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`Trial No. IPR2014-00726
`Docket No. 0110198-00194 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
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________________________________
`
`THE GILLETTE COMPANY
`
`Petitioners
`
`v.
`
`ZOND, LLC
`
`Patent Owner of
`
`U.S. Patent No. 6,896,773
`
`IPR Trial No. IPR2014-00726
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`PETITIONER’S REPLY
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`Claims 21-33 and 40
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`I.
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`II.
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`Trial No. IPR2014-00726
`Docket No. 0110198-00194 US2
`TABLE OF CONTENTS
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`
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`INTRODUCTION ........................................................................................ 1
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`INDEPENDENT CLAIMS 21 AND 40 ARE OBVIOUS ......................... 3
`
`A.
`A “feed gas” as used in independent claims 21 and 40 is shown
`in Mozgrin ....................................................................................................... 3
`B.
`The combination of Mozgrin with Fortov discloses choosing
`an amplitude and a rise time of the voltage pulse so that ions in the
`strongly ionized plasma 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 rquired by claims 21 and 40. .... 5
`C.
`One skilled in the art would have been able to combine the
`cited references with reasonable expectation of success ............................ 7
`III. THE DEPENDENT CLAIMS ARE ALSO OBVIOUS ............................ 9
`
`Dependent claim 28 ...................................................................... 9
`A.
`Dependent claims 24 and 25 ........................................................ 9
`B.
`Dependent claim 23 .................................................................... 10
`C.
`Dependent claim 29 .................................................................... 11
`D.
`IV. CONCLUSION ............................................................................................ 12
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`I.
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`INTRODUCTION
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`Trial No. IPR2014-00726
`Docket No. 0110198-00194 US2
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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 21-33 and 40 are unpatentable. See
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`IPR2014-726 DI at p. 2. None of the arguments raised by Zond alters that
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`conclusion.
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`The only disputes remaining as to the independent claims are whether: (1)
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`Mozgrin discloses or renders obvious a “feed gas,” as narrowly interpreted by Zond;
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`(2) combining Mozgrin with Fortov to choose an amplitude and a rise time of the
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`voltage pulse so that ions in the strongly ionized plasma generate sufficient thermal
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`energy in the sputtering target to cause a sputtering yield to be non-linearly related to
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`a temperature of the sputtering target; and (3) whether one skilled in the art would
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`have been able to combine the cited references with reasonable expectation of
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`success. IPR2014-728 PO Resp. at 38-43, 26-37. Each of these arguments fail.
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`First, Zond proposes to interpret the claim term “feed gas” to require a
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`constantly-flowing gas (to the exclusion of a static gas in a chamber) in a misguided
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`effort to distinguish the prior art. The Board has already rejected such a narrow
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`reading of the term “feed gas.” But even if Zond’s interpretation were adopted, the
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`cited prior art nevertheless renders the claims unpatentable.
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`Second, it would have been obvious to a person of ordinary skill to combine
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`Mozgrin with Fortov to achieve the “particular sputtering yield by choosing the
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`Trial No. IPR2014-00726
`Docket No. 0110198-00194 US2
`amplitude and rise time of the applied voltage pulse.” IPR2014-726 Patent Owner’s
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`Response (“PO Resp.”) at p. 41. Mozgrin discloses choosing voltage amplitudes and
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`rise times. Fortov describes the relationship between the sputtering yield and target
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`temperature (which depends on the voltage amplitudes and rise times applied to the
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`target), including when that relationship becomes “non-linear” as required by the
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`claims. Moreover, the combination of Mozgrin and Fortov would have been
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`obvious—indeed, recognizably advantageous—to a person of ordinary skill in the art,
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`despite Zond’s argument that Mozgrin is directed to etching while Fortov is directed
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`to sputtering (as explained below, Mozgrin is directed to sputtering as well as etching).
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`Third, the Petition, supported by Mr. DeVito’s declaration, demonstrates why
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`one of ordinary skill in the art would have combined Mozgrin with the teachings of
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`Fortov, Lantsman and Kudryavtsev, with reasonable expectation of success. In fact,
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`the cross examination testimony of Dr. Hartsough, Zond’s declarant, confirms that
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`the motivation to combine existed well before the ‘773 patent. Petitioner also
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`provides the declaration of Dr. John Bravman, who reached the same conclusion: that
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`the references would have been combined by one of ordinary skill in the art, and that
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`the challenged claims are unpatentable.1
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`Finally, as to the dependent claims, the concessions made by Dr. Hartsough
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`and an accurate representation of the factual record clearly demonstrate that these
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`1 Mr. DeVito is no longer available to provide testimony.
`2
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`claims too are invalid.
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`Trial No. IPR2014-00726
`Docket No. 0110198-00194 US2
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`II.
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`INDEPENDENT CLAIMS 21 AND 40 ARE OBVIOUS
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`Zond’s own declarant, Dr. Larry Hartsough, concedes that all the limitations
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`individually recited in the independent claims were well known before the effective
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`date of the ‘775 patent. See Ex. 1124 (“’773 Hartsough Depo.”) at 76:5-10; 77:14-
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`78:16; 80:13-18; 89:21-24; 37:25 – 38:4; and 32:9-14. The claimed combinations were
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`similarly obvious.
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`A.
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`A “feed gas” as used in independent claims 21 and 40 is shown in
`Mozgrin2
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`Zond argues that “Mozgrin does not disclose a feed gas (i.e., a gas that flows
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`into the chamber during the plasma generation process).” IPR2014-726 PO Resp. at
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`p. 45. This is wrong for three reasons.
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`First, the Board already considered and rejected Zond’s proposal that the term
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`2 In IPR2014-00580, Zond made similar arguments with respect to claims 1 and 34.
`Zond also argue that Mozgrin fails to disclose that a weakly-ionized plasma is
`generated “proximate” to an anode and cathode as required by those claims.
`IPR2014-580, PO Resp. at pp. 35-36. Claims 31 and 40, addressed here, do not
`include such limitations. See ’773 patent, claim 21 (“generate a weakly-ionized plasma
`proximate to a cathode assembly,” with no mention of the anode) and claim 40
`(“means for ionizing a feed gas to generate a weakly-ionized plasma”). To the extent
`Zond incorrectly argues that the “proximate” limitations of claims 1 and 34 apply to
`claims 21 and 40, those arguments would fail for the reasons discussed in Petitioner’s
`Reply in IPR2014-00580. IPR2014-580, Petitioner’s Reply at Section II.B.
`3
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`Trial No. IPR2014-00726
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`“feed gas” requires a constant flow of gas to the exclusion of a “static” gas.
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`Specifically, “[t]he recitation of ‘a feed gas’ … does not necessarily imply the flow of
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`gas.” Ex. 1126 (IPR2014-00578 Decision on Institution) at p.9. Zond cites nothing
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`to question the Board’s conclusion on this point.
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`Second, as Mr. DeVito explained, one skilled in the art would understand
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`Mozgrin to teach a constant flow of gas:
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`Q: Just point me to where in the Mozgrin reference he’s talking
`about using a constant flow of gas.
`A: … I think he teaches it because … he’s applying these pulses
`over may periods. He’s getting these very high deposition rates. And,
`you know, just the body of the work suggests to me that this is a
`constant flow of gas going on. He mentions about the pressure. So …
`in order for the pressure to stay constant, you’d have to keep
`applying this flow of gas and pumping it out.
`Ex. 2010 (“’773 DeVito Depo.”) at 84:13-85:1.
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`Third, Zond cites the reference in the Mozgrin Thesis to needle valves, which
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`Zond claims to demonstrate that use of needle valves is inconsistent with a
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`continuous flow of gas in Mozgrin. IPR2014-728 PO Resp. at pp. 39 and 45. This is
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`incorrect. As Dr. Bravman explained, “it is well-known that needle valves provide a
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`continuous flow of gas.” Ex. 1127 (“Bravman Dec.”) at ¶ 48. Furthermore,
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`Ehrenberg, a book published in 1981, expressly teaches that “while still pumping,
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`argon gas is allowed to enter the bell-jar through a needle valve… This continuous
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`flow method tends to sweep away any impurities….” Ex. 1125 (“Ehrenberg”) at p.
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`
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`81. It is well known that use of needle valves allow a controlled, continuous flow of
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`gas into an evacuated chamber.
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`B.
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`The combination of Mozgrin with Fortov discloses choosing an
`amplitude and a rise time of the voltage pulse so that ions in the
`strongly ionized plasma 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 rquired by
`claims 21 and 40.
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`Zond also argues that Mozgrin and Fortov individually or in combination do
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`not teach the claim limitation of choosing an amplitude and a rise time of the voltage
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`pulse for the purpose of generating “sufficient thermal energy in the sputtering target
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`to cause a sputtering yield to be non-linearly related to a temperature of the sputtering
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`target.” Zond goes on to assert that one skilled in the art would not have combined
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`the two references without using the ‘773 as a blueprint for that combination.
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`IPR2014-726 PO Resp. at pp. 40-43. As already explained in the Petition, this is
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`incorrect.
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`In fact, each and every individual component of this limitation is taught by the
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`combination of Mozgrin and Fortov. As conceded by Dr. Hartsough, “Mozgrin
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`delivers a voltage pulse to [a] weakly-ionized plasma” that “has an amplitude” and
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`“has a rise time.” ‘773 Hartsough Depo. at 77:20 – 78:8. Mozgrin used a typical
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`control system where the controlled variable could be the voltage. Id. at 83:12-25
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`(“Q. So one of ordinary skill in the art could expect that the pulsed power supply used
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`by Mozgrin would operate using such a known control system; correct? … [A.] Yes.
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`Q. And the controlled variable in Mozgrin’s control system would be voltage because
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`that’s what he’s applying; right? … [A.] It -- it’s a little difficult to determine what he
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`means -- what -- when -- how a controlled variable would be, but it could be.”). This
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`voltage pulse would lead to “a rapid increase from the weakly-ionized plasma” and
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`grow into “a strongly-ionized plasma generated in the sputtering regime of Mozgrin.”
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`‘773 Hartsough Depo. at 78:11-16; 79:3-6; and 80:13-18. The sputtering yield of the
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`copper target described in Mozgrin (‘773 Hartsough Depo. at 69:7-13) would behave
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`according to the non-linear relationship with temperature of the sputtering target, as
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`described in Fortov. ‘773 Hartsough Depo. at 75:10-13. See Bravman Dec. at ¶¶ 61-
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`64.
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`Faced with these facts, Zond argues that a person of ordinary skill in the art
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`would not have combined Mozgrin with Fortov. But as Dr. Hartsough concedes, “a
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`person of ordinary skill would have been motivated to increase the sputtering yield in
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`a sputtering application.” ‘773 Hartsough Depo. at 53:13-17. Moreover, Dr.
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`Hartsough conceded that “[i]ncreasing the ionization of sputtered atoms is
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`advantageous in sputtering applications.” ‘773 Hartsough Depo. at 51:21 – 52:1.
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`Therefore, increasing the sputtering yield of Mozgrin—which provides well-known
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`benefits—would lead to the non-linear relationship described in Fortov at sufficiently
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`high temperatures. In other words, contrary to Zond’s argument that the “Petition’s
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`motivation to combine is rooted in forbidden hindsight” (IPR2014-726, PO Resp. at
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`p. 26), Zond’s own declarant actually supports the Petitioners’ position. That is, a
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`person of ordinary skill in the art would have been motivated to combine Fortov with
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`Mozgrin to achieve the non-linear increase in sputtering yield taught in Fortov.
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`Bravman Dec. at ¶¶ 65-66.
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`Finally, Zond argues that there are “serious discrepancies” between Mozgrin
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`and Fortov that would prevent their combination. Zond argues that Fortov discloses
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`sputtering over a large range of plasma densities while Mozgrin has no sputtering in
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`its “regime 3” and, therefore, “these contradictory teachings” would not have led a
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`person of ordinary skill to combine the references. IPR2014-726 PO Resp. at 28-29.
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`However, this argument ignores the fact that Mozgrin teaches a regime 2 that is
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`dedicated to sputtering. Mozgrin at p. 409, left col, ¶¶ 4-5. As Mozgrin states, “[e]ach
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`point of the discharge characteristic [of Figs. 4 and 7] represent a pair of voltage and
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`current oscillograms [of Fig. 3].” Mozgrin at p. 402, right col., ¶2. Accordingly, Fig.
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`3b of Mozgrin shows a voltage pulse generated by a power supply for either
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`sputtering or etching regimes. Ex. 1127 (“Bravman Dec.”) at ¶¶ 59-60.
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`C. One skilled in the art would have been able to combine the cited
`references with reasonable expectation of success
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`In addition to the argument that a person of ordinary skill would not combine
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`Mozgrin with Fortov addressed in the prior section, Zond argues that one skilled in
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`the art would not combine Mozgrin with Lantsman because “a system that uses a
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`pulsed discharge supply … would operate very differently if it were modified to use
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`
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`two DC power supplies….” IPR2014-726 PO Resp. at p. 31. However, Mozgrin
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`itself combined a constant DC power supply unit with a pulsed supply unit into a
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`single power supply. Mozgrin at p. 401, left col, ¶ 4. Indeed, Dr. Hartsough concedes
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`that “it wouldn’t be beyond the skill of a person of ordinary skill in the art … to
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`combine a constant DC supply with a pulsed DC supply.” Ex. 1128 (’775 Hartsough
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`Depo.) at 152:9-18. See Bravman Dec. at ¶¶ 67-68.
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`Zond also argues that one skilled in the art would not combine Mozgrin with
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`Kudryavtsev. IPR2014-726 PO Resp. at pp. 33-37. However, Mozgrin himself
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`explicitly “took into account the dependenc[i]es which had been obtained in
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`[Kudryavtsev]” when designing his own system. Mozgrin at p. 401, right col, ¶1; see
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`also Bravman Dec.at ¶¶ 69-70. Zond’s argument that one of skilled in art would not
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`have done exactly what Mozgrin himself actually did do makes no sense.
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`The differences cited by Zond that may exist in the systems of Mozgrin,
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`Fortov, Lantsman and Kudryavtsev are inconsequential. A person of ordinary skill in
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`the art would have known how to apply the teachings of these references to systems
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`for performing sputtering, irrespective of different pressures, different dimensions,
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`different sizes, magnets and/or other feature differences. These are routine variables
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`one of ordinary skill in the art would work with on a regular basis, and would consider
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`it routine to make any necessary changes to accommodate any and all such variables.
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`See Bravman Dec. at ¶¶ 71-72.
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`III. THE DEPENDENT CLAIMS ARE ALSO OBVIOUS
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`Zond provides no argument that dependent claims 22, 26, 27 and 30-33 add
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`any patentable subject matter, thereby conceding that these claims are unpatentable.
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`Dependent claims 23-25, 28 and 29 are also obvious, as discussed more fully below.
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`A. Dependent claim 28
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`Zond’s sole argument on the purported deficiency of the prior art lies in the
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`assertion that Mozgrin fails to teach a “feed gas” as that term has been interpreted by
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`Zond (i.e., requiring a continuous flow of a feed gas). However, as explained above in
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`Section II.A with respect to the independent claims, Mozgrin does, in fact, teach a
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`“feed gas,” Even under Zond’s previously-rejected interpretation. As such, Zond’s
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`argument fails and claim 28 is invalid. Bravman Dec. at ¶¶ 109 and ¶¶ 44-49.
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`B. Dependent claims 24 and 25
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`Zond argues that a person skilled in the art would not have been “motivated to
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`combine Lantsman’s feed gas in Mozgrin’s static gas system.” IPR2014-726 PO Resp.
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`at p. 46. However, as explained above in Section II.A, this argument is predicated on
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`an incorrect understanding of the prior art. Bravman Dec. at ¶ 104 and ¶¶ 44-49.
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`Zond also argues that “Lantsman is also silent with regard to controlling the
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`flow of feed gas with a controller to diffuse strongly-ionized plasma.” IPR2014-726
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`PO Resp. at p. 45; see also id. at p. 48. However, as Dr. Hartsough concedes, feed gas
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`will “intermingle” as it “want[s] to diffuse the – the particles of both the plasma and
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`the feed gas together.” ‘773 Hartsough Depo. at 35:25 – 36:20. As a result, “addition
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`of the feed gas would diffuse the strongly-ionized plasma.” IPR2014-726, Petition at
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`p. 48; see also Bravman Dec. at ¶ 106.
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`C. Dependent claim 23
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`Zond argues that “the combination of Mozgrin and Kudryavtsev does not
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`teach generating “secondary electrons from the cathode assembly, the secondary
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`electrons ionizing the excited atoms, thereby creating the strongly-ionized plasma,” as
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`recited in claim 23. IPR2014-726 PO Resp. at p. 50.
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`Zond’s argument centers on its assertion that “sputtering (e.g., the impacting of
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`ions to the target) does not occur in region 3.” IPR2014-726 PO Resp. at p. 49.
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`However, as explained above, Figures 4 and 7 teach both sputtering and etching in
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`regimes 2 and 3, respectively, that are generated from different voltage pulses shown
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`in Fig. 3b. Mozgrin at p. 409, left col, ¶¶ 4-5. As Mozgrin states, “[e]ach point of the
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`discharge characteristic [of Figs. 4 and 7] represent a pair of voltage and current
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`oscillograms [of Fig. 3].” Mozgrin at p. 402, right col., ¶2. Accordingly, Fig. 3b of
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`Mozgrin show a voltage pulse generated by a power supply for either sputtering or
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`etching regimes. Bravman Dec. at ¶¶ 121 and ¶¶ 59-60.
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`Having established that Mozgrin does indeed teach sputtering, no dispute
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`remains. Dr. Hartsough conceded that “generating a strongly-ionized plasma,”
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`“generating secondary electrons” and “generating plasma from the secondary
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`electrons colliding with excited atoms” each was “a well-known concept before
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`2002.” ‘775 Hartsough Depo. at 43:12-15 and 44:4-15.
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`D. Dependent claim 29
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`Zond argues that “the mere disclosure of sputtering in Mozgrin and Fortov
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`does not teach that “the ions in the strongly-ionized plasma causes at least a portion
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`of a surface layer of the sputtering target to evaporate,” as recited in claim 29,
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`(IPR2014-726 PO Resp. at pp. 51-52), because “evaporation need not necessarily
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`occur during sputtering.” IPR2014-726 PO Resp. at p. 51.
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`However, Dr. Hartsough concedes that both Mozgrin and Fortov describe use
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`of copper targets for sputtering. ‘773 Hartsough Depo. at 69:7-13. Dr. Hartsough
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`also concedes that it was well-known that the non-linear increase in sputtering yield of
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`copper targets would “begin somewhere around 0.7 Tm, the melting point of copper.”
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`‘773 Hartsough Depo. at 75:10-13. Bravman Dec. at ¶¶125-126.
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`Fortov further explains that “sputtering is reviewed as evaporation,” (Ex.
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`1104 [Fortov] at p. 123, left col.). One skilled in the art therefore would have
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`understood that evaporation increasingly occurs with increasing temperature.
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`Bravman Dec. at ¶¶ 127-128. See ’773 DeVito Depo. at 64:19 – 65:2:
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`A: [O]ne of skill in the art who had these references in front of
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`him would have said, look … Mozgrin is trying to do higher sputter yield
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`Trial No. IPR2014-00726
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`with this technique. Fortov has a recipe for getting to a certain
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`temperature, increase sputtering yield. I’m pretty sure that I can modify
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`these powers and rise times to get to this temperature. Let me put these
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`two together and make it happen.
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`Hence, one skilled in the art would readily have been able to choose the amplitude
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`and rise time of a voltage pulse in Mozgrin to achieve the temperature condition for
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`more evaporation and sputtering, as described in Fortov. ’773 DeVito Depo.at 65:7-
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`14; see also Bravman Dec. at ¶ 128.
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`IV. CONCLUSION
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`The Board correctly found that there was a reasonable likelihood that the
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`claims are unpatentable. None of Zond’s arguments undermine that conclusion
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`reached by the Board. As set forth in the Petition and the supporting declarations,
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`challenged claims 21-33 and 40 are unpatentable beyond a preponderance of the
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`evidence.
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`Tel: (202) 663-6025
`Fax: (202) 663-6363
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`April 2, 2015
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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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`Trial No. IPR2014-00726
`Docket No. 0110198-00194 US2
`CERTIFICATE OF SERVICE
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`I hereby certify that, on April 2, 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 1124-1128
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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
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`Manner of service
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`April 2, 2015
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`Email: gonsalves@gonsalveslawfirm.com;
`bbarker@chsblaw.com; kurt@rauschenbach.com
`
`
`Persons Served Dr. Gregory J. Gonsalves
`2216 Beacon Lane
`Falls Church, Virginia 22043
`
`Bruce Barker
`Chao Hadidi Stark & Barker LLP
`176 East Mail Street, Suite 6
`Westborough, MA 01581
`
`
`
`
`/Yung-Hoon Ha/
`Yung-Hoon Ha
`Registration No. 56,368
`7 World Trade Center
`250 Greenwich Street
`New York, NY10007
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`Exhibit
`1101
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`1102
`1103
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`1104
`1105
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`1106
`1107
`1108
`1109
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`1110
`1111
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`1112
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`1113
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`1114
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`1115
`1116
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`1117
`1118
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`Trial No. IPR2014-00726
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`EXHIBIT APPENDIX
`
`Description
`U.S. Patent No. 6,896,773
`D.V. Mozgrin, et al, High-Current Low-Pressure Quasi-
`Stationary Discharge in a Magnetic Field: Experimental
`Research, Plasma Physics Reports, Vol. 21, No. 5, 1995
`(“Mozgrin”)
`U.S. Patent No. 6,413,382 (“Wang”)
`Certified Translation of Encyclopedia of Low-Temperature
`Plasma Physics, Introductory Vol. III, Section VI, Fortov, V.E.,
`Ed., Nauka/Interperiodica, Moscow (2000); pp. 117-126
`(“Fortov”)
`Declaration of Richard DeVito (“DeVito”)
`A. A. Kudryavtsev, et al, Ionization relaxation in a plasma
`produced by a pulsed inert-gas discharge, Sov. Phys. Tech. Phys.
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