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`Page 1
` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________
`THE GILLETTE COMPANY, Cases: IPR2014-00477
` Petitioner, IPR2014-00479
` v. Patent 8,125,155 B2
`ZOND, INC.,
` Patent Owner.
`__________________________
`
` VIDEOTAPED DEPOSITION of RICHARD DeVITO
` Boston, Massachusetts
` November 20, 2014
`
`Reported by:
`Dana Welch, CSR, RPR, CRR, CBC, CCP
`Job #87397
`
`TSG Reporting - Worldwide 877-702-9580
`
`TSMC et. at. v. Zond, IPR2014-00800
`Page 1 Exhibit 2014
`
`

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`Page 2
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`Page 3
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`1 APPEARANCES:
`2
`For Zond, LLC:
`3
`RADULESCU
`4
`350 Fifth Avenue
`5 New York, NY 10118
`6
`BY: ETAI LAHAV, ESQ.
`
`78
`
`9
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`CHAO HADIDI STARK & BARKER
`11
`176 East Main Street
`12 Westborough, MA 01581
`13
`BY: BRUCE BARKER, ESQ.
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`For The Gillette Company:
`18 WILMERHALE
`19
`1875 Pennsylvania Avenue, N.W.
`20 Washington, D.C. 20006
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`BY: DAVID CAVANAUGH, ESQ.
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`- AND -
`
`--- appearances continue ---
`
`Page 5
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` November 20, 2014
` 9:40 a.m.
`
` Videotaped deposition of RICHARD DeVITO,
`held at the offices of WilmerHale, 60 State Street,
`Boston, Massachusetts, before Dana Welch, Certified
`Shorthand Reporter, Registered Professional
`Reporter, Certified Realtime Reporter and Notary
`Public of the Commonwealth of Massachusetts.
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`APPEARANCES (continued)
`2
`For The Gillette Company:
`3 WILMERHALE
`4
`60 State Street
`5
`Boston, MA 02109
`6
`BY: LARISSA BIFANO PARK, ESQ.
`
`1 APPEARANCES (continued)
`2 HAYNES AND BOONE
`3
`2505 North Plano Road
`4
`Richardson, TX 75082
`5
`BY: GREGORY HUH, ESQ.
`
`6789
`
`For Taiwan Semiconductor Manufacturing Company,
`Ltd. and TSMC North America Corporation:
`HAYNES AND BOONE
`2323 Victory Avenue
`Dallas, TX 75219
`BY: DAVID McCOMBS, ESQ.
`
`HAYNES AND BOONE
`1221 McKinney
`Houston, TX 77010
`BY: DONALD JACKSON, ESQ.
`
`--- appearances continue ---
`
`10 Also Present: David Woodford, Videographer
`11
` Joann Pappas, The Gillette Company
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`TSMC et. at. v. Zond, IPR2014-00800
`Page 2 Exhibit 2014
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`

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`Page 6
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`Page 7
`
`1
` DeVITO
`2
` P R O C E E D I N G S
`3
` THE VIDEOGRAPHER: This is tape number one
`4
`to the videotaped deposition of Richard DeVito.
`5
`This is in the matter of The Gillette Company,
`6
`petitioner, versus Zond LLC, patent owner, Case
`7
`IPR2014-00479 and also Case IPR2014-00477 for
`8
`Patent 8,125,155 B2. This is in the U.S. Patent
`9
`and Trademark Office before the Patent and Trial
`10
`Appeal Board.
`11
` This deposition is being held at the firm
`12
`of WilmerHale at 60 State Street, Boston,
`13 Massachusetts on November 20th, 2014 beginning at
`14
`9:40 a.m.
`15
` My name is David Woodford. I am the legal
`16
`video specialist from TSG Reporting, Inc.,
`17
`headquartered at 747 Third Avenue, New York, New
`18
`York. The court reporter is Dana Welch, in
`19
`association with TSG Reporting.
`20
` Will counsel present please introduce
`21
`yourselves and the witness will be sworn.
`22
` MR. LAHAV: Etai Lahav of Radulescu LLP
`23
`representing patent owner Zond.
`24
` MR. BARKER: This is Bruce Barker from
`25
`Chao Hadidi Stark & Barker also for Zond.
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`Page 8
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` DeVITO
` address for the record.
` A. Richard DeVito, 11 Parkside Drive, Jamaica
` Plain, Massachusetts.
` Q. Have you ever given a deposition before?
` A. In a divorce case years ago.
` Q. Apart from the divorce case years ago,
` have you ever given a deposition?
` A. No.
` Q. So before we begin in earnest, I'll go
` over some rules of deposition; is that all right?
` A. (Nodding head up and down.)
` Q. Do you understand that I'm going to be
` asking you questions?
` A. Yes.
` Q. And do you understand you have an
` obligation to answer my questions?
` A. I do.
` Q. Do you understand that from time to time
` your attorney my object to my questions?
` A. I do.
` Q. Do you understand that nevertheless you
` have an obligation to answer those questions?
` A. I do.
` Q. The only instance where you do not have to
`
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` DeVITO
` MR. CAVANAUGH: David Cavanaugh of
` WilmerHale representing Gillette.
` MS. PARK: Larissa Park of WilmerHale
` representing Gillette.
` MS. PAPPAS: Joann Pappas, from Gillette.
` MR. HUH: Gregory Huh of Haynes and Boone,
` representing TSMC.
` MR. JACKSON: Don Jackson, representing
` TSMC.
` MR. McCOMBS: David McCombs, representing
` TSMC.
` RICHARD DeVITO, sworn
` MR. LAHAV: And before we begin with the
` testimony, I note that counsel for TSMC is here and
` we don't have any objection to your presence, but
` we do object to you speaking on the record since
` it's Gillette's petition. Hopefully that won't be
` an issue, but if it does, I guess we can talk about
` it later.
` EXAMINATION
`BY MR. LAHAV:
` Q. Good morning, Mr. DeVito.
` A. Good morning.
` Q. Will you please state your full name and
`
`Page 9
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` DeVITO
` answer my question is if the attorney objects for
` attorney/client privilege or work product. Do you
` understand that?
` A. I do.
` Q. If you need a break at any time, please
` let me know and we'll be happy to go on a break.
` A. Okay. Thank you.
` Q. One exception to that is if there is a
` question pending, then I'll insist on an answer
` before we take a break. Is that okay?
` A. Understood.
` Q. If I ask you a question that you don't
` understand, can you please let me know and I'll
` rephrase.
` A. Okay. Great.
` Q. If you answer a question, I'm going to
` assume you understood it; is that all right?
` A. Okay.
` Q. You understand you just took an oath to
` tell the truth?
` A. I do.
` Q. You will tell the truth today?
` A. I will.
` Q. Are you taking any medication today that
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` DeVITO
` would impair your ability to testify truthfully?
` A. I am not.
` Q. Is there any other reason why you are not
` able to testify truthfully today?
` A. There is not.
` Q. Please describe your post high school
` education.
` A. I have a degree in physics from Suffolk
` University and a master's degree in physics --
` experimental solid state physics from Syracuse
` University.
` Q. In your bachelor's degree, did you ever
` take any classes in plasma physics?
` A. Not plasma physics, per se, no.
` Q. And in your graduate work, did you take
` any plasma physics classes?
` A. Not plasma physics, per se, no.
` Q. Did you take any classes in either
` bachelor's or master's relating to sputter
` deposition?
` A. I did not, no.
` Q. Any classes on any PVD process?
` A. No.
` Q. In the CV that you submitted along with
`Page 12
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` DeVITO
` your declaration, you begin your experience in --
` your commercial experience in 1987; is that fair?
` A. Sounds about right.
` At Litton?
` Q. Yeah.
` And so from 1987 to 1994 you were employed
` by Litton?
` A. I'd have to see, but it sounds about
` right.
` Q. Okay. And what were your responsibilities
` at Litton?
` A. Well, they were varied.
` Do you just want to know about the
` thin-film stuff or PVD stuff?
` Q. Why don't you tell me about the PVD stuff.
` A. Okay. So PVD, I was involved in ion beam
` deposition, ion beam etching; PVD, I was involved
` in some sputtering as well, as well as plasma CVD,
` plasma enhanced CVD.
` Q. And what do you mean involved with?
` A. I was the lead researcher on those
` programs.
` Q. What did those programs relate to?
` A. So in the plasma CVD work we were
`Page 13
`
` DeVITO
` making -- and also there was sputtering work, we're
` making infrared transmitting windows that were
` resistant to scratching in planes basically,
` fighter jets.
` Q. And what specifically was the focus of
` your research with respect to the plasma CVD?
` A. So there was sputtering and plasma CVD.
` So in both work, we were trying to come up with
` compounds that were transmitting in the infrared
` and also were very robust and tough in terms of the
` environment, because they were being used mainly in
` the desert. So for example, germanium carbide,
` silicon carbide, these are the types of materials
` we were trying to deposit using RF and DC
` sputtering and also plasma enhanced CVD.
` Q. So you were investigating target
` materials?
` A. Well, we would use different targets to
` get the films.
` Q. And did you do any research into
` appropriate pressures or power to be used for the
` deposition?
` A. We investigated the entire space using
` design of experiments.
`
` DeVITO
` Q. And in your specific role in that
` research, did that relate to the investigation of
` the pressures and other operating conditions of the
` deposition chamber?
` A. I designed the experiments and I actually
` ran the machine. At first I didn't have a
` technician; later on I did have a technician. But
` I was very hands-on. I'm always hands-on.
` Q. What do you mean by "designed the
` experiments"?
` A. So if someone wants to figure out, for
` example, what -- you look at the pressure, you look
` at the power, you look at the energetics, and you
` design experiments around those variables to get a
` range of experiments that you can test.
` Q. What do you mean by "energetics"?
` A. So in the plasma, whether it's PECVD or
` whether it's sputtering, you have a range of
` energetics, so the incoming energy of the atoms or
` the ions.
` Q. So by "energetics," you mean the energy of
` atoms or ions?
` A. Correct.
` Q. And you said you did some work in ion beam
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` DeVITO
` deposition?
` A. Correct.
` Q. And what was that?
` A. One second.
` So one of the ways to increase the density
` of the film is to apply an ion beam directly to the
` substrate while the film is growing on it, so we
` call that ion beam-assisted deposition.
` Q. And what was the application you were
` researching?
` A. So all these -- my entire thin-film focus
` from the company was to enhance the hardness,
` enhance the durability of these films that were
` transmitting in the infrared, for example, as I
` said, silicon carbide, germanium carbide, and
` diamond-like carbon.
` Q. So all of your thin-film work related to
` that application, correct?
` A. At Itek, yes -- or Litton, sorry.
` Q. And so what's the relationship between
` Litton and Itek?
` A. So Litton Industries was the conglomerate
` that owned Itek.
` Q. So you had always worked for Itek or did
`Page 16
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` DeVITO
` Q. You may. That means I have to now go
` searching for an exhibit.
` A. I'm hoping it's in back of one of the
` depositions.
` Q. I just want to make sure I'm seeking out
` the right declaration. I may have to mark several
` of them.
` I'm handing you what already bears an
` Exhibit Number 1005 in the '477 proceeding.
` A. Okay. Great.
` Q. Before we go to the pending question, can
` you please confirm that Exhibit 1005 is a
` declaration that you signed in connection with the
` '477 petition?
` A. Yes.
` Q. And so back to the question, we're looking
` for the name of the company that you worked with to
` design the chamber when you were working at
` Litton-Itek
` A. I'm sorry. I don't see it here.
` Q. Okay. Did you design the magnet for the
` chamber?
` A. The magnetron? No.
` Q. Who designed the magnetron?
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` DeVITO
` Litton acquire Itek while you were employed there?
` A. I believe several months before I joined
` they had purchased Itek Optical Systems.
` Q. Did any of your work at Litton-Itek
` involve magnetron sputtering?
` A. Yes.
` Q. And what we just discussed, was that
` magnetron sputtering?
` A. Yes. For example, the silicon carbide and
` germanium carbide were magnetron sputtering.
` Q. Any other magnetron sputtering experience
` at Litton-Itek?
` A. Just that.
` Q. Do you remember the chamber that you used?
` A. Yes. I designed the chamber.
` Q. Okay. So it was -- it wasn't a commercial
` chamber, it's one you designed from the ground up?
` A. We worked with a company that's no longer
` in existence to design that chamber, yes. It was
` designed to my specifications.
` Q. What was the name of the company?
` A. It's been so long ago.
` Is it in the -- can I check my CV to see
` if it's in there?
`
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` DeVITO
` A. It was a company called S/Gun out in
` Stanford, California.
` Q. Did you design the power supply for the
` chamber?
` A. I did not.
` Q. Do you know what power supply you used?
` A. I believe it was ENI.
` Q. Is that E and I or ENI?
` A. Capital E capital N capital I.
` Q. Do you remember the operating
` characteristics of that power supply?
` A. Oh, gosh, all I can tell you, it was an RF
` supply, that's all I remember. I don't know the
` maximum power.
` Q. Were there any other power supplies used
` for that chamber?
` A. We did have a DC power supply as well.
` Q. Did you design the DC power supply?
` A. No.
` Q. And who provided that?
` A. Advanced Energy.
` Q. AE?
` A. AE, yes.
` Q. Yeah.
`
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` And do you know the make and the name of
` that power supply?
` A. It was an MDX, I believe it was a 5
` kilowatt.
` Q. Do you remember the voltage or current
` ratings on that?
` A. For 5 kilowatt? Typically, the 85
` kilowatt, the maximum is a thousand volts; the
` current, I don't know.
` Q. Okay. So let me try and just to -- you
` said "5 kilowatt" and then you referenced 85
` kilowatt?
` A. Oh, did I say 85. No.
` Q. Okay. I just -- that's what I heard
` and --
` A. Okay. Sorry.
` Q. -- the court reporter had.
` So for 5-kilowatt, typically it's a
` thousand volts?
` A. Yeah, is the max.
` Q. This company that you worked with to
` design the chamber when you were at Litton-Itek,
` did they start with a template chamber that you
` then customized pieces of or did you design it from
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` first principles?
` A. I guess it was a combination of both. So
` basically, what my instructions to them, as I
` recall, was I needed -- so basically, we had three
` magnetrons -- I'm sorry -- two magnetrons all
` pointed at the substrate, concentrically -- you
` know, concentrically pointed at the substrate, and
` at the top was that PECVD ion source, which was
` also used for deposition as well. It was called
` ECR, capital E, capital C, capital R, ion source.
` And we gave specifications that we had to
` have a substrate, a cooler, cooling and heating,
` and base vacuum, and we had an envelope that we had
` to work within, and out from that came the design
` of the chamber.
` Q. When you say you had an envelope that you
` had to work within, what do you mean by that?
` A. So we needed to have a certain size
` substrate, and basically, the size of the magnetron
` dictates the uniformity you can have. And one of
` the ways to get uniformity is to get a certain
` distance to the substrate from the targets, from
` the magnetrons. And so we needed to have a certain
` range, and based on that range, the distance, that
`Page 21
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` DeVITO
` determined the envelope of the chamber. You don't
` want to have -- you don't want to have to pump out
` any more chamber than you have to, so you want it
` as small as possible to do the job.
` Q. And so by "envelope," is that like volume
` of the chamber?
` A. Volume, correct.
` MR. CAVANAUGH: Just before you go into
` another question, if I can interject, that anything
` about your background for these companies that you
` worked with is confidential shouldn't be shared
` because there is no protective order.
` THE WITNESS: Right.
` MR. CAVANAUGH: So at a high level,
` answering questions about kind of what it is you
` did there, to the extent that it gets into
` confidential information that a company would
` consider proprietary, I'd ask you not to -- if it's
` under a confidentiality agreement, then you should
` respect the confidentiality agreement.
` THE WITNESS: Well, I won't give him
` recipes for how we did the films for sure, so...
` MR. CAVANAUGH: Thank you.
` MR. LAHAV: I agree with that comment.
`
` DeVITO
` Okay. Got it.
` Q. Do not divulge any confidential
` information that you have an obligation not to
` divulge, but apart from that, I would appreciate,
` you know, candid and forthcoming answers as you've
` been giving thus far.
` Was the chamber that you helped design at
` Litton-Itek, was that a high power deposition
` chamber?
` A. What do you mean by high power?
` Q. Are you familiar with HiPIMS?
` A. I am.
` Q. What's a HiPIM?
` A. A HiPIM is the process of actually
` generating, either through a high pulse power
` supply or a high power density power supply, highly
` ionized sputter plasma where a large fraction of
` the metal ions are actually sputtered.
` Q. What do you mean by "high pulse power
` supply"?
` A. So the ratio of -- so the ratio of the
` power density of the target has to be above a
` certain limit, so until you get, you know,
` substantial ionization of the atoms.
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` Q. What limit is that?
` MR. CAVANAUGH: Object to the form.
` A. Well, based on the literature, you know, I
` would have to say, you know, greater than .5, .6
` amps per -- I'm sorry. I have to look at the
` declaration to see what I wrote down. Just give me
` a few minutes.
` Q. Sure.
` A. So the limit, you know, it varies, it
` depends on the diameter of the -- I'm sorry -- the
` diameter of the target and the application of the
` power to get a certain power density. So for
` example, if you're asking is it 10 percent or
` 20 percent or 30 percent of the metal ions are
` ionized, it depends, so...
` Q. So I just want to understand the answer
` that you gave a minute ago. I asked you what you
` meant by "high pulse power supply," and you said
` that "the ratio of the power density of the target
` has to be above a certain limit." And so I'm
` trying to figure out what that limit is. If you
` can't give a number, then if you want to describe
` kind of what it depends on.
` A. Well, I mean, if you have a certain
`
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` DeVITO
` Q. Are you saying that you can have HiPIMS
` with very low ionization?
` A. No.
` Q. Okay.
` A. Okay. So do you mean more than 50
` percent? I mean --
` Q. I'm asking you.
` A. Yeah.
` Q. You made a comment about HiPIMS and you
` said that the power density has to be above some
` threshold.
` A. Uh-huh.
` Q. And I understand that might depend on
` things, but there has to be, you know, some that
` you acknowledge that it can't be low ionization.
` A. Right. Right.
` Q. So there's some minimum for what a HiPIM
` is, and I'm asking if you could please supply that.
` MR. CAVANAUGH: Object to the form.
` MR. LAHAV: And it's a fair objection
` because it's a very long question, so I'm just
` going to rephrase it, and begin now.
` Q. What is the minimum threshold power
` density for a HiPIM?
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` DeVITO
` diameter, so the power density is the power applied
` by the area of the target. So depending on the
` target size and depending on what you mean by what
` fraction of the ionized particles are, it could be
` a very low power density or it could be extremely
` high power density, for example, between a
` three-inch target and an eight-inch target.
` Q. So are you saying that HiPIMS can use low
` power density?
` A. No. It has to be a certain Hi -- power --
` I'm sorry -- the power -- the power density is
` constant, but it's the power.
` Q. And so what I'm asking is, I understand
` that the size of the target can vary.
` A. Correct.
` Q. The question is -- but that's a ratio --
` A. Right.
` Q. -- so you're saying that the density has
` to be high. I'm asking, what is the threshold for
` high?
` A. Well, what's the --
` MR. CAVANAUGH: Objection to form.
` A. What fraction of ionization are you
` talking about? So, there could be a range.
`
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` DeVITO
` MR. CAVANAUGH: Objection to form.
` A. I don't know if I can give you any one
` number. You know, it also depends on the target
` materials. So it's tough to nail down for -- as a
` general -- as a general number for, you know, if
` depending on the -- it depends on the pressure,
` depends on the target materials, so I just can't
` give you a straight answer. It's too general.
` Q. Okay. One millitorr copper?
` A. I'd have to look at the literature for
` that specific -- that specific example.
` Q. And you have no understanding, sitting
` here today, about a general range of power
` densities that are appropriate to be called HiPIMS;
` is that right?
` A. Well, the literature gives a range, but
` you know, if you -- you have to look at each
` specific paper in the context, right? So we do
` talk about it in here, but it's in the context of
` off these patents, not just a general purpose
` number, right?
` Q. So you don't have a general understanding
` of the power densities used in HiPIM; is that
` correct?
`
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` DeVITO
` MR. CAVANAUGH: Objection to form.
` A. That's not a true statement. So I mean,
` if I were pressed, I would say based on the
` literature that I've read and kept up to speed on
` HiPIMS, that they all seem to suggest -- we have it
` down here somewhere, I can give you what we wrote.
` Just give me a second.
` I know it's in here. So we talk about and
` the literature talks about, you know, around 250,
` 300 watts per centimeter squared.
` Q. And could you have a HiPIM that has a
` power density of 200 watts per centimeter square?
` A. I mean, it depends on -- I'd have to see
` what fraction of the -- I mean, I can't answer that
` question the way it's posed because, you know,
` HiPIMS means -- to me it means that you have to
` have like at least greater than 50 percent of the
` particles ionized and I, you know --
` Q. So with that constraint, I know that's
` your understanding of HiPIMS, could you have a
` HiPIM that has a power density of 200 watts per
` centimeter squared?
` MR. CAVANAUGH: Objection to form.
` A. I don't know if I can answer that
`
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` DeVITO
` question. Could you repeat it?
` Q. Sure.
` I asked you could you have a HiPIM that
` has a power density of 200 watts per centimeter
` squared.
` A. Given the fact we talked about 250 to 300
` or 350? We just talked about 250 to 350 being a
` typical range for HiPIMS, right? Now you're asking
` me about 200?
` Q. Yes.
` A. I mean -- I mean, I don't know the answer
` to that question. I mean, it's very subjective in
` terms of the target material. You're getting down
` to sort of the low end now and it depends on, you
` know, for some people that may be considered HiPIMS
` depending on what they're looking to do.
` Q. You're saying whether something is HiPIM
` is a subjective criteria?
` A. Well, if they're looking to fill holes or
` vias or something like that, they maybe don't need
` 70 percent, 80 percent, right?
` Q. So maybe they don't need a HiPIM.
` A. It depends. I mean, for them it may be
` HiPIM, you know.
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` DeVITO
` Q. Would anyone call a system that has a 150
` watts per centimeter squares a HiPIM?
` MR. CAVANAUGH: Objection to form.
` A. I don't know what they would say.
` Q. If you have at least 50 percent of the
` particles ionized and there is a --
` A. Of the metal ions -- of the metal atoms.
` Q. If you have a system with at least
` 50 percent of the metal ions ionized and you have a
` power density of 250 watts per centimeter squared,
` could that system not be a HiPIM?
` MR. CAVANAUGH: Objection.
` A. I mean, I would need more information in
` terms of the operating pressure and stuff like
` that. But I mean, I guess some people would
` consider it, maybe some people wouldn't. I would
` consider it.
` Q. Regardless of pressure you would consider
` it or are there some pressure regime that we --
` A. Certainly there's some pressure -- some
` normal operating pressure regimes to one skilled in
` the art. You know, if you were at -- give me an
` example.
` Q. Well, question for you: Is there a
`
` DeVITO
` pressure where you would still have 50 percent of
` the metal ions ionized and a power density of 250
` watts per centimeter squared where you would not
` consider that system a HiPIM?
` MR. CAVANAUGH: Objection.
` A. You know what? I can't figure that out
` right now. I mean, it's -- it's not a simple
` question. You have to sit down and calculate that.
` Q. Do you have all the information you need
` or do you need more information to calculate that?
` A. I'd have to sit down and get some
` references and see what the mean free path is
` and...
` Q. Well, isn't the mean free path just
` dictated by the pressure?
` A. It is, yes.
` Q. I'm asking you given any pressure --
` A. Right.
` Q. -- right, is there a pressure and the
` other requirements making at least 50 percent of
` the metal ions ionized where a system in a chamber
` that has 250 watts per centimeter squared of power
` density would not be considered a HiPIM --
` A. I'm sure there is. I just don't know what
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` DeVITO
` that would be.
` Q. So what is --
` MR. LAHAV: Restart that.
` Q. What are the other criteria necessary for
` you to consider a system to be a HiPIM system?
` A. So I just -- very simply to me, a HiPIM
` system is, you know, you apply a certain power in
` order to get substantial fraction of the metal
` ions -- the metal atoms ionized. So that power
` would be dictated by many different -- well, not
` many different things, but several different
` things, but mainly the diameter of the magnetron.
` Q. Right.
` But as we just covered, the ionization of
` a substantial number of metal ions -- metal atoms
` ionized is a necessary but, in your view, not a
` sufficient condition for HiPIMS, correct?
` MR. CAVANAUGH: Objection.
` A. I didn't say that. I mean, that is a --
` you have to have that, right? If you don't have
` that, you don't have -- that's the basic
` definition, having a substantial fraction of the
` metal atoms ionized. If you're at atmospheric
` pressure, the plasma will extinguish, so...
`
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` DeVITO
` Q. That being at atmospheric pressure goes
` along with not having 50 percent or more of the
` metal atoms ionized, right?
` A. Uh-huh.
` Q. So maybe we're coming back to the
` beginning. Is there any other condition necessary
` for a system to be called HiPIMS other than having
` greater than 50 percent of the metal atoms ionized?
` A. I guess all I can say is you have to be
` operating in what one would consider a normal
` pressure range for semiconductor processing, so...
` Q. And what do you mean by "a normal pressure
` range"?
` A. Well, it means -- here it means different
` things depending on what your application is, but
` the typical sputtering range for plasmas, right? I
` mean, if you look in the literature, that would be
` anywhere from just under a millitorr to ten's of
` torr, I guess, tens of millitorr.
` Q. So is it the case, then, that the power
` density is not important to considering the system
` HiPIMS?
` MR. CAVANAUGH: Objection.
` A. No, we didn't say that at all. We just
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` said that that is a necessary condition, right,
` power density. And we need to have at a --
` operating at a normal pressure range as well. I
` mean, if you have a normal pressure range and you
` don't have a high density power, you won't have
` HiPIMS, right?
` Q. So just want to understand if there are
` any other criteria. In order to have a HiPIM, you
` need to have a system in a pressure range of just
` under a millitorr to tens of millitorr, at least
` 50 percent of the metal atoms ionized, and a power
` density roughly in the range of 250 to 350 watts
` per centimeter squared, correct?
` MR. CAVANAUGH: Objection.
` You can answer. I'm sorry. I just want
` to make sure I interpose the objection.
` A. Yes. That's what I said, yes.
` Q. Is there any other condition necessary to
` have a HiPIM?
` A. Not that I can think of right now.
` Q. And since there's a requirement of
` ionization of metal atoms, it doesn't make sense to
` talk about HiPIMS in a non-sputtering system; is
` that fair?
`
` DeVITO
` MR. CAVANAUGH: Objection.
` A. Say that again? Rephrase.
` Q. Yes.
` If you don't have a target, if you have a
` plasma without a target, you don't talk about HiPIM
` systems; is that fair?
` A. You don't have to have a target. It
` certainly helps if you're doing sputtering.
` Q. Well, what would the metal atoms be in a
` chamber with a target?
` A