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`Trial No. IPR2014-00803
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`Filed on behalf of The Petitioners
`By: David L. Cavanaugh, Reg. No. 36,476 (Lead Counsel)
`David M. Tennant, Reg. No. 48,362 (Back-up Counsel)
`Wilmer Cutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Avenue NW
`Washington, DC 20006
`Tel: (202) 663-6025
`Email: David.Cavanaugh@wilmerhale.com
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`THE GILLETTE COMPANY, FUJITSU SEMICONDUCTOR LIMITED,
`ADVANCED MICRO DEVICES, INC., RENESAS ELECTRONICS
`CORPORATION, RENESAS ELECTRONICS AMERICA, INC.,
`GLOBALFOUNDRIES 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., and TOSHIBA CORPORATION
`
`Petitioners
`
`v.
`
`ZOND, LLC
`
`Patent Owner of
`U.S. Patent No. 7,808,184
`IPR Trial No. IPR2014-008031
`
`PETITIONER’S REPLY
`
`Claims 6-10 and 16-20
`
`
`1 Cases IPR 2014-00858, IPR 2014-00996, and IPR 2014-01061 have been joined with
`the instant proceeding.
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`Trial No. IPR2014-00803
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`TABLE OF CONTENTS
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`
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`I. 
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`INTRODUCTION ........................................................................................ 1 
`
`II. 
`ZOND CONCEDES THAT INDEPENDENT CLAIMS 1 AND 11
`ARE TAUGHT BY THE PRIOR ART ................................................................. 2 
`
`III.  ZOND’S NEWLY PROPOSED CONSTRUCTION IS ERRONEOUS 4 
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`IV.  WANG TEACHES THE CLAIM LIMITATIONS EVEN UNDER
`ZOND’S NEWLY PROPOSED CONSTRUCTION .......................................... 7 
`
`V. 
`THE ALLEGED “INCOMPATIBILITIES BETWEEN
`KUDRYAVTSEV AND WANG” ARE BASED ON
`MISUNDERSTANDINGS OF BOTH FACT AND LAW .................................. 9 
`
`VI.  ZOND’S ALLEGED EVIDENCE OF SECONDARY
`CONSIDERATIONS OF NON-OBVIOUSNESS IS FLAWED ...................... 12 
`
`VII.  DEPENDENT CLAIMS ARE OBVIOUS ................................................ 13 
`
`A. 
`Dependent Claims 7 and 17 ........................................................ 13 
`VIII.  CONCLUSION ............................................................................................ 15 
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`CASES
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`Trial No. IPR2014-00803
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`TABLE OF AUTHORITIES
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`Page(s)
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`In re Mouttet, 686 F.3d 1322, 1332 (Fed. Cir. 2012) ………………………… 12
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`In re Etter, 756 F.2d 852, 859 (Fed. Cir. 1985) (en banc)…………………….. 12
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`I.
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`INTRODUCTION
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`Trial No. IPR2014-00803
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`In its Decision on Institution (“DI”), the Board recognized there is a
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`reasonable likelihood that the challenged claims 1-5 and 11-15 are unpatentable. See
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`IPR2014-803 DI at p. 31. The Board reached its conclusion after adopting the
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`constructions proposed by Zond. Belatedly recognizing that the Board correctly
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`reached its conclusion even under Zond’s earlier proposed construction, Zond now
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`attempts to distinguish the prior art by proposing a new, but flawed, construction. In
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`fact, Zond failed to even address why the challenged claims are valid under the
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`previous construction adopted by the Board, effectively conceding that the challenged
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`claims are unpatentable under the construction adopted by the Board.
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`None of the arguments raised by Zond is sufficient to alter the determination
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`of the Board in its Decision on Institution. First, Zond’s newly proposed
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`construction is not supported by the patent specification itself and therefore should
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`not be adopted. Even if the newly proposed construction were adopted, the cited
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`prior art nevertheless render the claims unpatentable.
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`The Petition, supported by Mr. DeVito’s declaration, demonstrates why one of
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`ordinary skill in the art would have combined the teachings of the cited references.
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`The cross examination testimony of Dr.Hartsough, Zond’s declarant, further
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`confirms that the references were in the same art and would have been combined.
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`Petitioner also provides the declaration of Dr. John Bravman, who reached the same
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`Trial No. IPR2014-00803
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`conclusion: that the references would have been combined by one of ordinary skill in
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`the art and that the challenged claims are unpatentable.2
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`II.
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`ZOND CONCEDES THAT INDEPENDENT CLAIMS 1 AND 11
`ARE TAUGHT BY THE PRIOR ART
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`The only dispute remaining as to independent claim 1 is whether the cited
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`references “teach the claimed control of voltage amplitude or rise time to avoid arc
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`when rapidly forming a strongly ionized plasma.” IPR2014-803, Patent Owner
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`Response (“PO Resp.”) at p. 26. However, it is clear from Dr. Hartsough’s
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`concessions that this was well-known.
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`Avoiding Arcing
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`Wang teaches that “the chamber impedance changes relatively little
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`between the two power levels PB, PP since a plasma always exist in the chamber.” Ex.
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`1105 (“Wang”) at 7:49-51. Dr. Hartsough conceded as follows:
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`Q: But if impedance changes relatively little during the
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`transition from a low-to a high-density plasma, then it’s indicative of no
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`short circuit or arcing; right?
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`…
`A: That’s indicative of no – certainly no unipolar arc…”)
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`Ex. 1125 (“’775 Hartsough Depo.”) at 89:8-24 (emphases added). Accordingly,
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`Wang, which explicitly teaches that impedance changes relatively little between PB and
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`2 Mr. DeVito is no longer available to provide testimony.
`2
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`PP, therefore teaches the avoidance of arcing when strongly-ionized plasma is
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`generated with the application of peak power pulses PP. Ex. 1128 (“Bravman Dec.”)
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`at ¶¶ 73-76.
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`Control of Voltage Amplitude or Rise Rime when Rapidly Forming a Strongly Ionized
`Plasma
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`It is undisputed that controlling voltage amplitude or rise time when rapidly
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`forming a strongly-ionized plasma was well-known long before the ‘184 patent. See
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`IPR2014-803, Petition at pp. 47-52 and Ex. 1102 (“DeVito Dec.”) at ¶¶ 117-126. As
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`conceded by Dr. Hartsough, the ‘184 patent itself admits this limitation as being prior
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`art.
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`Q: And Figure 10 is prior art; right?
`…
`A: So as Figure 10 is illustrated – or described as prior art. So
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`he’s saying that it can generate voltage pulses.”
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`Q: Choosing a voltage pulse rise time was well known before the
`alleged ‘155 invention; correct?
`…
`A: Again, Dr. Chistyakov says that these pulses are according to
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`the present invention, and -- so I will use my understanding of what he
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`said there, since a controlled rise time is part of his present
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`invention, that these power supplies could do that.”
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`Ex. 1126 (“’155 Hartsough Depo.”) at 84:25-86:23 (emphases added).
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`Trial No. IPR2014-00803
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`Zond also does not challenge that this limitation is met by Wang under the
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`construction adopted by the Board in the Decision on Institution. Accordingly, Zond
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`has conceded that this limitation is taught by the cited prior art under the construction
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`adopted by the Board.
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`III. ZOND’S NEWLY PROPOSED CONSTRUCTION IS ERRONEOUS
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`Zond seeks to modify the construction adopted by the Board, effectively
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`conceding that the challenged claims are invalid under the Board’s construction. In
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`particular, Zond seeks to add the additional requirements underlined below:
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`Claim Language at Issue
`“Generating at the output a voltage
`pulse having at least one of a controlled
`amplitude and a controlled rise time
`that increases an ionization rate of
`sputtered ion material atoms so that a
`rapid increase in electron density and a
`formation of a strongly ionized plasma
`occurs without forming an arc…”
`
`Newly Proposed Construction
`Generating at the output 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 of sputtered ion material atoms so that
`a rapid increase in electron density and a
`formation of a strongly ionized plasma
`occurs without forming an arc.
`
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`However, this newly proposed construction is inconsistent with the patent’s
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`specification. For example, Zond asserts that the newly proposed construction
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`requires the use of a feedback control system, such as those disclosed by the Eronini
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`reference. But the Eronini reference has no apparent relationship to the ‘184 patent.
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`Ex. 2015 (“Hartsough Dec.”) at ¶¶ 37-40. Indeed, Dr. Hartsough was unable to
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`identify any teaching in the ‘184 patent that would suggest such a feedback control
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`system exists in the claimed invention. Ex. 1127 (“’184 Hartsough Depo.”) at 177:21-
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`178:5 (“Q: Can you show me anywhere in the 184 patent any reference to a feedback
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`loop that’s connected to a sensor?…A: No.”). See also Bravman Dec. at ¶¶ 46-52.
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`Unsurprisingly, without the teaching of any such feedback control system, none
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`of the examples provided in the patent specification shows the actual ouput voltage
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`amplitude and/or rise time that are “directed or restrained to a target voltage level
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`and/or a rise time level.” For example, Zond touts Fig. 8 of the ‘184 patent as an
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`“example [that] demonstrates the compelling advantages of combining voltage
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`amplitude control with voltage rise time control…” IPR2014-803, PO Resp. at p. 15
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`(emphasis added). Fig. 8 is also compared with Fig. 3, which Zond assert “is NOT
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`an example of the claimed controlled pulse,” (IPR2014-803 PO Resp. at p. 17)
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`(emphasis added), but which the Board relied on in adopting the previous
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`construction proposed by Zond. IPR2014-803 DI at pp. 22-23.
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`
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`Zond’s arguments distort what is shown in these figures. In both figures, the
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`
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`“target” voltage profiles (overlaid with red) are square. See Ex. 1101 (“’184 Patent”) at
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`6:8-19 and 18:21-23. However, the actual voltage pulses (overlaid with green), are
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`clearly different in shape. See ’184 Patent at 6:8-19 and 18:25-19:3. Specifically, in
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`Trial No. IPR2014-00803
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`both figures, the actual output voltage amplitude and rise time (in green) is not
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`“directed or restrained” to the target value because there are numerous fluctuations
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`that exceed and/or undershoot the target voltage level, and a lag in rise time is
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`observed as compared to the target value. Accordingly, the ‘184 patent specification
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`fails to support Zond’s newly proposed construction that the “voltage pulse …
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`amplitude and/or rise time … are directed or restrained to a target voltage level
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`and/or a rise time level.” In fact, such a construction would effectively read out
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`what Zond calls its most “compelling” embodiment from the claims, IPR2014-803,
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`PO Resp. at p. 15, as well as all of Zond’s other embodiments. See ’184 Patent at Figs.
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`4-7. See also Bravman Dec. at ¶¶ 35-40.
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`Moreover, the reason why a high-density plasma was formed in Fig. 8, and not
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`in Fig. 3, is not because the “voltage pulse … amplitude and/or rise time … are
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`directed or restrained to a target voltage level and/or a rise time level.” This
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`fact is explained by a completely different reason: because the power supply in Fig. 8
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`“operates in a high-power mode throughout the duration of the voltage pulse 452,”
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`(‘184 Patent at 18:64-66), whereas the power supply in Fig. 3 “operat[es] in a low-
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`power voltage mode.” ’184 Patent at 5:65-67. See also Bravman Dec. at ¶¶ 41-43.
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`As Dr. Hartsough declares, this difference in power modes is reflected in “prior art
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`low-current discharge 152 and a high-current plasma 154” where the “power can be
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`100 to several hundred kW” for the high-current plasma shown in Fig. 2. Hartsough
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`Dec. at ¶¶ 72-73. Simply put, in Fig. 8, the power supply “suppl[ies] a sufficient
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`amount of uninterrupted power to drive the plasma from the transient non-steady
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`state to a strongly-ionized state ….” ‘184 Patent at 13:52-57 (emphasis added). See
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`also Bravman Dec. at ¶¶ 41-43.
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`Accordingly, the Board’s oringally adopted construction is consistent with the
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`requirements of the ‘184 patent specification that the voltage pulse amplitude and/or
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`rise time is directed or restrained by supplying a sufficient amount of uninterrupted
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`power to drive the plasma to a strongly-ionized state. Bravman Dec. at ¶¶ 41-43.
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`IV. WANG TEACHES THE CLAIM LIMITATIONS EVEN UNDER
`ZOND’S NEWLY PROPOSED CONSTRUCTION
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`Zond does not dispute that Wang meets the limitation under the construction
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`adopted by the Board. Rather, Zond argues that “Wang makes no mention
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`whatsoever of controlling the voltage amplitude,” (IPR2014-803 PO Resp. at p. 41),
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`based on Zond’s newly proposed construction. However, even under this newly
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`propsoed construction, Wang discloses the limitation to those skilled in the art.
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`Zond’s own declarant, Dr. Hartsough, concedes that Wang teaches the
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`application of negative voltage pulses during the application of peak power pulses.
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`’155 Hartsough Depo. at 152:17-154:17 (“Q: The negative voltage pulses that
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`correspond to PP are shown in Figure 7; correct?…A: Yes.”). Wang further explains
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`that a typical “pulsed power supply will output relative high voltage and almost no
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`current in the ignition phase and a lower voltage and substantial current in the
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`Trial No. IPR2014-00803
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`maintenance phase.” Wang at 5:32-35. As Dr. Hartsough conceded during his
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`deposition regarding the ‘775 patent (Ex. 1129), Figure 5 of the ‘775 patent illustrates
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`a typical power supply described by Wang, reproduced below with colored
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`annotations. ’775 Hartsough Depo. at 149:22-150:20 (“Q. So we can agree that Wang
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`is explaining how a typical pulsed power supply operates; right? A: Yes. … Q: And
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`that’s exactly what Figure 5 of the ‘775 patent is showing; right?…A: Yes.”). See also
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`Bravman Dec. at ¶¶ 55-56.
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`As shown above at left, in Fig. 5 of the ‘775 patent, when the voltage pulse is
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`initially applied (red region), voltage (green region) is initially higher with low current
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`(purple region). Then, when the strongly-plasma is generated (blue region), the
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`voltage (green region) becomes lower with the corresponding rise in current (purple
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`region). This is exactly how Zond’s “compelling example” of Fig. 8 also operates
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`shown above at right. Specifically, the ‘184 patent explains that “voltage pulse 452
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`includes a voltage 456 that is sufficient to ignite an initial plasma [see red
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`region]… and a voltage 472 that is sufficient to sustain the strongly-ionized
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`plamsa [see blue region].” ’184 Patent at 18:60-64 (emphases added). Both figures
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`behave nearly identically -- the difference is that the figure on the left is “a depiction
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`of a – of an idealized state” for typical power supplies described in Wang and
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`“variations” will exist in actual measured data as shown on the right, ’775 Hartsough
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`Depo. at 132:10-16 and 136:12-25, both figures behave nearly identically to one
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`another. See also Bravman Dec. at ¶¶ 57-58.
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`Accordingly, to the extent that Fig. 8 meets Zond’s newly proposed
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`construction, Wang also meets Zond’s newly proposed construction. The challenged
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`claims are therefore invalid under both constructions.
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`V. THE ALLEGED “INCOMPATIBILITIES BETWEEN
`KUDRYAVTSEV AND WANG” ARE BASED ON
`MISUNDERSTANDINGS OF BOTH FACT AND LAW
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`The Petition and Mr. DeVito’s declaration provide ample rationale to combine
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`the references. See, e.g., IPR2014-803, Petition at pp.49-51; DeVito Dec. at ¶¶ 120-
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`123. As explained therein, one of ordinary skill would have been motivated to use
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`Kudryavtsev’s explosive ionization in Wang, so as to increase plasma density and
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`thereby increase the sputtering rate. Use of Kudryavtsev’s teaching in Wang would
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`have been a combination of old elements yielding the predictable result of rapidly
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`increasing the ionization rate and electron density, which is known to be a desirable
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`result. See Bravman Dec. at ¶¶ 67-68.
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`Zond, however, argues that the references are incompatible with one another
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`Trial No. IPR2014-00803
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`and that one skilled in the art would not have been able to combine them. IPR2014-
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`803 PO Resp. at pp. 48-51. These arguments are wrong as matter of both fact and
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`law.
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`In particular, Zond argues that both Wang and Kudryavtsev teach arcing,
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`contrary to the claims. This is factually incorrect. As explained above, Dr. Hartsough
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`conceded that Wang does not have arcing. ’775 Hartsough Depo. at 89:8-24.
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`Moreover, Kudryavtsev teaches conditions where uniform plasma, which is indicative
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`of no arcing, can be obtained. Bravman Dec. at ¶¶ 65-66.
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`Zond further contends that Kudryavtsev and Wang would not be combined
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`because they are “not even in the same field.” IPR2014-803 PO Resp. at p. 51. This
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`is also factually incorrect, and indeed contrary to the ‘184 patent itself. That is, the
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`‘184 patent cites to Kudryavtsev, confirming that Kudryavtsev is indeed in the same
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`field.
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`Kudryavtsev is directed to a study of the behavior of plasma, and modeling
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`such behavior, which is general in its application. Kudryavtsev applies its theory to an
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`experimental embodiment. Ex. 1104 (“Kudryavtsev”) at Abstract. Kudryavtsev’s
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`theoretical framework is not limited in application to any specific type of apparatus
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`(flash tube or otherwise) within which plasma is discharged. In fact, while
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`Kudryavtsev may have utilized a particular experiment to verify his theoretical model
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`and “show[] that the electron density increases explosively in time,” Kudryavtsev
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`Trial No. IPR2014-00803
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`provides general teachings that are applicable “whenever a field is suddenly
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`applied to a weakly ionized gas.” Kudryavtsev at Abstract and p. 34, right col., ¶ 4
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`(emphasis added). Bravman Dec. at ¶ 67.
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`In fact, Kudryavtsev had long been considered by others in the field of pulsed
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`magnetron sputtering when designing pulsed magnetron sputter reactors. For
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`example, Mozgrin, which studied “high-current magnetron discharge (regime 2) in
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`sputtering or layer deposition technologies,” (Ex. 1103 (“Mozgrin”) at p. 409, left col.,
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`¶3; p. 403, right col., ¶3), took into account the dependences which had been obtained
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`in [Kudryavtsev] of ionization relaxation on pre-ionization parameters, pressure, and
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`pulse voltage amplitude.” Mozgrin at p. 401, right col. ¶1. See Bravman Dec. at ¶ 70.
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`Zond’s own expert retreated from his position that a person of ordinary skill in
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`the art would not look to Kudryavtsev “at all,” effectively narrowing his argument to
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`the technical nuances of physical substitution:
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`Q: Sir, it’s pretty strong language that you used to say a person
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`would not refer to Kudryavtsev at all when designing a plasma generator
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`whose purpose is to form a strongly-ionized plasma without forming an
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`arc.
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`A: Yes, that’s what I said.
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`Q: And my question is: Do you want to revise that language or do
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`you stand by the strong language today?
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`Trial No. IPR2014-00803
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`A: … So I would revise that statement --…
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`’155 Hartsough Depo. at 230:11 – 235:7.
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`As Dr. Bravman explains, a person of ordinary skill in the art would have
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`combined the teachings of Wang with Kudryavtsev, despite the physical differences
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`that may exist, just as Mozgrin had done in applying Kudryavtsev in designing his
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`magnetron sputtering system. Bravman Dec. at ¶ 69.
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`Moreover, such technical nuances of physical substitution have been rejected
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`by the Board. IPR2014-803, DI at pp. 18-21. As the Board explained, “[i]t is well-
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`established that a determination of obviousness based on teachings from multiple
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`references does not require an actual, physical substitution of elements.” In re Mouttet,
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`686 F.3d 1322, 1332 (Fed. Cir. 2012) (citing In re Etter, 756 F.2d 852, 859 (Fed. Cir.
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`1985) (en banc).
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`Accordingly, Zond’s argument is both factually incorrect and applies the wrong
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`standard. For these reasons, it should be rejected.
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`VI. ZOND’S ALLEGED EVIDENCE OF SECONDARY
`CONSIDERATIONS OF NON-OBVIOUSNESS IS FLAWED
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`Although Zond’s Response makes a fleeting and unsupported statement about
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`“secondary consideration,” IPR2014-803 PO Resp. at pp. 54-55, it does not provide
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`any substantive argument or evidence of secondary considerations of non-
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`obviousness. The sole argument rests on the alleged admission of Mr. DeVito that
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`“one skilled in art would require much experimentation (six months to a year).”
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`IPR2014-803 PO Resp. at p. 55.
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`However, as Mr. DeVito explained, this estimate was based on his assumption
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`that one “would have to build a prototype system first which would take up the
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`marjority of the – that would take obviously the majority of the time.” Ex. 2014
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`(“’155 DeVito Depo.”) at 306:2-6. With that assumption removed, that is, “if the
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`system already existed,” Mr. DeVito testified that he and a team of
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`engineers/technicians could carry out “routine engineering experiments” and “do all
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`the experiments in maybe less than a month.” ’155 DeVito Depo. at 307:1-13. See
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`also Bravman Dec. at ¶ 72. Thus, Zond has not presented any evidence of secondary
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`considertaions to rebut the prima facie case of obviousness.
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`VII. DEPENDENT CLAIMS ARE OBVIOUS
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`Zond does not challenge that claims 6, 8-10, 16 and 18-20 are unpatentable.
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`A. Dependent Claims 7 and 17
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`Zond points to Fig. 5C of the ‘184 patent as an example of a pulse that meet
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`the limitations “a lifetime of the strongly-ionized plasma is greater than about 200
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`µsec” (IPR2014-803 PO Resp. at pp. 55-58), recited in claims 7 and 17. Figure 5C of
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`the ‘184 patent is reproduced (below) with annotations. As shown, the strongly-
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`ionized plasma is sustained in the region shaded in blue, shown by the high plateau of
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`the power pulse (orange). Bravman Dec. at ¶ 95.
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`Trial No. IPR2014-00803
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`Zond concedes that Wang teaches power “pulse width up to … a millisecond,”
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`(IPR2014-803 PO Resp. at p. 57), which is five times larger than 200 µsec. Moreover,
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`as discussed above, Dr. Hartsough admitted that Wang’s typical power supplies can
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`be schematically represented by Fig. 5 of the ‘775 patent, (Ex. 1129), reproduced
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`(above) with annotations. As shown, Wang’s typical power supply generates and
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`sustains the strongly-ionized plasma in the region shaded in blue, shown by the high
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`plateau of the power pulse (orange), which can be up to a millisecond. Bravman Dec.
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`at ¶¶ 96-98.
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`Zond further argues that Wang “does not address the risk of arcing if his pulse
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`widths were extended over 200 microseconds.” However, as discussed above, Wang
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`teaches that “the chamber impedance changes relatively little between the two
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`power levels PB, PP since a plasma always exist in the chamber.” Ex. 1105 (“Wang”)
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`Trial No. IPR2014-00803
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`at 7:49-51. Dr. Hartsough further conceded that “if impedance changes relatively
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`little during the transition from a low-to a high-density plasma, then it’s indicative of
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`… certainly no unipolar arc…” ’775 Hartsough Depo. at 89:8-24 (emphases
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`added). Accordingly, Wang, teaches the avoidance of arcing as well. Wang teaches
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`the added limitations of claims 7 and 17. Bravman Dec. at ¶¶ 99-100.
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`VIII. CONCLUSION
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`Board correctly found that there was a reasonable likelihood that the claims
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`were unpatentable. None of Zone’s arguments undermine that conclusion. As set
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`forth in the Petition and the supporting declarations, claims 6-10 and 16-20 are
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`unpatentable, under either construction proposed by Zond.
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`Customer Number:
`Tel: (202) 663-6025
`Fax: (202) 663-6363
`
`Respectfully submitted,
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`Petitioner
`By: /David L. Cavanaugh/
`David L. Cavanaugh
`Registration No. 36,476
`Wilmer Cutler Pickering
`Hale and Dorr, L.L.P.
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`Trial No. IPR2014-00803
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`CERTIFICATE OF SERVICE
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`I hereby certify that, on March 31, 2015, I caused a true and correct copy of the
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`foregoing materials:
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` Petitioner’s Reply
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` Exhibits 1125-1129
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` Exhibit Appendix
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`to be served via email, as previously agreed between the parties, on the following
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`counsel of record for Patent Owner:
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`Date of service
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`Manner of service
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`
`Persons Served
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`March 31, 2015
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`Email: gonsalves@gonsalveslawfirm.com;
`bbarker@chsblaw.com; kurt@rauschenbach.com
`
`Dr. Gregory J. Gonsalves
`2216 Beacon Lane
`Falls Church, Virginia 22043
`
`Bruce Barker
`Chao Hadidi Stark & Barker LLP
`176 East Mail Street, Suite 6
`Westborough, MA 01581
`
`
`
`
`/Yung-Hoon Ha/
`Yung-Hoon Ha
`Registration No. 56,368
`7 World Trade Center
`250 Greenwich Street
`New York, NY10007
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`16
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`Exhibit
`1101
`1102
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`1103
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`1104
`1105
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`1106
`1107
`1108
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`1109
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`1110
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`1111
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`1112
`1113
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`1114
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`1115
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`1116
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`1117
`1118
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`Trial No. IPR2014-00803
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`EXHIBIT APPENDIX
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`Description
`U.S. Patent No. 7,808,184 (“the ‘184 Patent”)
`Declaration of Richard DeVito (“DeVito Decl.”)
`D.V. Mozgrin and V.N. Skerbov, High-Current Low-Pressure
`Quasi-Stationary Discharge in a Magnetic Field: Experimental
`Research, Plasma Physics Reports, Vol. 21, No. 5, pp. 400-
`409,1995 (“Mozgrin”)
`A. A. Kudryavtsev, et al, Ionization relaxation in a plasma
`produced by a pulsed inert-gas discharge, Sov. Phys. Tech. Phys.
`28(1), pp. 30-35, January 1983 (“Kudryavtsev”)
`U.S. Pat. No. 6,413,382 (“Wang”)
`Certified Translation of D.V. Mozgrin, High-Current Low-
`Pressure Quasi-Stationary Discharge in a Magnetic Field:
`Experimental Research, Thesis at Moscow Engineering Physics
`Institute, 1994 (“Mozgrin Thesis”)
`Mozgrin Thesis (Original Russian)
`Catalogue Entry for Mozgrin Thesis
`File History for U.S. Pat. No. 7,808,184, Office Action of
`December 8, 2009 (“12/08/09 Office Action”)
`File History for U.S. Pat. No. 7,808,184, Response dated June 3,
`2010 (“06/03/10 Response”)
`File History for U.S. Pat. No. 7,808,184, Notice of Allowance,
`(“06/28/10 Notice of Allowance”)
`Plasma Etching: An Introduction, by Manos and Flamm, pp.
`185-258, Academic Press (1989) (“Manos”)
`U.S. Patent No. 7,147,759 (“the ‘759 Patent”)
`File History for U.S. Pat. No. 7,147,759, Response of May 2,
`2006 (“05/02/06 Resp. of ‘759 patent file history”)
`J. T. Gudmundsson et al., Evolution of the electron energy
`distribution and plasma parameters in a pulsed magnetron
`discharge, Applied Physics Letters, 78(22), pp. 3427-3429, 2001
`(“Gudmundsson”)
`J. A. Thornton Magnetron sputtering: basic physics and
`application to cylindrical magnetrons, J. Vac. Sci. Technol.,
`15(2), pp. 171-177,1978 (“Thornton”)
`European Patent Application 1560943, Response of April 21,
`2008 (“04/21/08 Response in EP 1560943”)
`Leipold et al., High Electron Density, Atmospheric Pressure Air
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`1
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`Trial No. IPR2014-00803
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`Glow Discharges, IEEE, pp. 130-133, (2002) (“Leipold”)
`Claim Chart Based on Mozgrin and Kudryavtsev as used in
`1:13-cv-11570-RGS (“Claim Chart based on Mozgrin and
`Kudryavtsev”)
`Claim Chart Based on Mozgrin and Mozgrin Thesis as used in
`1:13-cv-11570-RGS (“Claim Chart based on Mozgrin and the
`Mozgrin Thesis”)
`Claim Chart Based on Wang and Kudryavtsev as used in 1:13-
`cv-11570-RGS (“Claim Chart based on Wang and
`Kudryavtsev”)
`Claim Chart Based on Wang, Kudryavtsev and Mozgrin as used
`in 1:13-cv-11570-RGS (“Claim Chart based on Wang,
`Kudryavtsev and Mozgrin”)
`List of Related Litigations
`Affidavit of Mr. Fitzpatrick in Support of Motion for Pro Hac
`Vice Admission
`Deposition Transcript of Larry D. Hartsough Ph.D. for U.S.
`Patent No. 6,896,775 (February 19, 2015)
`Deposition Transcript of Larry D. Hartsough Ph.D. for U.S.
`Patent No. 8,125,155 (February 12, 2015)
`Deposition Transcript of Larry D. Hartsough Ph.D. for U.S.
`Patent No. 7,808,184 (February 11, 2015)
`Declaration of John C. Bravman
`U.S. Patent No. 6,896,775
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`1119
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`1120
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`1121
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`1122
`1123
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`1124
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`1125
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`1126
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`1127
`1128
`1129
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`2
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