UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`
`THE PETITIONERS COMPANY
`Petitioner
`
`v.
`
`ZOND, LLC
`Patent Owner
`
`U.S. Patent No. 7,808,184
`Claims 1 – 5, 11 - 15
`Claims 6 – 10, 16 - 20
`
`_____________________
`
`Inter Partes Review Case No. 2014-00799
`
`Inter Partes Review Case No. 2014-00803
`
`_____________________
`
`DECLARATION OF LARRY D. HARTSOUGH, Ph.D.
`
`i
`
`
`
`
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`TABLE OF CONTENTS
`
`
`
`I.   Education and Professional Background ................................................................................... 1  
`II.   Summary of Opinions: Claims 1 - 20 ...................................................................................... 5  
`III.   Legal Standards ........................................................................................................................ 7  
`A.   Level of Ordinary Skill in the Art ............................................................................ 7  
`B.   Claim Interpretation Issues for Claims 1 - 20 .......................................................... 8  
`C.   Legal Standards for Anticipation ........................................................................... 10  
`D.   Legal Standards for Obviousness ........................................................................... 10  
`IV.   Background Topics ................................................................................................................ 12  
`A.   Voltage, current, impedance and power ................................................................. 13  
`B.   Control systems ...................................................................................................... 15  
`C.   Set point (Controlled Parameter) ............................................................................ 18  
`D.   Power Control vs Voltage Control ......................................................................... 19  
`E.   Magnetron Sputtering History and Operation ........................................................ 21  
`II.   Patent 7,808,184 ..................................................................................................................... 26  
`A.   The Programmable Power Modes: Low Power Mode vs. High Power Mode ....... 28  
`B.   Fig 2. Of the ‘184 patent: Plasma Current and Voltage ........................................ 32  
`C.   Figure 3 of the ‘184 patent ..................................................................................... 35  
`D.   Plasma Density ....................................................................................................... 37  
`E.   Figure 4 of the ‘184 Patent ..................................................................................... 38  
`F.   Figs 5A – 5C ........................................................................................................... 42  
`G.   Figs. 6A – 6B; 7A,B ............................................................................................... 45  
`a.   Stability of plasma transition to high density and risk of arc .......................................... 45  
`H.   Fig. 8 ...................................................................................................................... 47  
`III.   Prior Art .................................................................................................................................. 48  
`A.   Wang ...................................................................................................................... 48  
`a.   Wang’s Power Pulses ...................................................................................................... 48  
`
`ii
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`b.   Arcing in Wang ............................................................................................................... 52  
`c.   Variances between Wang’s Target Power Levels and Actual Power ............................. 55  
`B.   Kudryavtsev ........................................................................................................... 59  
`a.   Arcing in Kudryastev ...................................................................................................... 60  
`b.   Lack of Disclosure of Controlled Rise Time or Amplitude ............................................ 68  
`c.   A person of ordinary skill in the art would not combine Wang with Kudryavtsev ......... 71  
`IV.   Conclusions and Opinions Regarding Claims 1 - 20 ............................................................. 74  
`V.   Additional Conclusions and Opinions Regarding the Dependent Claims ............................. 77  
`A.   Claims 5, 15 .......................................................................................................... 77  
`B.   Dependent Claims 7, 17 ......................................................................................... 80  
`V.   Response to the Institution Decision ...................................................................................... 82  
`
`
`
`
`
`
`
`
`iii
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`
`
`
`
`I, Larry D. Hartsough, Ph.D., hereby declare:
`
`
`1.
`
`I am making this declaration at the request of patent owner
`
`Zond, LLC, in the matter of the Inter Partes Reviews (IPRs) of U.S. Patent
`
`No. 7,808,184 (the “’184 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.
`
`3.
`
`The list of materials I considered in forming the opinions set
`
`forth in this declaration includes the ‘184 patent, the file history of the ‘184
`
`patent, the Petitions for Inter Partes Review and the exhibits, the PTAB’s
`
`Institution Decisions, and the 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
`
`1
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`design, and plasma processing of materials. I made significant contributions
`
`to the development of magnetron sputtering hardware and processes for the
`
`metallization 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.
`
`2
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`Since then, I have been consulting full time doing business as UA
`
`Associates, where my consulting work includes product development
`
`projects, film failure analysis, project management, technical presentations
`
`and litigation support.
`
`7.
`
`Throughout my career, I have developed and/or demonstrated
`
`processes and equipment for making thin films, including Al, Ti-W, Ta, and
`
`Cu metallization of silicon wafers, RF sputtering and etching, and both RF
`
`and dc magnetron reactive sputtering, for example SiO2, Al2O3, ITO
`
`(Indium-Tin Oxide), TiN, and TaN. I have been in charge of the
`
`development of two sputter deposition systems from conception to prototype
`
`and release to manufacturing. I have also specialized in the development and
`
`improvement of magnetically enhanced sputter cathodes. I have experience
`
`with related technology areas, such as wafer heating, 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.
`
`3
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`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 Semiconductor Technical Advisory
`
`Committee.
`
`9.
`
`I have co-authored many papers, reports, and presentations
`
`relating to 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).
`
`10. 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 Exhibit A.
`
`4
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`II. Summary of Opinions: Claims 1 - 20
`In my opinion, the plasma generation methods described in
`
`11.
`
`claims 1 through 20 of the ‘184 patent are neither taught by Wang and
`
`Kudryavtsev, nor are obvious in view of them.
`
`12. Neither Wang nor Kudryavtsev teach the claimed method that
`
`generates at least one of a controlled voltage amplitude or voltage rise time
`
`to form a strongly-ionized plasma without forming an arc. Wang does not
`
`teach controlling voltage at all, but instead teaches controlling power pulses
`
`to a desired power level. As I explain below, such control of a pulse’s
`
`power level is very different from controlling the voltage amplitude and rise
`
`time of a pulse. Any voltage pulses disclosed by Wang are merely a
`
`consequence of the system attempting to deliver the desired power level, i.e.,
`
`the voltage (and current) are driven by the power supply of Wang based
`
`upon the desired power level but are determined by the plasma impedance.
`
`13. Moreover, Wang does not teach pulsing at all without forming
`
`an arc. Wang’s controlled power level pulses will cause an arc condition
`
`when used to ignite a plasma. The ‘184 patent, in contrast, shows many
`
`examples of pulses whose voltage amplitude and rise time are controlled so
`
`that they can ignite plasma without arcing. The control of pulse voltage
`
`amplitude/rise time are very different from controlling pulse power level,
`
`5
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`and such control has advantages that Wang overlooked.
`
`14. Kudryavtsev also does not teach the claimed power supply or
`
`suggest it, even if its teachings are considered together with those of Wang.
`
`Importantly, the system of Kudryavtsev is a flash tube which is designed to
`
`apply a high voltage greater than the breakdown voltage across an inert gas,
`
`resulting in a brilliant flash of light for a short duration. Flash tubes apply a
`
`voltage greater than the breakdown voltage, which may initiate the flash by
`
`an arc between the cathode and the anode.
`
`15. Kudryavtsev describes a voltage pulse
`
`that causes an
`
`“explosion” in electron density that appears to cause an arcing condition as
`
`shown in his measured voltage and current waveforms. In fact, the paper
`
`cited by Mr. DeVito to explain arcing includes a waveform which
`
`demonstrates arcing, and this waveform shows similar conditions to those
`
`shown by Kudryavtsev. Thus, the flash tube of Kudryavtsev is designed to,
`
`and likely does in fact, form an arc which initiates its “explosive” increase in
`
`electron density and its brilliant flash of light. A person of ordinary skill in
`
`the art would therefore not refer to Kudryavtsev at all when designing a
`
`plasma generator whose very purpose is to form a strongly-ionized plasma
`
`without forming an arc.
`
`16. Thus, for these reasons and the reasons described below, a
`
`6
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`person of ordinary skill in the art would look to neither the Wang nor
`
`Kudryavtsev references in attempting to design the claimed invention of
`
`generating a strongly-ionized plasma using a voltage pulse with a controlled
`
`rise time or amplitude to form a strongly-ionized plasma without forming an
`
`arc. Wang does not teach a person of ordinary skill in the art how to
`
`generate such a voltage pulse to avoid arcing, and the flash tube of
`
`Kudryavtsev is designed with arcing as a desirable condition, putting it at
`
`odds with the very purpose of the ‘184 patent.
`
`III. Legal Standards
`In this section I describe my understanding of certain legal
`
`17.
`
`standards. I have been informed of these legal standards by Zond’s
`
`attorneys. I am not an attorney and I am relying only on instructions from
`
`Zond’s attorneys for these legal standards.
`
`A. Level of Ordinary Skill in the Art
`18.
`
`I understand that a person of ordinary skill in the art provides a
`
`reference point from which the prior art and claimed invention should be
`
`viewed. This reference point prevents one from using his or her own insight
`
`or hindsight in deciding whether a claim is obvious.
`
`19.
`
`In my opinion, given the disclosure of the ‘184 patent and the
`
`disclosure of the prior art references considered here, I consider a person of
`
`7
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`ordinary skill in the art at the time of filing of the ‘184 patent to be someone
`
`who holds at least a 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 requirements for one of
`
`ordinary skill in the art at the time of the invention and continue to meet
`
`and/or exceed those requirements.
`
`B. Claim Interpretation Issues for Claims 1 - 20
`20.
`
`I understand that the Board tentatively construed the following
`
`language of claims 1 - 20:
`
`1.
`2.
`
`“Strongly ionized plasma;” and
`“Generating a voltage pulse … having at least one of a
`controlled amplitude and a controlled rise time …”
`
`
`
`21. The Board construed “strongly-ionized plasma” as “a plasma
`
`with a relatively high peak density of ions.”1 For purposes of this analysis, I
`
`have used this interpretation.
`
`22. The Board construed the above “pulse control” terminology as
`
`
`1 IPR2014-00799, Decision at p. 11; IPR 2014-00803, Decision at p. 11.
`
`8
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`proposed by Zond and reproduced below:2
`
`Generating a voltage pulse whose amplitude and/or rise time
`are directed or restrained to increase an ionization rate so that a
`rapid increase in electron density and a formation of a strongly
`ionized plasma occurs without forming an arc.
`
`However, I understand that the Board also concluded that the claimed pulse
`
`control encompasses any change in voltage amplitude that is incidental to
`
`directing a pulse to a target power level (or set point) as in Wang, regardless
`
`of whether the voltage amplitude is the parameter under control. Therefore,
`
`Zond has proposed the following clarification to the Board’s tentative
`
`construction:
`
`Claim Language at Issue
`Generating a voltage pulse … having
`at least one of a controlled amplitude
`and a controlled rise time that
`increases an ionization rate so that a
`rapid increase in electron density and
`a formation of a strongly ionized
`plasma occurs without forming an arc
`…”
`
`Proposed Construction
`Generating a voltage pulse whose
`amplitude and/or rise time are
`controlled variables that are directed
`or restrained to a target voltage level
`and/or a rise time level to increase an
`ionization rate so that a rapid increase
`in electron density and a formation of a
`strongly ionized plasma occurs without
`forming an arc.
`
`
`2 IPR2014-00799, Decision at p. 12; IPR 2014-00803, Decision at p. 12.
`
`9
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`For purposes of this declaration, I have used the proposed clarified
`
`interpretation, which is consistent with my understanding of the language
`
`and the specification.
`
`C. Legal Standards for Anticipation
`
`23.
`
`I understand that a claim is anticipated under 35 U.S.C. § 102 if
`
`(i) each and 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 arranged in the prior art reference in the same way as
`
`recited in the claims at issue.
`
`D. Legal Standards for Obviousness
`24.
`
`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, the scope and content of the prior art, the differences between
`
`the prior art and the claims, and any secondary evidence of non-obviousness.
`
`I have not been asked to study or analyze any secondary considerations of
`
`non-obviousness. As discussed further below, the Wang and Kudryavtsev
`
`prior art references describe systems that are so far different than what is
`
`claimed that they do not form the basis for an obviousness determination of
`
`10
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`the claimed subject matter.
`
`25.
`
`I understand that even if a patent is not anticipated, it is still
`
`invalid if 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.
`
`26.
`
`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 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.”
`
`27.
`
`I have been informed and understand that the obviousness
`
`11
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`analysis requires a comparison of the properly construed claim language to
`
`the prior art on a limitation-by-limitation basis.
`
`IV. Background Topics
`
`28. The ‘184 patent describes a system for forming a strongly
`
`ionized plasma using a controlled voltage pulse. The pulse’s amplitude
`
`and/or rise time is controlled to increase an ionization rate so that a rapid
`
`increase in electron density and a formation of a strongly-ionized plasma
`
`occurs without forming an arc.
`
`29. The prior art references cited in the Petition and the Board’s
`
`Decision (Wang and Kudryavtsev) describe pulses for generating a plasma,
`
`but do not disclose the type of “control” described in the ‘184 patent and its
`
`claims.
`
`30. The ‘184 patent describes a system that controls the amplitude
`
`of a voltage pulse and the rise time of that voltage to achieve certain plasma
`
`conditions that I will discuss ahead.
`
` But to provide context for
`
`understanding the issues identified in the Board’s Decision and addressed in
`
`this report, I briefly review well-known, basic relationships between voltage,
`
`current, impedance and power. I also review some basic concepts of control
`
`systems, such as used to control the output of power supplies for magnetron
`
`sputtering. I then give a brief overview of magnetron sputtering before
`
`12
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`discussing the ‘184 patent and the prior art.
`
`A. Voltage, current, impedance and power
`31. 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 impedance. For purely resistive impedance, the relation
`
`between the voltage and the resultant current is given by: V = I * R
`
`32. A common analogy is that voltage is like a pressure that causes
`
`charge particles like electrons and ions to flow (i.e., current), and the amount
`
`of current depends on the magnitude of the pressure (voltage) and the
`
`amount of resistance or impedance that inhibits the flow. The ‘184 patent
`
`and the prior art considered here involve the flow of current through an
`
`assembly having a pair of electrodes with a plasma in the region between
`
`them. The effective impedance of such an assembly varies greatly with the
`
`density of charged particles in the region between the electrodes. Although
`
`such an impedance is more complex than the simple resistive impedance of
`
`the above equation, the general relation is similar: a voltage between the
`
`electrode assembly forces a current to flow through the plasma, such that the
`
`amount of current is determined by the amplitude of the voltage and the
`
`impedance of the plasma. Thus, the current through the electrode assembly
`
`increases with the electrode voltage and, for a given electrode voltage, the
`
`13
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`current will increase with a drop in the impedance of the plasma.
`
`33. The impedance varies with the charge density of the plasma:
`
`With a high density of charged particle the impedance is relatively small,
`
`and with a low density of charge particles the impedance is relatively large.
`
`Simply, the more ions and electrons to carry the charge, the less resistance.
`
`However, the charges and fields react with each other in a very complicated
`
`manner.
`
`34.
`
`In response to the electric field in the region between the
`
`electrodes (i.e., the voltage across the electrodes), all charged particles in the
`
`region (the electrons and positive ions) feel a force that propels them to
`
`flow. This flow is an electric current “I.” Obviously, the amount of current
`
`depends upon the number of charged particles. When there are no charged
`
`particles (i.e., no plasma), there is no current flow in response to the electric
`
`field. In this condition, the impendence of the electrode assembly is
`
`extremely high, like that of an open circuit. But when there is a dense
`
`plasma between the electrodes (with many charged particles), a substantial
`
`current will flow in response to the electric field. In this condition, the
`
`impendence 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 impedance is effectively infinite (an open circuit) when
`
`14
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`there is no plasma, and is very low when the charge density is very high.
`
`35.
`
` It is also well known that electric power (P) is the product of
`
`voltage (V) and current (I): P = V * I. Thus, for a given voltage across an
`
`electrode assembly, the amount of power will depend on the amount of
`
`corresponding current flowing through the electrode assembly. If there is
`
`no current flow (such as when there is no plasma between the electrodes),
`
`the power is zero, even if the voltage across the electrodes is very large.
`
`Similarly, at very low electrode voltages, the power can still be quite high if
`
`the current is large.
`
`36. The claims of the ‘184 patent refer to “a controlled amplitude”
`
`of a voltage pulse and a “controlled rise time” of the voltage pulse. The
`
`‘184 patent describes many examples of such control and how a
`
`programmable power supply can be used to achieve this control. I will
`
`describe these examples from the ‘184 patent ahead.
`
`37. But first, to provide context for understanding this aspect of the
`
`‘184 patent, I consider below some known basic principles of control
`
`systems (such as used in all power supplies and all such control systems) for
`
`controlling a parameter such as voltage amplitude.
`
`B. Control systems
`38. The programmable power supply mentioned in the ‘184 patent
`
`15
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`is an example of a control system. This system controls the voltage
`
`amplitude of a voltage pulse. A simplified block diagram of a common
`
`feedback control system is shown the figure below from a text by Eronini.3
`
`
`
`
`
`Figure 1 Control system simplified block diagram
`39. The “reference input signal” represents a “desired value” or
`
`“set-point” of the controller. The control system directly controls 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 control system directs the controlled variable in an attempt to
`
`reduce the difference to zero, thereby causing the controlled variable to
`
`equal the set point value.
`
`3 Ex. 2021, Eronini Umez-Eronini, System Dynamics and Control, Brooks
`Cole Publishing Co., CA, 1999, pp. 10-13.
`
`16
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`40. For example, the set-point for filling a water tank may be 1,000
`
`gallons, or full. The desired value, set-point or desired level is the value
`
`“full” or “1000 gallons.” An open loop control system might just fill the
`
`tank for a pre-calibrated time that result in the tank being full. The control
`
`system might be set to fill the tank once per day based on historical water
`
`usage. However, if water usage is not consistent, the tank may run empty
`
`before it is filled, or may overflow because 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 level, and only adds
`
`the needed amount. It might have a switch or sensor that detects when the
`
`tank is full, and turns off the flow of water. The set-point is the desired
`
`value. “Here the comparison of the tank level signal with the desired value
`
`of the tank level (entered into the system as a set-point setting) and the
`
`turning of the pump on or off are all performed by appropriate hardware in
`
`the controller.” 4 Further, a closed loop system could be left on to fill the
`
`tank if the level dropped too low. “In feedback control, a measurement of the
`
`output of a system is used to modify its input in such a way that the output
`
`
`4 Ex. 2021, Eronini Umez-Eronini, System Dynamics and Control, Brooks
`Cole Publishing Co., CA, 1999, pp. 10-13.
`
`17
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`stays near the desired value5.”
`
`Set point (Controlled Parameter)
`
`C.
`41. The parameter that is directed to a desired value is called the
`
`“controlled variable,” as shown in the figure from Eronini. Eronini’s
`
`diagram also shows that while controlling the “controlled variable,” the
`
`system may “manipulate” another control parameter that Eronini calls the
`
`“manipulated variable.”
`
`42. This terminology is commonly used in other references that
`
`describe control systems. A reference by Weyrick, for example, uses the
`
`same terminology as Eronini:
`
`• “The controlled output is the process quantity being controlled.”
`
`• “The manipulated variable is the control signal which the control
`
`elements process.”6
`
`43. Similarly, Kua and Sinka also show that the “controlled
`
`parameter” is widely understood to mean the parameter being controlled by
`
`the control system.7
`
`
`
`44. With this understanding, I now consider the difference between
`
`5 Ex. 2021, Eronini Umez-Eronini, p. 12.
`6 Ex. 2011, Weyrick at 13
`7 Ex. 2012, Kua; Ex. 2013, Sinka.
`
`18
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`controlling the amplitude of a voltage and controlling the power.
`
`Power Control vs Voltage Control
`
`D.
`45. 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. In a system for controlling voltage, the set
`
`point is a specified voltage and the “controlled variable” obviously is
`
`voltage. Thus, in a 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 point.” Based on the difference between the
`
`measured voltage and the desired voltage or set point, the control system
`
`drives or restrains the voltage in an attempt to move the actual voltage to
`
`match the desired voltage.
`
`46.
`
`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 can be driven by the control system to whatever levels
`
`are needed to achieve the target power level. Thus, in the example of a
`
`system for controlling the power of a plasma electrode assembly, if there is
`
`no plasma between the electrodes (and therefore little or no current) a
`
`controller attempting to achieve a target power level will drive the voltage
`
`extremely high in an attempt to achieve the target power P, i.e., P = V * I,
`
`19
`
`TSMC et al. v. Zond IPR2014-00799
`Zond Ex. 2015
`
`

`
`
`
`(because I is very low or zero in this situation).
`
`47.
`
` Thus, in a control system for controlling power to a desired set
`
`point, voltage will vary as the controller attempts to achieve the desired
`
`power level (i.e., a desired product of voltage and current). However, the
`
`amplitude of the voltage is not controlled and instead the voltage and/or the
`
`current vary as needed to achieve the desired power.
`
`48. The rise time of a voltage therefore is a different pa