Exhibit 2005
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`Exhibit 2005
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`Exhibit 2005
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`
` THE GILLETTE COMPANY, TAIWAN SEMICONDUCTOR
`MANUFACTURING COMPANY, LTD., TSMC NORTH AMERICA
`CORP., FUJITSU SEMICONDUCTOR LIMITED, and FUJITSU
`SEMICONDUCTOR AMERICA, INC.,
`Petitioners
`
`v.
`
`ZOND, LLC
`Patent Owner
`
`U.S. Patent No. 6,896,773 B2
`
`_____________________
`
`Inter Partes Review Case Nos. IPR2014-00580, 01479,
`00726, 01481
`
`_____________________
`
`DECLARATION OF LARRY D. HARTSOUGH, Ph.D.
`
`
`
`
`
`
`I, Larry Hartsough, Ph.D., hereby declare:
`
`
`
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`1. I am making this declaration at the request of patent owner Zond, LLC, in the
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`matter of the Inter Partes Reviews (IPRs) of U.S. Patent No. 6,896,773 (the “’773
`
`Patent”), as set forth in the above caption.
`
`2. I am being compensated for my work in this matter at the rate of $300 per
`
`hour. My compensation in no way depends on the outcome of this proceeding.
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`3. The list of materials I considered in forming the opinions set forth in this
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`declaration includes the ’773 patent, the file history of the ’773 patent, the Petitions
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`for Inter Partes Review and the exhibits, the PTAB’s Institution Decisions, the
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`transcript of the deposition of the Petitioners’ expert on the ‘773 patent, and the
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`prior art references discussed below.
`
`I. Education and Professional Background
`
`4. My formal education is as follows. I received a Bachelors of Science degree
`
`in 1965, Master of Science degree in 1967, and Ph.D. in 1971, all in Materials
`
`Science/Engineering from the University of California, Berkeley.
`
`5.
`
`I have worked in the semiconductor industry for approximately 30
`
`years. My experience includes thin film deposition, vacuum system design, and
`
`plasma processing of materials. I made significant contributions to the
`
`development of magnetron sputtering hardware and processes for the metallization
`
`
`
`2
`
`
`
`of silicon integrated circuits. Since the late 1980’s, I have also been instrumental
`
`in the development of standards for semiconductor fabrication equipment
`
`published by the SEMI trade organization.
`
`6.
`
`From 1971-1974, I was a research metallurgist in the thin film
`
`development lab of Optical Coating Laboratory, Inc. In 1975 and 1976, I
`
`developed and demonstrated thin film applications and hardware for an in-line
`
`system at Airco Temescal. During my tenure (1977-1981) at Perkin Elmer, Plasma
`
`Products Division, I served in a number of capacities from Senior Staff Scientist, to
`
`Manager of the Advanced Development activity, to Manager of the Applications
`
`Laboratory. In 1981, I co-founded a semiconductor equipment company, Gryphon
`
`Products, and was VP of Engineering during development of the product. From
`
`1984-1988, I was the Advanced Development Manager for Gryphon, developing
`
`new hardware and process capabilities. During 1988-1990, I was Project Manager
`
`at General Signal Thinfilm on a project to develop and prototype an advanced
`
`cluster tool for making thin films. From 1991-2002, I was Manager of PVD
`
`(physical vapor deposition) Source Engineering for Varian Associates, Thin Film
`
`Systems, and then for Novellus Systems, after they purchased TFS. Since then, I
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`have been consulting full time doing business as UA Associates, where my
`
`consulting work includes product development projects, film failure analysis,
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`project management, technical presentations and litigation support.
`
`
`
`3
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`
`
`7.
`
`Throughout my career, I have developed and/or demonstrated
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`processes and equipment for making thin films, including Al, Ti-W, Ta, and Cu
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`metallization of silicon wafers, RF sputtering and etching, and both RF and dc
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`magnetron reactive sputtering, for example SiO2, Al2O3, ITO (Indium-Tin Oxide),
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`TiN, and TaN. I have been in charge of the development of two sputter deposition
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`systems from conception to prototype and release to manufacturing. I have also
`
`specialized in the development and improvement of magnetically enhanced sputter
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`cathodes. I have experience with related technology areas, such as wafer heating,
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`power supply evaluation, wafer cooling, ion beam sources, wafer handling by
`
`electrostatics, process pressure control, in-situ wafer/process monitoring, cryogenic
`
`pumping, getter pumping, sputter target development, and physical, electrical and
`
`optical properties of thin films.
`
`8.
`
`I am a member of a number of professional organizations including
`
`the American Vacuum Society, Sigma Xi (the Scientific Research Society), and as
`
`a referee for the Journal of Vacuum Science & Technology. I have been a leader
`
`in the development of SEMI Standards for cluster tools and 300mm equipment,
`
`including holding various co-chair positions on various standards task forces. I
`
`have previously served as a member of the US Department of Commerce’s
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`Semiconductor Technical Advisory Committee.
`
`9.
`
`I have co-authored many papers, reports, and presentations relating to
`
`
`
`4
`
`
`
`semiconductor processing, equipment, and materials, including the following:
`
`a. P. S. McLeod and L. D. Hartsough, "High-Rate Sputtering of Aluminum
`for Metalization of Integrated Circuits", J. Vac. Sci. Technol., 14 263
`(1977).
`b. D. R. Denison and L. D. Hartsough, "Copper Distribution in Sputtered
`Al/Cu Films", J. Vac. Sci. Technol., 17 1326 (1980).
`c. D. R. Denison and L. D. Hartsough, "Step Coverage in Multiple Pass
`Sputter Deposition" J. Vac. Sci. Technol., A3 686 (1985).
`d. G. C. D’Couto, G. Tkach, K. A. Ashtiani, L. Hartsough, E. Kim, R.
`Mulpuri, D. B. Lee, K. Levy, and M. Fissel; S. Choi, S.-M. Choi, H.-D.
`Lee, and H. –K. Kang, “In situ physical vapor deposition of ionized Ti
`and TiN thin films using hollow cathode magnetron plasma source” J.
`Vac. Sci. Technol. B 19(1) 244 (2001).
`
`My areas of expertise include sputter deposition hardware and processes,
`
`thin film deposition system design and thin film properties. I am a named inventor
`
`on twelve United States patents covering apparatus, methods or processes in the
`
`fields of thin film deposition and etching. A copy of my CV is attached as
`
`Attachment A.
`
`
`
`II. Summary of Opinions
`
`10.
`
`It is my opinion that none of the claims of the ‘773 patent are obvious.
`
`III. Legal Standards
`
`11. In this section I describe my understanding of certain legal standards. I have
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`been informed of these legal standards by Zond’s attorneys. I am not an attorney
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`and I am relying only on instructions from Zond’s attorneys for these legal
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`5
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`
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`standards.
`
`A. Level of Ordinary Skill in the Art
`
`12. In my opinion, given the disclosure of the ’773 Patent and the disclosure of
`
`the prior art references considered here, I consider a person of ordinary skill in the
`
`art at the time of filing of the ‘773 Patent to be someone who holds at least a
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`bachelor of science degree in physics, material science, or electrical/computer
`
`engineering with at least two years of work experience or equivalent in the field of
`
`development of` plasma-based processing equipment. I met or exceeded the
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`requirements for one of ordinary skill in the art at the time of the invention and
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`continue to meet and/or exceed those requirements.
`
`B.
`
`Legal Standards for Anticipation
`
`13. I understand that a claim is anticipated under 35 U.S.C. § 102 if (i) each and
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`every element and limitation of the claim at issue is found either expressly or
`
`inherently in a single prior art reference, and (ii) the elements and limitations are
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`arranged in the prior art reference in the same way as recited in the claims at issue.
`
`C. Legal Standards for Obviousness
`
`14. I understand that obviousness must be analyzed from the perspective of a
`
`person of ordinary skill in the relevant art at the time the invention was made. In
`
`analyzing obviousness, I understand that it is important to understand the scope of
`
`the claims, the level of skill in the relevant art, and the scope and content of the
`
`
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`6
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`
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`prior art, the differences between the prior art and the claims.
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`15.
`
` I understand that even if a patent is not anticipated, it is still invalid if
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`the differences between the claimed subject matter and the prior art are such that
`
`the subject matter as a whole would have been obvious at the time the invention
`
`was made to a person of ordinary skill in the pertinent art.
`
`16.
`
`I understand that a person of ordinary skill in the art provides a
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`reference point from which the prior art and claimed invention should be viewed.
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`This reference point prevents one from using his or her own insight or hindsight in
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`deciding whether a claim is obvious.
`
`17.
`
`I understand
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`that an obviousness determination
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`includes
`
`the
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`consideration of various factors such as (1) the scope and content of the prior art;
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`(2) the differences between the prior art and the asserted claims; and (3) the level
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`of ordinary skill in the pertinent art.
`
`18.
`
`I also understand that a party seeking to invalidate a patent as obvious
`
`must demonstrate that a person of ordinary skill in the art would have been
`
`motivated to combine the teachings of the prior art references to achieve the
`
`claimed invention, and that the person of ordinary skill in the art would have had a
`
`reasonable expectation of success in doing so. This is determined at the time the
`
`invention was made. I understand that this temporal requirement prevents the
`
`forbidden use of hindsight. I also understand that rejections for obviousness cannot
`
`
`
`7
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`
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`be sustained by mere conclusory statements and that the Petitioners must show
`
`some reason why a person of ordinary skill in the art would have thought to
`
`combine particular available elements of knowledge, as evidenced by the prior art,
`
`to reach the claimed invention.” I also understand that the motivation to combine
`
`inquiry focuses heavily on “scope and content of the prior art” and the “level of
`
`ordinary skill in the pertinent art.”
`
`19.
`
`I have been informed and understand that the obviousness analysis
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`requires a comparison of the properly construed claim language to the prior art on
`
`a limitation-by-limitation basis.
`
`IV. Background Topics
`20. The prior art references cited in the Petition and the Board’s Decision
`
`describe pulses for generating a plasma, but do not disclose the type of method and
`
`apparatus described in the ‘773 patent and its claims.
`
`A. Voltage, current, impedance and power
`21. As is commonly known, when a voltage “V” is applied across an impedance
`
`“I,” an electric field is generated that forces a current I to flow through the
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`impedance. For purely resistive impedance, the relation between the voltage and
`
`the resultant current is given by: V = I * R.
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`22. A common analogy is that voltage is like a pressure that causes charge
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`particles like electrons and ions to flow (i.e., current), and the amount of current
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`depends on the magnitude of the pressure (voltage) and the amount of resistance or
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`
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`8
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`
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`impedance that inhibits the flow. The ‘773 patent and the prior art considered here
`
`involve the flow of current through an assembly having a pair of electrodes with a
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`plasma in the region between them. The effective impedance of such an assembly
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`varies greatly with the density of charged particles in the region between the
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`electrodes. Although such an impedance is more complex than the simple resistive
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`impedance of the above equation, the general relation is similar: a voltage between
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`the electrode assembly forces a current to flow through the plasma, such that the
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`amount of current is determined by the amplitude of the voltage and the impedance
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`of the plasma. Thus, the current through the electrode assembly increases with the
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`electrode voltage and, for a given electrode voltage, the current will increase with a
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`drop in the impedance of the plasma.
`
`23. The impedance varies with the charge density of the plasma: With a high
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`density of charged particle the impedance is relatively small, and with a low
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`density of charge particles the impedance is relatively large. Simply, the more ions
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`and electrons to carry the charge, the less resistance. However, the charges and
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`fields react with each other in a very complicated manner.
`
`24. In response to the electric field in the region between the electrodes (i.e., the
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`voltage across the electrodes), all charged particles in the region (the electrons and
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`positive ions) feel a force that propels them to flow. This flow is an electric
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`current “I.” Obviously, the amount of current depends upon the number of charged
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`9
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`
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`particles. When there are no charged particles (i.e., no plasma), there is no current
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`flow in response to the electric field. In this condition, the impedance of the
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`electrode assembly is extremely high, like that of an open circuit. But when there
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`is a dense plasma between the electrodes (with many charged particles), a
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`substantial current will flow in response to the electric field. In this condition, the
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`impedance of the electrode assembly is very low. Thus, in general, the impedance
`
`of an electrode assembly varies greatly with the charge density of the plasma: The
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`impedance is effectively infinite (an open circuit) when there is no plasma, and is
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`very low when the charge density is very high.
`
`25. It is also well known that electric power (P) is the product of voltage (V)
`
`and current (I): P = V * I. This too is a complex relationship. When the voltage
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`and current are perfectly in phase, then one may simply multiply them to yield the
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`power. Thus, for a given voltage across an electrode assembly, the amount of
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`power will depend on the amount of corresponding current flowing through the
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`electrode assembly. If there is no current flow (such as when there is no plasma
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`between the electrodes), the power is zero, even if the voltage across the electrodes
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`is very large. Similarly, at very low electrode voltages, the power can still be quite
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`high if the current is large.
`
`26. To provide context for understanding this aspect of the ‘773 patent, I
`
`consider below some known basic principles of control systems (such as used in all
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`10
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`
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`power supplies and all such control systems) for controlling a parameter such as
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`voltage amplitude.
`
`B. Control systems
`27. The power supply mentioned in the ‘773 patent is an example of a control
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`system. This system controls the voltage amplitude of a voltage pulse. A
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`simplified block diagram of a common feedback control system is shown the
`
`figure below from a text by Eronini.1
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`
`
`
`
`Figure 1 Control system simplified block diagram
`
`28. The “reference input signal” represents a “desired value” or “set-point” of
`
`the controller. The “forward elements” directly control the “controlled variable.”
`
`In response to the difference between the set-point and a feedback signal (which
`
`represents the condition of the controlled variable), the forward elements direct the
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`1 Ex. 2010, Eronini Umez-Eronini, System Dynamics and Control, Brooks Cole
`
`Publishing Co., CA, 1999, pp. 10-13.
`
`
`
`11
`
`
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`controlled variable in an attempt to reduce the difference to zero, thereby causing
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`the controlled variable to equal the set point value.
`
`29. For example, the set-point for filling a water tank may be 1,000 gallons, or
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`full. The desired value, set-point or desired level is the value “full” or “1000
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`gallons.” An open loop control system might just fill the tank for a pre-calibrated
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`time that result in the tank being full. The control system might be set to fill the
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`tank once per day based on historical water usage. However, if water usage is not
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`consistent, the tank may run empty before it is filled, or may overflow because
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`there was less water usage than normal. On the other hand, a closed loop system
`
`such as shown above uses feedback control. For example, it measures the water
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`level, and only adds the needed amount. It might have a switch or sensor that
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`detects when the tank is full, and turns off the flow of water. The set-point is the
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`desired value. “Here the comparison of the tank level signal with the desired value
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`of the tank level (entered into the system as a set-point setting) and the turning of
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`the pump on or off are all performed by appropriate hardware in the controller.” 2
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`Further, a closed loop system could be left on to fill the tank if the level dropped to
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`low. “In feedback control, a measurement of the output of a system is used to
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`2 Ex. 2007, Eronini Umez-Eronini, System Dynamics and Control, Brooks Cole
`
`Publishing Co., CA, 1999, pp. 10-13.
`
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`12
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`
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`modify its input in such a way that the output stays near the desired value3.”
`
`C. Set point (Controlled Parameter)
`30. The parameter that is directed to a desired value is called the “controlled
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`variable,” as shown in the figure from Eronini. Eronini’s diagram also shows that
`
`while controlling the “controlled variable,” the system may “manipulate” another
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`control parameter that Eronini calls the “manipulated variable.”
`
`31. For example, Eronini’s text on control systems shows a control system that
`
`directs the “controlled variable” to its desired value (or “set point”):
`
`
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`32. Eronini’s diagram also shows that while controlling the “controlled
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`variable,” the system may “manipulate” another control parameter that Eronini
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`calls the “manipulated variable.” Another reference by Weyrick uses the same
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`terminology as Eronini:
`
` “The controlled output is the process quantity being controlled.”
`
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`3 Id. at p. 12.
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`13
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` “The manipulated variable is the control signal which the control
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`elements process.”4
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`33. Similarly, Kua and Sinka also show that the “controlled parameter” is
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`widely understood to mean the parameter being controlled by the control system.5
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`34.
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` With this understanding, I now consider the difference between
`
`controlling the amplitude of a voltage and controlling the power.
`
`D. Power Control vs Voltage Control
`35. To demonstrate the difference between the control of voltage and the control
`
`of power, I will refer to the generic diagram of a feedback control system from
`
`Eronini shown above. In a system for controlling voltage, the set point is a
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`specified voltage and the “controlled variable” obviously is voltage. Thus, in a
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`feedback control system as shown in Eronini, a feedback signal representative of
`
`the measured voltage is fed back and compared to the desired voltage level or “set
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`point.” Based on the difference between the measured voltage and the desired
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`voltage or set point, the forward elements are instructed to drive or restrain the
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`voltage in an attempt to move the actual voltage to match the desired voltage.
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`36. In a system for controlling power, the set point is a specified power value
`
`and the controlled variable is power. In such a system, the voltage and/or current
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`4 Ex. 2011, Weyrick at 13
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`5 Ex. 2009, Kua, Automatic Control, Prentice Hall Inc., 1987; Ex. 2006, Sinha,
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`Naresh, K., Control Systems, Holt, Rinehart and Winston, 1986.
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`14
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`
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`can be driven by the feed forward elements to whatever levels are needed to
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`achieve the target power level. Thus, in the example of a system for controlling
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`the power of a plasma electrode assembly, if there is no plasma between the
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`electrodes (and therefore little or no current) a controller attempting to achieve a
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`target power level will drive the voltage extremely high in an attempt to achieve
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`the target power P, i.e., P = V * I, (because I is very low or zero in this situation).
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`37. Thus, in a control system for controlling power to a desired set point,
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`voltage will vary as the controller attempts to achieve the desired power level (i.e.,
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`a desired product of voltage and current). However, the amplitude of the voltage is
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`not controlled and instead the voltage and/or the current vary as needed to achieve
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`the desired power.
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`38. The rise time of a voltage therefore, is a different parameter than the rise
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`time of power. For example, consider a scenario in which a voltage source outputs
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`a constant voltage. If that source is connected across an impedance that gradually
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`drops, the current will increase as the impedance drops. Since power is the product
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`of voltage (here a constant) and current, the power too will rise as the current
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`increases. Thus, in this situation, power rises at a rate determined by the rate at
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`which the impedance decreases. But there is no rise in voltage because the source
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`maintains a static, constant voltage at its output in this example. This demonstrates
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`that a rise time in voltage is a different parameter than rise time in power.
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`15
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`
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`39. This example can also be used to demonstrate the difference between a
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`controlled change in the output of a voltage source, and a reaction to a change in
`
`impedance. If the impedance drops so fast that the voltage source cannot maintain
`
`the voltage at its target level, the voltage output by the source can drop due to
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`limitations of the voltage source. This drop in voltage is not a controlled drop,
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`caused by the power supply in response to a programmed change in the voltage set
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`point: It is a transient drop caused by a change in the impedance load that exceeds
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`the capacity of the voltage source.
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`E. Magnetron Sputtering History and Operation
`40. Since the late 1970s, DC magnetron sputtering has become the preferred
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`method for the deposition of thin metal films for many applications, including
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`semiconductor devices and protective layers on cutting tools. Several significant
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`advantages of this method over alternatives, such as thermal evaporation or diode
`
`sputter deposition, are higher deposition rate and improved film structure.
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`41.
`
` The higher deposition rate is possible because the closed loop
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`magnetic field of the magnetron traps the secondary electrons (produced when the
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`inert gas ions bombard the metal target that is attached to the cathode assembly
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`held at a negative voltage of several hundreds of volts). These electrons gain
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`energy as they are accelerated across the dark space. Since most of the voltage
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`drop from anode to cathode occurs in this region, the electrons arrive in the
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`discharge region with more than enough energy to ionize the neutral gas atoms
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`
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`16
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`
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`there. The crossed electric and magnetic fields create a force on the electrons that
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`causes them to circulate in a path that follows the shape of the magnetic loop and is
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`only a few mm from the face of the target. The circulating current in this loop is
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`about 10x the anode-cathode current of the sputtering discharge. It is these
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`electrons that collide with, and create large numbers of ions of, the inert neutral
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`sputtering gas atoms (usually argon) that have diffused into this region. The ions
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`are accelerated toward the target and bombard it with energies that are nearly the
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`full cathode-anode voltage. As the secondary electrons create an ion, they lose
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`energy and move closer to the anode. After several ionizing collisions they no
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`longer have enough energy to create ions. It is the secondary electrons that sustain
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`a normal magnetron discharge.
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`42. The magnetron discharge is characterized by higher current and lower
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`voltage (i.e., lower impedance) compared to a diode discharge. This allows higher
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`powers to be delivered than would be possible with diode sputtering, because the
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`drop in yield with lower voltage is more than made up for by the increase in the
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`number of ions. In DC magnetron sputtering, repeatability of film thickness is
`
`usually achieved by operating the power supply in power control mode and
`
`depositing for a specific time.
`
`43. The sputtered metal atoms are ejected from the target with high
`
`velocity, compared to evaporation, which contributes to film adhesion and
`
`
`
`17
`
`
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`microstructure. However, this high velocity means that relatively few of the metal
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`atoms have a chance to become ionized as they traverse the thin zone of high
`
`energy electrons on their way from the source target to the substrate workpiece
`
`(e.g., silicon wafer or razor blade).
`
`44. As research progressed over the ensuing decades, the advantages of
`
`increasing the ionization of the sputtered atoms became evident. Ions impacting
`
`the growing film improved qualities such as hardness, adhesion and density even
`
`further. Furthermore, the trajectories of the incoming ions could be made more
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`perpendicular to the substrate surface by application of a negative bias. This
`
`allowed more film to be deposited in the bottom of high aspect ratio holes enabling
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`the production of semiconductor devices with ever-decreasing geometries.
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`45. The challenge of increasing the degree of ionization of the sputtered
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`atoms could be met by increasing the chances that they would encounter an
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`ionizing collision in the space between target and substrate. This could be
`
`achieved by expanding the high density plasma into that space. Just increasing the
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`DC power to the magnetron would do this and would increase the power density
`
`delivered to the target, increasing the sputtering rate and the ionization of the
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`sputtered atoms. However, this approach, if applied steady state, would require
`
`large power supplies and would overheat the target. Therefore, other techniques
`
`were developed to meet the challenge.
`
`
`
`18
`
`
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`46. One approach, introduced by Rossnagel and Hopwood6 was to create
`
`a separately sustained plasma in the target-substrate space. Another was to use the
`
`hollow cathode magnetron invention of Helmer.7 Yet another approach was to use
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`pulsed DC magnetron sputtering to create a short-lived high density magnetron
`
`plasma with enough time between pulses such that the average power delivered
`
`over many pulses did not exceed the steady state power delivery capability of the
`
`power supply or the cooling capacity of the cathode. As the density of the plasma
`
`increases it also expands, at least partially due to reduced trapping of the electrons
`
`circulating with the magnetic field loop. The large circulating current in this loop
`
`forms a one-turn (very high amperage) electromagnet that creates a magnetic field
`
`opposing the magnetic field produced by the magnetron magnets. This reduction
`
`in effective magnetic field allows an increase in width of the sputtering zone and
`
`an expansion of the plasma away from the cathode.
`
`47. However, this pulsed approach is accompanied by several risks. An
`
`abrupt large increase in applied voltage can cause localized instabilities in electric
`
`fields to be large enough to initiate an arc on the cathode, even if a low density
`
`magnetron discharge is already present. If the high density plasma is driven to
`
`
`6 S.M. Rossnagel and J. Hopwood, Journal of Vacuum Science & Technology 12B
`
`(449-453) 1994.
`
`7 U.S. Patent No. 5,482,611.
`
`
`
`19
`
`
`
`over-expansion it can essentially form a short between the cathode and anode
`
`leading to a breakdown mode in which no sputtering occurs.
`
`48. There are large changes in plasma impedance during a pulsed DC
`
`magnetron discharge. The more charged particles within it, the more electrically
`
`conducting it becomes. During ignition, the impedance may be in the hundreds of
`
`ohms, dropping to the tens of ohms in the low density mode. In the transition from
`
`a low to a high density plasma, the impedance drops to a few ohms, accompanied
`
`by up to two orders of magnitude increase in current. Depending on power supply
`
`design and control settings, the density of the plasma may increase quite unevenly,
`
`also leading to the possibility of plasma breakdown or arcs, if the transitions are
`
`uncontrolled.
`
`49. Power supplies in the art prior to the ‘773 patent for DC magnetron
`
`sputtering include those that set power for the duration of a deposition step. In
`
`power control mode, the output is controlled until the product of discharge voltage
`
`and current equals the set power. In pulsed power mode, the total energy delivered
`
`during a pulse is controlled.
`
`50. However, such pulsed power systems are prone to arcing upon
`
`igniting the plasma, especially when working with high-power pulses.8
`
`51. Such arcing can result in the release of undesirable particles in the
`
`8 Ex. 1001, ‘773 patent, col. 1, lines 38-40.
`
`
`
`20
`
`
`
`chamber that can contaminate the sample, which is especially undesirable in
`
`semiconductor processing.9
`
`V. The ’773 Patent
`
`
`52. Sputtering systems generate and direct ions from plasma “to a target surface
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`where the ions physically sputter target material atoms.”10 Then, “The target
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`material atoms ballistically flow to a substrate where they deposit as a film of
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`target material.”11 “The plasma is replenished by electron-ion pairs formed by the
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`collision of neutral molecules with secondary electrons generated at the target
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`surface.”12
`
`53. A planar magnetron sputtering system is one type of sputtering system.13
`
`“Magnetron sputtering systems use magnetic fields that are shaped to trap and to
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`concentrate secondary electrons, which are produced by ion bombardment of the
`
`target surface.”14 “The trapped electrons enhance the efficiency of the discharge
`
`and reduce the energy dissipated by electrons arriving at the substrate.”15
`
`
`9 Ex. 1001, ‘773 patent, col. 1, lines 40-42.
`
`10 Ex. 1001, col. 1, ll. 9-10.
`
`11 Id. at col. 1, ll. 10-12.
`
`12 Id. at col. 1, ll. 30-33.
`
`13 Id. at col. 1, ll. 42-58.
`
`14 Id. at col. 1, ll. 34-36.
`
`15 Id. at col. 1, II. 49-51.
`
`
`
`21
`
`
`
`54. But prior art planar magnetron sputtering systems deposit low uniformity
`
`films, poorly utilize the target, and have a low deposition rate and yield.16
`
`“[C]onventional magnetron sputtering systems have a relatively low deposition
`
`rate [meaning] the amount of material deposited on the substrate per unit of time”17
`
`“The deposition rate is proportional to the sputtering yield.”18 The sputtering yield
`
`means “the number of target atoms ejected from the target per incident particle.”19
`
`55. To overcome the problems of low deposition rate and sputtering yield of the
`
`prior art, Dr. Chistyakov invented a sputtering source containing (i) a cathode
`
`assembly, containing a sputtering target, adjacent to an anode; (ii) an ionization
`
`source to generate weakly ionized plasma from a feed gas proximate to the anode;
`
`and (iii) a power supply generating a voltage pulse having an amplitude and a rise
`
`time chosen to generate a strongly ionized plasma with an increase in the density
`
`of ions 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 claims 1 and 34, and as illustrated in Fig. 5A of
`
`the ’773 patent, reproduced below:
`
`
`16 Id. at col. 1, ll. 52-66.
`
`17 Id. at col. 1, ll. 63-66.
`
`18 Id. at col. 2, ll. 66-67.
`
`19 Id. at col. 2, ll. 1-2.
`
`
`
`22
`
`
`
`
`
`
`
`
`
`56. As illustrated by FIG. 5A, Dr. Chistyakov’s sputtering source 200 includes a
`
`pulsed power supply 234, and a cathode assembly 216 including the sputtering
`
`target 220. In one embodiment, the “cathode assembly 216 is coupled to the
`
`output 222 of a matching unit 224.”20 “An input 230 of the matching unit 224 is
`
`coupled to the first output 232 of a pulsed power supply 234. A second output 236
`
`of the pulsed power supply 234 is coupled to an anode 238.”21 “The anode 238 is
`
`positioned so as to form a gap 244 between the anode 238 and the cathode
`
`assembly 216 that is sufficient to allow current to flow through the region 245
`
`between the anode 238 and the cathode assembly 216. In one embodiment, the
`
`
`20 Id. at col. 6, ll. 39-40.
`
`21 Id. at col. 6, ll. 42-45.
`
`
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`23
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`
`
`width of th
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