`‘775 Hartsough Depo. at 152:9-18 (“So it’s not your position that a person of ordinary
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`skill would not be able to combine a constant DC supply with a pulsed DC supply;
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`right? … A:… It wouldn’t be – it – it wouldn’t be beyond the skill of a person of – of
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`ordinary skill in the art.”). See also Bravman Dec. at ¶ 80.
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`IV. DEPENDENT CLAIMS ARE ALSO OBVIOUS
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`Zond is silent regarding dependent claims 31, 32, 34 and 35, thereby conceding
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`these dependent claims do not add any additional patentable subject matter. Zond
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`asserts that dependent claim 33 adds patentable subject matter. As explained below, it
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`does not.
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`A. Dependent Claim 33
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`Zond asserts that Wang’s high density plasma region would be non-uniform
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`due to the presence of an unbalanced magnetic field. IPR2014-604 PO Resp. at pp.
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`44-46. However, this argument merely represents the state of plasma at a single
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`instant in time, and fails to take into account the uniformity of the plasma near the
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`
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`cathode/target over time. Bravman Dec. ¶ 114.
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`There is nothing in the claim that requires the uniformity to occur at only a
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`single instant in time. Rather, as Dr. Hartsough concedes, the magnet in Wang rotates
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`about a central axis. Hence, the location of the high-density plasma region 42 also
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`rotates over time. ‘775 Hartsough Depo. at 128:14-22. As Dr. Hartsough further
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`concedes, this is carried out to cause a more uniform erosion of the target over time.
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`‘775 Hartsough Depo. at 129:23-130:10; see also Wang at 1:64-66. This is schematically
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`illustrated in the figure below showing that the plasma (red) follows the rotation of
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`the magnet (green). Averaged over time (bottom of figure), the plasma (red) will be
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`uniform near the cathode surface. Bravman Dec. at ¶¶ 115-117.
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`With the generation of a uniform plasma near the cathode surface over time,
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`Dr. Hartsough further concedes that Wang teaches the formation of a uniform
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`plasma near the wafer 20 over time as well. ‘775 Hartsough Depo. at 130:11-20 (“Q:
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`So Wang does teach over time the formation of a uniform plasma of the wafer 20;
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`right? … A: And that would occur over many, many pulses of the – of the power. Q:
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`But it would occur; right? … A: It would occur.”). See also Bravman Dec. at ¶ 118.
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`Accordingly, over time, Wang teaches “selecting at least one of a pulse amplitude and
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`a pulse width of the electrical pulse that causes the strongly-ionized plasma to be
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`substantially uniform in an area adjacent to the surface of the substrate,” as required
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`by 33. Bravman Dec. at ¶ 119.
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`V. CONCLUSION
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`Board correctly found that there was a reasonable likelihood that the claims
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`should be cancelled based on the Petition and the supporting declaration. None of
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`the arguments raised by Zond provides any reason to alter the determination of the
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`Board in the Decision on Institution. Based on the foregoing, Petitioners have
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`demonstrated beyond a preponderance of the evidence that the claims are
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`unpatentable and request cancellation of the the challenged claims 30-37.
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`Trial No. IPR2014-00604
`Docket No. 0110198-00193 US2
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`Respectfully submitted,
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`Petitioner
`By: /David L. Cavanaugh/
`David L. Cavanaugh
`Registration No. 36,476
`Wilmer Cutler Pickering
`Hale and Dorr, L.L.P.
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`Customer Number:
`Tel: (202) 663-6025
`Fax: (202) 663-6363
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`Trial No. IPR2014-00604
`Docket No. 0110198-00193 US2
`CERTIFICATE OF SERVICE
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`I hereby certify that, on March 27, 2015, I caused a true and correct copy of the
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`foregoing materials:
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` Petitioner’s Reply
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` Exhibits 1119-1122
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` Exhibit Appendix
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`to be served via email, as previously agreed between the parties, on the following
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`counsel of record for Patent Owner:
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`Date of service March 27, 2015
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`Manner of service
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`Persons Served
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`
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`Email: tarek.fahmi@ascendalaw.com;
`gonsalves@gonsalveslawfirm.com;
`bbarker@chsblaw.com
`
`Tarek Fahmi
`84 W. Santa Clara St. Suite 550
`San Jose, CA 95113
`
`Gregory J. Gonsalves
`2216 Beacon Lane
`Falls Church, Virginia 22043
`
`
`
`
`/Yung-Hoon Ha/
`Yung-Hoon Ha
`Registration No. 56,368
`7 World Trade Center
`250 Greenwich Street
`New York, NY10007
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`15
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`Trial No. IPR2014-00604
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`EXHIBIT APPENDIX
`
`Description
`Chistyakov, U.S. Patent No. 6,896,775
`D.V. Mozgrin, et al, High-Current Low-Pressure Quasi-
`Stationary Discharge in a Magnetic Field: Experimental
`Research, Plasma Physics Reports, Vol. 21, No. 5, 1995
`A. A. Kudryavtsev, et al, Ionization relaxation in a plasma
`produced by a pulsed inert-gas discharge, Sov. Phys. Tech. Phys.
`28(1), January 1983
`Lantsman, U.S. Pat. No. 6,190,512
`Certified translation of D.V. Mozgrin, High-Current Low-
`Pressure Quasi-Stationary Discharge in a Magnetic Field:
`Experimental Research, Thesis at Moscow Engineering Physics
`Institute, 1994 (“Mozgrin Thesis”)
`Mozgrin Thesis (Original Russian)
`Catalogue Entry at the Russian State Library for the Mozgrin
`Thesis
`Wang, U.S. Pat. No. 6,413,382
`Gopalraja, U.S. Pat. No. 6,277,249
`Bobbio, U.S. Pat. No. 5,045,166
`Declaration of Richard DeVito
`Thornton, J. and Hoffman, D.W. Stress related effects in thin
`films, Thin Sold Films, 171, 1989, 5-31.
`
`N. Savvides and B. Window, Unbalanced magnetron ion‐
`
`assisted deposition and property modification of thin films, J.
`Vac. Sci. Technol. A 4(3), 504-508, 1986
`Grove, T.C., Arcing problems encountered during sputter
`deposition of aluminum, White Papers, ed: Advanced Energy,
`2000
`Sellers, J., Asymmetric bipolar pulsed DC: the enabling
`technology for reactive PVD, Surface & Coatings Technology,
`vol. 98, issue 1-3, January, 1998.
`Rossnagel, S. M., & Hopwood, J., Magnetron sputter deposition
`with high levels of metal ionization. Applied Physics Letters,
`63(24), 3285-3287, 1993.
`Declaration of Mark Matuschak in support of Unopposed
`Motion for Admission Pro Hac Vice
`Declaration of Cosmin Maier in support of Unopposed Motion
`1
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`Exhibit
`Gillette 1101
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`Gillette 1102
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`Gillette 1103
`Gillette 1104
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`Gillette 1105
`Gillette 1106
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`Gillette 1107
`Gillette 1108
`Gillette 1109
`Gillette 1110
`Gillette 1111
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`Gillette 1112
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`Gillette 1113
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`Gillette 1114
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`Gillette 1115
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`Gillette 1116
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`Gillette 1117
`Gillette 1118
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`Trial No. IPR2014-00604
`Docket No. 0110198-00193 US2
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`Description
`for Admission Pro Hac Vice
`Deposition Transcript of Larry D. Hartsough Ph.D. for U.S.
`Patent No. 6,896,775 (February 19, 2015)
`Declaration of John C. Bravman
`Figure 7 of the ‘775 Patent with handwriting by Larry
`Hartsough, Ph.D. identifying “Gap”
`Annotated Figure 3 from Larry Hartsough, Ph.D.’s Declaration
`
`Exhibit
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`Gillette 1119
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`Gillette 1120
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`Gillette 1121
`Gillette 1122
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`2