Patent No. 7,811,421
`IPR2014-00802
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`FUJITSU SEMICONDUCTOR LIMITED, FUJITSU SEMICONDUCTOR
`AMERICA, INC., ADVANCED MICRO DEVICES, INC., RENESAS
`ELECTRONICS CORPORATION, RENESAS ELECTRONICS
`AMERICA, INC., GLOBAL FOUNDRIES U.S., INC.,
`GLOBALFOUNDRIES DRESDEN MODULE ONE LLC & CO. KG,
`GLOBALFOUNDRIES DRESDEN MODULE TWO LLC & CO. KG,
`TOSHIBA AMERICA ELECTRONIC COMPONENTS, INC., TOSHIBA
`AMERICA INC., TOSHIBA AMERICA INFORMATION SYSTEMS,
`INC., TOSHIBA CORPORATION, and THE GILLETTE COMPANY,
`
`Petitioners
`v.
`ZOND, LLC
`Patent Owner
`_____________________
`
`Inter Partes Review Case No. IPR2014-008021
`Patent 7,811,421
`
`____________________
`
`
`
`
`
`
`PATENT OWNER’S OBSERVATIONS ON CROSS-EXAMINATION
`OF PETITIONER’S REPLY WITNESS
`
`37 C.F.R. §42.70
`
`
`1 Cases IPR2014-00848, IPR2014-00992, and IPR2014-01071 have been joined
`with the instant proceeding.
`
`
`
`IPR2014-00802
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`FUJITSU SEMICONDUCTOR LIMITED, FUJITSU SEMICONDUCTOR
`AMERICA, INC., ADVANCED MICRO DEVICES, INC., RENESAS
`ELECTRONICS CORPORATION, RENESAS ELECTRONICS
`AMERICA, INC., GLOBAL FOUNDRIES U.S., INC.,
`GLOBALFOUNDRIES DRESDEN MODULE ONE LLC & CO. KG,
`GLOBALFOUNDRIES DRESDEN MODULE TWO LLC & CO. KG,
`TOSHIBA AMERICA ELECTRONIC COMPONENTS, INC., TOSHIBA
`AMERICA INC., TOSHIBA AMERICA INFORMATION SYSTEMS,
`INC., TOSHIBA CORPORATION, and THE GILLETTE COMPANY,
`
`Petitioners
`v.
`ZOND, LLC
`Patent Owner
`_____________________
`
`Inter Partes Review Case No. IPR2014-008021
`Patent 7,811,421
`
`____________________
`
`
`
`
`
`
`PATENT OWNER’S OBSERVATIONS ON CROSS-EXAMINATION
`OF PETITIONER’S REPLY WITNESS
`
`37 C.F.R. §42.70
`
`
`1 Cases IPR2014-00848, IPR2014-00992, and IPR2014-01071 have been joined
`with the instant proceeding.
`
`
`
`
`Patent No. 7,811,421
`IPR2014-00802
`
`
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`Pursuant to 37 C.F.R. §42.70(a), Patent Owner, Zond, LLC, hereby
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`submits it observations on cross-examination of Dr. Overzet, whose
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`Declaration was submitted by Petitioners with their Reply Brief filed May 1,
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`2015. Dr. Overzet’s cross-examination was conducted by deposition on May
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`7, 2015. Exhibit 2018 is a transcript of that deposition, and is used as the basis
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`for the present observations.
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`1. Dr. Overzet’s testimony confirms that the ‘421 patent used the
`phrase “creates a weakly ionized plasma” to refer to the ignition of
`feed gas.
`
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`In his testimony at page 87, line 4 – page 88, line 19; and at page 99, line 10 –
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`page 104, line 5 (in particular within the excerpts below), Dr. Overzet
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`confirmed that the ‘421 patent used the phrase “creates a weakly ionized
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`plasma” to refer to the ignition of feed gas. This is relevant to the Patent
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`Owner’s assertion that the claimed phrase “creates a weakly ionized plasma”
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`refers to igniting a gas from a state in which there is no plasma to a state in
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`which a plasma exists. (Patent Owner Response, pages 18 – 22) and to the
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`Petitioner’s arguments to the contrary (Petitioners’ Reply, pages 2 – 4):
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`Excerpt A: Zond Ex. 2018, Page 102, line 6 - page 104, line 5
`Q. So look at the entire sentence: "The characteristics of the voltage
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`pulse are chosen such that an electric field develops between the cathode
`assembly that creates a weekly-ionized plasma 362 in the region 245."
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`Patent No. 7,811,421
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`Q. Do you see that language at column 11 --
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`…
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`A. I do.
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`Q. -- lines 14 on?
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`A. I see that language, uh-huh.
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`Q. Now, which of the two techniques for creating a weakly-ionized
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`plasma do you think is being referred to here?
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`A. It wasn't part of the section that we read together, but the first line of
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`that paragraph describes the beginning of the feed gas flow. Do you see
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`that in that first line, after the feed gas is supplied between the cathode
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`assembly and the anode --
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`Q. At line 9, right.
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`A. Yes, indicating an initiation of the feed gas flow --
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`Q. Uh-huh.
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`A. -- yes. So because of that line, I have the impression that this would
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`be a first application of the electric field.
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`Q. Does that mean that the sentence referred to here starting at line 14
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`through 18 or 19 refers to the first type – first technique for creating
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`weakly-ionized plasma that you referred to in your declaration as
`ignition?
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`A. As I read this and think about it, in its context, it is consistent with
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`the first application in developing a first weakly-ionized plasma.
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`Q. By "first" you mean ignition, just --
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`A. Yes.
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`Excerpt B: Zond Ex. 2018, Page 88, lines 3 – 14:
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`Q. In the flow chart depicted in figures 11A and 11B, can you identify
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`for me a step that corresponds to the creation of weakly-ionized plasma
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`referenced in element B of Claim 1?
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`A. It looks to me like item 618 is that location, because it says, "Ionized
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`feed gas to generate weakly-ionized plasma."
`2. Dr. Overzet’s was unable to identify any text of the ‘421 patent
`that used the phrase “creates a weakly ionized plasma” to refer to
`the so-called “alternative technique” in which a strongly ionized
`plasma transitions to a weakly ionized plasma.
`
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`In his testimony at page 111, line 6 – page 114, line 19, and in particular in the
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`testimony excerpts below, Dr. Overzet testified that he was unable to identify
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`any text of the ‘421 patent that used the phrase “creates a weakly ionized
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`plasma” when referring to the so-called “alternative technique” in which a
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`strongly ionized plasma transitions to a weakly ionized plasma. This too is
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`relevant to the Patent Owner’s interpretation of the claimed phrase “creates a
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`weakly ionized plasma” and rebuts Petitioners’ proposed interpretation:
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`Q. So based upon your review to date and your -- your current
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`knowledge, are you able to cite right now any additional text in the '421
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`patent where the phrase "creates a weakly-ionized plasma" was used to
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`refer to the technique referred to in paragraph 31 of your declaration?
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`A. I cannot point to at this moment in time a location in the '421 patent
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`that refers to creating a weakly-ionized plasma as occurring from a
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`strongly-ionized plasma.
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`3. Dr. Overzet confirmed that the ‘421 patent instead used the phrase
`“maintains the plasma” when referring to a transition from a
`strongly ionized plasma to a weakly ionized plasma.
`
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`In his testimony at page 111, line 18 – page 113, line 10, and in particular in
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`the testimony excerpts below, Dr. Overzet acknowledges that the text of the
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`‘421 patent that describes the transition from a strongly ionized plasma to a
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`weakly-ionized plasma uses the phrase “maintains the plasma” for this
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`transition, and NOT the claimed phrase - “creates a weakly ionized plasma.”
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`This too is relevant to the dispute over the meaning of the claimed phrase
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`“creates a weakly ionized plasma” by demonstrating that the Patent Owner’s
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`proposal is consistent with the language of the ‘421 patent specification and
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`that the Petitioners’ proposal is not:
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`A. So if I may parrot the question back to you, the question is, am I
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`aware of the '421 patent using the phrase "creates a weakly-ionized
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`plasma" in conjunction with the transition from strongly-ionized to
`generating weakly-ionized, from a strongly-ionized?
`
`Q. Yes.
`
`A. I've got the wrong patent in front of me now.
`
`Q. And again, I want to break it down.
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`First I want to see if you have any in mind, and if not, you know, look to
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`the patent if you'd like and see if you can find it. So let's start with what
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`you know.
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`A. I'm going to look back at column 16 again. Is that what -- that is what
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`I have in mind, to look at column 16 first.
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`Q. Okay.
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`A. It doesn't use those exact words, but what's said in column 16 at line
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`42 and following -- I'm sorry, 41 and following is this: "At time t6, the
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`maximum power 350 is terminated. In one embodiment, the pulsed
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`power supply 234 continues to supply a background power that is
`sufficient to maintain the plasma after time t6." This plasma at that time
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`is clearly identified as the weakly-ionized plasma because later on in that
`same column another high-power pulse is applied, so it does not
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`specifically call out the word "create," but it calls out what I would
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`consider to be the function of "create." That is to generate or to form or
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`something along those lines.
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`Q. Here this characterizes that as, quote, maintaining the plasma,
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`closed quote. Is that correct?
`
`A. It uses that word "maintain," but before t6 there is not weakly-
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`ionized plasma. At some point in time after there is. That is a generation
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`event.
`4. Dr. Overzet’s testimony confirms that the portion of Wang’s
`waveform that the Petitioners call a “pulse” does not “create a
`weakly
`ionized plasma,” even using Dr. Overzet’s so-called
`“alternative” definition of “creating a weakly-ionized plasma.”
`In his testimony at page 122, line 6 – page 124, line 13, Dr. Overzet identified
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`the portion of Wang’s waveform that he relies upon for allegedly teaching the
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`voltage pulse of claim 1 by annotating the reproduction of Wang’s figure 6 on
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`page 26 of his declaration. Although created during his deposition testimony
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`(see page 122, line 6 – page 124, line 13), Dr. Overzet’s annotated version of his
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`declaration was not produced with his deposition transcript, and it has not
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`been found. The Patent Owner submits that when Dr. Overzet annotated his
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`declaration, he identified a region in the middle of the Wang’s figure 6 that is
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`consistent with the contention in Petitioners’ Reply Brief that the claimed pulse
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`corresponds to a “high-power peak and the lower-power region preceding
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`it,” presumably agreeing with the Petitioners’ contention on this issue. (see
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`Petitioners’ Reply Brief at page 10). But Dr. Overzet further testified that this
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`preceding lower-power region at the power level PB operates to “create a
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`weakly-ionized plasma” as claimed. Yet this low power region of the “pulse”
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`clearly does not “create a weakly ionized plasma” (even accordingly to Dr.
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`Overzet’s “alternative” definition of the phrase) because in that region the
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`weakly ionized plasma already exists (see e.g., page 95, line 7 – page 99, line 9
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`of Dr. Overzet’s deposition transcript.
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` Excerpt A: Zond Ex. 2018, Page 123, line 3 – page 124, line 12:
`Q. … Looking at the reproduction of Wang's figure 6 on page 26, can
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`you identify for me the portion of that waveform that you believe
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`corresponds to the claimed pulse? ….
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`A. That pulse would begin and end like so.
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`Q. Now, which portion of that pulse, quote, unquote, creates the
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`weakly-ionized plasma?
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`A. The beginning portion.
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`This is relevant to the Patent Owner’s argument that Wang does NOT teach
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`the claimed power supply for generating a voltage pulse that creates a weakly
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`ionized plasma and then a strongly ionized plasma from the weak, without an
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`occurrence of arcing (Patent Owner Response, pages 28 – 38).
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`5. Dr. Overzet’s testimony confirms that his proposed definition of
`“pulse” was contrived for purposes of this litigation and is not a
`reasonable interpretation derived from the ‘421 patent.
`In his testimony at page 54, line 15 – page 73, line 4, (and in particular to the
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`excerpts below), Dr. Overzet testified that: 1) he did not know whether the
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`word “pulse” has a special meaning in this art, 2) the definition of pulse he
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`proposes in his declaration was prepared for this litigation, 3) he could not
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`recall whether he or his lawyers prepared it, and 4) he did not consult any
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`dictionaries or trade literature to see if such documents were consistent with
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`his proposed definition. This is relevant to the Patent Owner’s contention that
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`the Petitioners’ theory of anticipation requires an unnatural reading of the
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`claim phrase - “pulse … that creates a weakly ionized plasma and then a
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`strongly ionized plasma” - that was contrived for purposes of this litigation.
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`(Patent Owner’s Response, pages 1 – 4).
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`Q. To your knowledge, does the meaning of the word "pulse" in this art
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`differ from the ordinary English usage of the word "pulse"?
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`A. Do you have a dictionary that I can look at?
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`Q. Well, let's start with your knowledge.
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`A. I don't want to speculate, and a dictionary would define the ordinary
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`usage. I would need to see that to answer your question.
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`Q. Did you consult any technical dictionaries for guidance?
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`***
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`A. Not that I recall.
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`***
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`Q. Basically what I asked is, at the time you prepared the definition here
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`in paragraph 3 --
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`A. Uh-huh.
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`Q. -- did at that time you pause to go consult the literature to see how the
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`word "pulse" was being used in the literature?
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`A. I did not go and specifically search through the literature for a
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`definition of a word that I believe I already understand very well.
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`Q. Okay. When did you come up with this statement or definition of the
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`word "pulse" that you have here in paragraph 33?
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`A. Are you asking for when as a specific date, or as part of -- I can recall
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`that this definition -- I came up with this definition as part of the first
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`draft of my declaration.
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`Q. Okay. And let's start there. So in that first draft, was it -- were you the
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`one who crafted the terminology of the definition here?
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`A. I don't recall who wrote which sentence for the first time, but I agree
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`with that first sentence in paragraph 33. That is my opinion.
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`Q. Understood. But as you sit here now, you can't recall whether it was
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`you or someone else who first -- did the first draft of this sentence in
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`paragraph 33; is that correct?
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`A. It is my assertion that that sentence is my opinion, and it's immaterial
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`who first typed it up, that it came out of conversation with counsel.
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`Q. The materiality aside, is it true that you can't recall whether you or
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`counsel did the first draft of this sentence?
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`A. Yes, I do not recall.
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`6. Dr. Overzet EFFECTIVELLY modified his definition of “pulse”
`during his deposition, thus demonstrating that the definition proposed
`in his declaration is not a reasonable one
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`In his testimony at page 61, line 7 – page 62, line 12 and at page 68, line 12 –
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`page 73, line 4 (including the excepts below), Dr. Overzet essentially modified
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`his proposed definition of “pulse.” This supports the Patent Owner’s
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`argument that the Petitioners’ theory of anticipation requires an unnatural
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`reading of the claim phrase - “pulse … that creates a weakly ionized plasma
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`and then a strongly ionized plasma” - that was contrived for purposes of this
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`litigation. (Patent Owner’s Response, pages 1 – 4).
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`Q. Well, let me see if I understand the definition as you have offered it
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`here. You mentioned that the property is applied, quote, over a period of
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`time, closed quote. What -- what is that period of time?
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`A. It is -- it is a length of time.
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`Q. So your definition of pulse in that first sentence is silent on
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`amplitude. Is that what you intended?
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`A. I would disagree.
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`Q. Okay. Fantastic. Then why don't you just -- because I'm trying to get
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`an understanding, why don't you elaborate for me where in this
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`definition there is a hint of the amplitude component of your pulse
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`definition?
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`A. It seems to me that there is just more than just a hint. Since it's a
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`property over a period of time, that means that that property must have
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`changed.
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`Q. Okay. So the word "property" as you understand it here implies some
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`change in one of the parameters listed; is that correct?
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`A. I believe that's correct. Stronger than that, that's correct.
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`***
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`Q. Please identify for me any word in your definition of paragraph 33
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`that refers to the concept of change that you have been discussing.
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`A. A property that is applied over a period of time.
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`Q. And to you, that implies change; is that correct?
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`A. Yes, it implies a stop and a start, and not a false setting of said stop
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`and start.
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`***
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`Q. Would you agree that a -- the word "pulse" implies a transient
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`variation of a brief duration?
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`A. I think I agree with that as well. I believe that to be consistent with
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`my prior testimony.
`7. Dr. Overzet’s testimony confirmed that Wang does not disclose a
`power supply that chooses the amplitude, duration and rise time of a
`pulse’s voltage as in the claims.
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`Between page 37, line 2 and page 48, line 23, Dr. Overzet’s testimony explains
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`the meaning of the word “power” in various contexts, and in doing so clarifies
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`that some power supply controllers control the power of their output to a target
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`power level, and that others control the voltage of their output to choose a
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`desired voltage. This testimony is relevant to the Patent Owner’s argument that
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`Wang does not teach the claimed power supply that chooses voltage
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`amplitude, duration AND rise time of the voltage of its output, since it is
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`designed to choose a desired target power level (Page 50, line 17 – page 54, line
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`14). A few pertinent excerpts are reproduced below:
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`Excerpt A: Zond Ex. 2018, Page 44, line 19 – page 45, line 12:
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`Q. I got it, I think, but just to be much simpler, so there is a structure
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`generally known as a controller within power supplies for controlling the
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`power supply operation. Do I have that correct?
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`A. The word "power supply" is a more general word than that. So one
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`would call a supply that controls voltage a power supply, or a supply
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`that controls current a power supply or a supply that controls power a
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`power supply. All three of those are used, and I have seen in my
`experience power supplies wherein one can choose between any of the
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`three, or more commonly between controlling voltage or controlling
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`current, but yet it's called a power supply.
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`Q. Thank you, got it. So this leads to the terminology issue I want to get
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`to. So in the version of power supply that controls power, I assume then
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`that the controller has some target power level that it's trying to achieve.
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`Do I have that right?
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`A. I believe that typically would be the case.
`Excerpt B: Zond Ex. 2018, Page 48, lines 15 - 23:
`Q. Right. And for power supplies that control power, as you mentioned,
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`the target power level is a parameter of that controller; is that correct?
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`A. That is my understanding that a power supply where you can set
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`power, would try to control the output power.
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`8. Dr. Overset confirmed that his declaration does not provide an
`opinion on the patentability of the claims, just on whether the
`individual elements were “anticipated and/or rendered obvious by the
`prior art.”
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`Dr. Overzet confirms in his testimony (Zond Ex. 2018, page 136, line 12 –
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`page 137, line 17; and page 167, line 24 – page 168, line 24), that his
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`declaration does not offer an opinion on the patentability of the claims: His
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`declaration merely opines that each of the individual limitations of the claims
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`was allegedly taught by “the prior art” or was obvious in view of “the prior
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`art.” This is relevant because it confirms that the scope and evidentiary value
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`of Dr. Overzet’s declaration is limited to his assessment of the individual
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`elements (as he characterizes them) and not to the claimed combinations as a
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`whole.
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`9. Dr. Overzet’s testimony confirms that the gas flow in Wang was
`constant and that Dr. Overzet never considered the claimed
`requirement for controlling flow to diffuse the strongly-ionized
`plasma as recited in claims 6, 31
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`Dr. Overzet’s testimony cited below confirms that the gas flow in Wang was
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`constant and that Dr. Overset never considered the requirement for controlling
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`flow rate to diffuse the strongly-ionized plasma as recited in claims 6, 31. This
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`is relevant to the Patent Owner’s argument in IPR2014-00805 that Wang does
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`not teach the claimed flow control (Patent Owner Response, IPR2104-00805,
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`pages 45 – 48).
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`Excerpt A: Zond Ex. 2018, Page 161, lines 13 - 24:
`Q. So did you discuss in your declaration the process of diffusion of the
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`plasma particles, the particles within the strongly-ionized plasma, did
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`you discuss that in your declaration?
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`A. Did I discuss that?
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`A. No, that was not a -- an argument that I saw being made by the prior
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`exhibits, so I discussed the diffusion of the argon in the plasma, which I
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`take to be the clear meaning of Claim 6.
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`Excerpt B: Zond Ex. 2018, Page 159, lines 2 - 25:
`Q. And in paragraph 77, I notice you use that terminology, that the feed
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`gas diffuses into the plasma.
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` A. That's right.
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` Q. Right. And that means that the gas molecules through the procession
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`of diffusion that you described reach the plasma; is that right?
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` A. Diffuse into and replace old gas atoms --
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` Q. Right.
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`A. -- that are being pumped away.
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`Q. Now, does the feed gas in Wang operate to expand the volume of the
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`strongly-ionized plasma?
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`A. To expand the volume. My understanding is that without the feed gas
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`entering in Wang, the pressure would reduce. As part of the pressure
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`reducing, the strongly ionized plasma would contract and go away. So
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`without the feed gas feeding into the strongly ionized plasma, the plasma
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`would, in fact, be reduced. As a result, I believe it is accurate to say that
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`it expands. If preventing a reduction is expansion, then expansion.
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`Excerpt C: Zond Ex. 2018, Page 159, lines 14 - 25:
`Q. Well, does -- does Wang ever suggest increasing the flow rate once a
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`strongly-ionized plasma is formed?
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` A. I do not recall Wang discussing an increase of the flow rate after the
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`formation of strongly-ionized plasma.
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` Q. So the rate of -- is it true then that the rate of diffusion of the feed gas
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`from the inlet to the region with the strongly-ionized plasma is, would be
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`essentially constant in Wang's system?
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` A. It could be essentially constant. There are other factors which could,
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`in fact, influence that rate as well.
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`Excerpt D: Zond Ex. 2018, Page 165, line 12 – 167, line 23:
`Q. So what was the shortcoming in Wang that you were relying upon --
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`you were looking to Lantsman to fill?
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`A. We were responding to an argument by the patent owner.
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`Q. I don't understand. So what argument were you relying upon
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`Lantsman for?
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` A. The final sentence in paragraph 79 of my declaration states exactly
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`this: "Thus, even if Wang did not teach continuous feed of gas during
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`the plasma process, I consider this a regular and routine modification,
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`consistent with the teachings of Lantsman."
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`Q. I see. So you are relying upon Lantsman for the teaching of
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`continuous feed of gas; correct?
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` A. Yeah.
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` Q. So the reference to two-stage plasma that -- that you are not relying
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`upon Lantsman for whatever that is?
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` A. Correct.
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`Date: May 18, 2015
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`Respectfully submitted,
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`
`/Bruce Barker/
`Bruce Barker
`Reg. No. 33,291
`Chao Hadidi Stark & Barker LLP
`176 East Main Street, Suite 6
`Westborough, MA 01581
`(508) 366-3800
`bbarker@chsblaw.com
`15
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`
`
`Patent No. 7,811,421
`IPR2014-00802
`
`PATENT OWNER’S EXHIBIT LIST IPR 2014-00800
`
`Exhibit
`No.
`Ex. 2001
`
`Ex. 2002
`
`Ex. 2003
`
`Exs. 2004 - 2009
`Ex. 2010
`Ex. 2011
`Ex. 2012
`Ex. 2013
`Ex. 2014
`Ex. 2015
`Ex. 2016
`Ex. 2017
`Ex. 2018
`
`
`
`Description
`
`Affidavit of Etai Lahav in Support of Patent
`Owner’s Motion for Pro Hac Vice Admission
`Affidavit of Maria Granovsky in Support of
`Patent Owner’s Motion for Pro Hac Vice
`Admission
`Affidavit of Tigran Vardanian in Support of
`Patent Owner’s Motion for Pro Hac Vice
`Admission
`Not Used
`Eronini
`Weyrick
`Kuo
`Sinha
`DeVito Deposition
`Hartsough Declaration
`Rossnagel
`Kortshagen Deposition of 12.23.14
`Overzet Deposition 5/7/15
`
`16
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`
`
`
`
`
`
`
`
`
`
`Patent No. 7,811,421
`IPR2014-00802
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Patent
`
`Owner Observations were served via email on May 18, 2015, on Petitioner’s
`
`attorneys:
`
`GlobalFoundries:
`David Tennant
`dtennant@whitecase.com
`Dohm Chankong
`dohm.chankong@whitecase.com
`
`Toshiba:
`Robinson Vu
`robinson.vu@bakerbotts.com
`
`Fujitsu:
`David L. McCombs
`david.mccombs.ipr@haynesboone.com
`David M O’Dell
`david.odell.ipr@haynesboone.com
`
`Gillette:
`David Cavanaugh
`david.cavanaugh@wilmerhale.com
`Larissa B. Park
`larissa.park@wilmerhale.com
`
`
`
`
`
`
`
`
`
`/Bruce Barker/
`Bruce Barker
`Reg. No. 33,291
`Chao Hadidi Stark & Barker LLP
`176 East Main Street, Suite 6
`Westborough, MA 01581
`(508) 366-3800
`bbarker@chsblaw.com
`
`17
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