UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________________________
`
`THE GILLETTE COMPANY, FUJITSU SEMICONDUCTOR LIMITED,
`FUJITSU SEMICONDUCTOR AMERICA, INC., 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
`Trial No. IPR2014-008031
`
`
`
`PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION FOR
`OBSERVATION ON CROSS-EXAMINATION OF PETITIONER’S REPLY
`WITNESS DR. JOHN C. BRAVMAN
`
`
`1 Cases IPR2014-00799 and IPR2014-00858, IPR2014-00996 and IPR2014-01061
`have been joined with the instant proceeding.
`
`

`

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`I. 
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`II. 
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`Trial No. IPR2014-00803
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`TABLE OF CONTENTS
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`
`INTRODUCTION ........................................................................................... 1 
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`RESPONSES TO OBSERVATIONS ON DR. BRAVMAN’S
`TESTIMONY .................................................................................................. 1 
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`A.  Observation 1 ........................................................................................ 1 
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`B. 
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`C. 
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`Observation 2 ........................................................................................ 2 
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`Observation 3 ........................................................................................ 4 
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`D.  Observation 4 ........................................................................................ 5 
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`E. 
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`F. 
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`Observation 5 ........................................................................................ 6 
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`Observation 6 ........................................................................................ 8 
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`G.  Observation 7 ...................................................................................... 10 
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`H.  Observation 8 ...................................................................................... 11 
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`I. 
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`Observation 9 ...................................................................................... 13 
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`i
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`Trial No. IPR2014-00803
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`INTRODUCTION
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`I.
`
`Petitioner submits this response to Patent Owner Zond’s Motion for
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`Observation on Cross-Examination of Dr. Bravman, Paper No. 46 (“Observation”).
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`Patent Owner presents nine observations on Dr. Bravman’s testimony. While
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`Petitioner believes that the testimony will be appropriately viewed and weighed by
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`the Board, the specific observations presented by Patent Owner mischaracterize the
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`testimony of Dr. Bravman, as specified below and therefore are not probative of
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`any material issue before the Board.
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`II. RESPONSES TO OBSERVATIONS ON DR. BRAVMAN’S
`TESTIMONY
`A. Observation 1
`Patent Owner contends that Dr. Bravman’s testimony indicates “the
`
`terminology of control systems is relevant to the claimed control.” Observation at
`
`1. More specifically, the Patent Owner contends that “the terminology of control
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`systems such as described in Eronini is applicable to such control.” Observation at
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`1. Actually, Dr. Bravman’s testified to the exact opposite.
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`As Patent Owner’s own “Excerpt A” and “Excerpt B” show, Dr. Bravman
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`explained broadly that power supplies would generally have “some means of
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`controlling the power supply’s output,” that could “vary from something as simple
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`as on/off switches to something quite sophisticated.” Bravman Dep. at 11:20-24
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`(Ex. 1131). Patent Owner then specifically asked whether a feedback control
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`1
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`Trial No. IPR2014-00803
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`system, such as those described in Eronini, would also be understood by one
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`skilled in the art to be found in the ’184 patent’s specification. In response, Dr.
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`Bravman explicitly testified that the ’184 patent does not teach such a feedback
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`control system, nor does it require such a feedback control system to be read into
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`the claims under the broadest reasonable interpretation standard:
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`Q. Now, if one skilled in the art reads that language, "attempts
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`to maintain," that the power supply attempts to maintain, would that in
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`any way suggest the possibility of a feedback control system?
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`MR. MAIER: Objection to form. Go ahead.
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`A. My answer is no.
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`Bravman Dep. at 117:11-122:5. (Ex. 1131). Thus, the cited testimony does not
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`support the argument in Patent Owner’s Response at pages 19-21 (IPR2014-799).
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`B. Observation 2
`The Patent Owner contends that Dr. Bravman’s testimony supports its
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`argument that “the ‘155 patent includes a programmable controller that is
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`programmed to various target voltage amplitudes depicted as dotted lines in Figure
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`5C of the ‘155 patent.” Observation at 3. Again, Dr. Bravman’s testimony was
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`exactly the opposite.
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`The testimony cited by the Patent Owner merely highlights that one skilled
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`in the art would understand that “some [power supply] may or may not include
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`2
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`Trial No. IPR2014-00803
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`various circuits to do thing such as program it” and that “the phrase programmable
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`controller is understood to workers of skill.” Bravman Dep. at 39:9 – 40:13;
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`emphases added (Ex. 1131). However, when Dr. Bravman was specifically asked
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`whether the ‘155 Patent discloses a programmable controller, Dr. Bravman
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`testified that it does not.
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`Q: And it says, “The pulsed power supply 102 can be
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`programmed.” Now, you mentioned earlier that you dealt with
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`programmable controllers. Does this sentence in the '155 Patent refer
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`to a programmable controller?
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`MR. MAIER: Object to form; foundation.
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`A: I don't believe the phrase programmable controller is in
`
`here. Programmed means has to be directed or in some way
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`instructed, told, to create the pulses that are required that it says have
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`various shapes….
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`Bravman Dep. at 38:10 – 39:8; emphasis added (Ex. 1131).
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`Q: Now, that target voltage level to one skilled in the art, how is
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`-- how is that target level set in the controller?
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`MR. MAIER: Object to form; foundation.
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`A: I think the patent doesn't describe the actual means for
`
`doing that.…
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`3
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`Trial No. IPR2014-00803
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`Bravman Dep. at 45:5-16; emphasis added (Ex. 1131). Thus, Dr. Bravman’s
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`testimony is that the power supply disclosed by the ‘184 patent does not disclose a
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`programmable controller.
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`C. Observation 3
`The Patent Owner contends that Dr. Bravman’s testimony “refutes the
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`Petitioners’ contention that the ‘184 patent admits (in its figure 10) that the claimed
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`pulse voltage control was known in the prior art.” Observation at 5. Dr.
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`Bravman’s testimony is consistent with Petitioner’s arguments..
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`Dr. Bravman testified that the admitted prior art power supply shown in
`
`figure 10 can generate the voltage pulses shown in Figure 5. Figure 5 is alleged by
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`the Patent Owner to meet the claimed voltage control. See Patent Owner’s
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`Response at 12.
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`Q. Well, in order to generate multi-step voltage pulses like we
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`just saw in Figure 5C, would you need an additional controller beyond
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`what's shown in Figure 10?
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`MR. MAIER: Objection; foundation. Hypothetical.
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`A. … “Figure 10 illustrates a schematic diagram of a pulsed
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`power supply that can generate multi-step voltage pulses according to
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`the present invention.” … So what the author of the patent is
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`directing us here to is this prior art, pulse power supply can generate
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`4
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`Trial No. IPR2014-00803
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`multi-step voltage pulses according to the present invention. So the
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`multi-step pulses such as you and I have been discussing in Figure
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`5.
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`Bravman Dep. at 70:15 – 71:16; emphases added (Ex. 1131). Thus, Dr. Bravman’s
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`testimony is consistent with the positions taken in Petitioner’s Reply at pp. 3-4 that
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`the admitted prior art power supply shown in Figure 10 can generate the claimed
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`voltage control.
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`D. Observation 4
`The Patent Owner contends that Dr. Bravman’s testimony “confirm[s] that a
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`controller could control the rise time of voltage amplitude using a power supply,
`
`such as shown in figure 10, by controlling the amount of available stored energy of
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`the supply, as proposed in the ‘155 patent.” Observation at 8. The Patent Owner
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`alleges that this testimony is “relevant to the Patent Owner’s argument … that the
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`‘184 patent teaches that voltage rise time can be controlled to a desired rate by the
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`combination of a selected target voltage level and a selected output energy mode.”
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`Observation at 8; emphasis added. This is incorrect.
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`The testimony cited by the Patent Owner merely indicates that “if all of the
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`switches, 558, were closed” as opposed to “some relatively small percentage of
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`them were closed,” this would lead to a “higher level of energy storage [which]
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`could raise the output voltage faster.” Bravman Dep. at 112:12-11:17 (Exhibit
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`5
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`Trial No. IPR2014-00803
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`1131). In other words, Dr. Bravman testified that when more switches are closed,
`
`more energy or power can be provided, which would lead to a higher rise time.
`
`Indeed, the cited testimony is more consistent and more relevant to Dr. Bravman’s
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`opinion, expressed in his Declaration, that “[i]t is not because the actual voltage
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`amplitude and rise time were directed or restrained to target voltage amplitude and
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`rise time. Rather, the ‘184 patent teaches that the amplitude and rise time of the
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`voltage pulse is indirectly controlled by setting a different parameter – the power
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`mode.” Bravman Dec. at ¶ 41; see also Bravman Dep. at 26:17-24 (Exhibit 1131).
`
`Moreover, the cited testimony is consistent with Dr. Bravman’s opinion that
`
`“Wang teaches control of the amplitude and/or rise time when rapidly forming a
`
`strongly ionized plasma in the same manner as taught in the ‘184 patent.”
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`Bravman Dec. at ¶81.
`
`E. Observation 5
`The Patent Owner contends that Dr. Bravman’s testimony “acknowledges a
`
`relationship between voltage amplitude and arcing, and thus indirectly
`
`acknowledges the importance of the claimed voltage control to the claimed arc
`
`avoidance.” Observation at 10. The Patent Owner mischaracterizes Dr.
`
`Bravman’s testimony.
`
`Dr. Bravman testified that in the hypothetical asked by Patent Owner’s
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`counsel (i.e., when all other variables are held constant), a drop in voltage
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`6
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`Trial No. IPR2014-00803
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`amplitude would reduce the probability of arcing.
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`A. … unfortunately, you can't look just at voltage because
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`voltage is a function of imped[a]nce that will determine arcing. So
`
`whether or not what's described in 5C, as you directed me, actually
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`achieves that end, I don't think one can say because in dropping the
`
`voltage, which one would understand all other things being equal
`
`would drop the probability of arcing. Other things are not equal. …
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`Bravman Dep. at 66:5 – 67:14; emphases added (Ex. 1131). Dr. Bravman testified
`
`that in a more realistic system, it is the impedance that will determine the
`
`likelihood of arcing.
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`A. [S]o you are positing for me a situation in which Figure 8
`
`obtains but with the higher plateau voltage as a target of Figure 3,
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`would the arcing therefore be more likely?
`
`Q. Yes.
`
`A. I believe we talked about a similar scenario this morning. In
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`a given experimental setup or run with a given gas density and all that,
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`if you increase the voltage, the power is going to increase unless the
`
`imped[a]nce changes. So one would expect that in this operational
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`regime, meaning the operational regime depicted in Figure 8, higher
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`voltages, within limits, would produce more current and therefore
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`7
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`Trial No. IPR2014-00803
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`higher power levels. So the statistical process of arcing is related to,
`
`all things being equal, the voltage across the gap. Whether or not a
`
`given system would actually evidence more arcing, I don't know, but
`
`it is certainly true that the statistical probability would go up, all
`
`things being equal, if the voltage was higher. In a plasma system, if
`
`the voltage is higher, the density gets higher, you get higher
`
`conducting pathways. That's why I am saying I don't see it as a yes-
`
`no answer.
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`Bravman Dep. at 152:18 – 154:9; emphases added (Ex. 1131) . Thus, Dr.
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`Bravman’s testimony is consistent with the position taken in Petitioner’s
`
`Reply Brief at pages 2-3.
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`F. Observation 6
`The Patent Owner contends that Dr. Bravman “admitted that Wang makes
`
`no mention of a desired voltage amplitude of his pulses.” Observation at 11. The
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`Patent Owner mischaracterizes Dr. Bravman’s testimony.
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`The testimony cited by the Patent Owner reflects Dr. Bravman’s testimony
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`that Wang does not show any “experimental detail” with “actual numbers.”
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`However, Dr. Bravman testified that Wang teaches producing any desired voltage
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`pulses, which one skilled in the art would readily understand to have the desired
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`voltage amplitudes.
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`8
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`Trial No. IPR2014-00803
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`Q. Now, does Wang provide any indication of how that
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`controller operates?
`
`A. I believe he provides indication of how it operates. He
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`clearly discusses that it does operate and that in different
`
`experimental regimes, it will produce desirable pulse trains of
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`negative voltage.
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`Bravman Dep. at 123:19 – 124:8; emphases added (Ex. 1131).
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`Q. Now, where in Figure 7 is there any indication that the
`
`waveform shown is representative of voltage amplitude?
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`A. Well, it is coming out of a pulse DC supply and it would be
`
`my testimony that any worker of skill would understand in such a
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`drawing that this was representative of the pulse DC voltage that
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`element 80 DC supply actually outputs. … So that text plus that
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`figure plus the ordinary knowledge of a worker of skill I believe
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`would clearly indicate that the pulse train shown in Figure 7 is a
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`pulse train of voltages.
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`Bravman Dep. at 129:13 – 130:19; emphases added (Ex. 1131). Thus, Dr.
`
`Bravman testified that one skilled in the art would understand Wang to teach
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`generating various desired voltage pulse amplitudes.
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`9
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`Trial No. IPR2014-00803
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`G. Observation 7
`The Patent Owner contends that Dr. Bravman testified “that one skilled in
`
`the art cannot deduce the operating condition of a power supply from the actual
`
`voltage across the electrodes.” Observation at 12. According to the Patent Owner,
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`the testimony “is relevant to Petitioner’s argument that if the actual voltage across
`
`a pair of plasma electrodes has a rise time, then that rise time is necessarily due to
`
`the control by the power supply (see, e.g., Petition at page 18, citing to Wang’s
`
`statement that ‘rise times and fall times are expected.’)” Observation at 12. Again,
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`the Patent Owner mischaracterizes Dr. Bravman’s testimony.
`
`As the testimony cited by the Patent Owner itself shows, the Patent Owner
`
`posed a very narrow question: “But from the waveform alone, you can’t tell what
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`the power supply’s target voltage amplitude or energy capacity is just from the
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`measured waveform alone.” Dr. Bravman appropriately responded by repeating
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`this assumption: “If the only information one had available was that measured
`
`actual voltage and nothing else… That single piece of data I don’t see how it
`
`could tell you that. You would have to know other things.” Bravman Dep. at
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`146:9-23 (Ex. 1131).
`
`As discussed above with respect to Petitioner’s Response to Observation 4,
`
`Dr. Bravman testified the rise time could be controlled simply by setting a different
`
`power mode (e.g., closing more switches of the power supply). See Bravman Dep.
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`10
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`

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`Trial No. IPR2014-00803
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`at 113:18 – 114:13 (Ex. 1131). Thus, Dr. Bravman’s testimony is consistent with
`
`the Petitioner’s position that “one of ordinary skill in the art would be able to
`
`adjust the rise times of Wang’s voltage pulses to achieve the claimed rapid increase
`
`in electron density. Devito Decl. ¶110 (Ex. 1005).”2 IPR2014-477 Petition at 18.
`
`H. Observation 8
`The Patent Owner contends that Dr. Bravman testified “that his proposed
`
`definition of claim term ‘stage’ was not previously presented by Petitioners, that
`
`the definition is circular, and that it provides no way for one to identify a stage or
`
`determine where one stage ends and another begins.” Observation at 13. The
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`Patent Owner mischaracterizes Dr. Bravman’s testimony on all three points.
`
`First, Dr. Bravman’s explanation of the term “stage” was in response
`
`to the Patent Owner’s newly proposed construction of the term “multi-stage
`
`voltage pulse.” See Bravman Dep. at 174:12-24; emphases added (Ex. 1131)
`
`(“A. No, that's not one of the phrases that was construed. I also note in
`
`paragraph 84 that “The patent owner did not the [sic] previously propose a
`
`construction of a multi-stage voltage pulse." So I think – I think no one
`
`did.).
`
`Second, Dr. Bravman testified that one skilled in the art would readily
`
`
`2 Petitioner has also cited to the Petition of IPR 2014-00477 to be consistent with
`the Patent Owner’s Observation.
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`11
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`Trial No. IPR2014-00803
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`be able to identify where one stage ends and another begins in light of the
`
`teachings of the ’184 Patent. See Bravman Dep. at 178:17 – 180:5;
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`emphases added (Ex. 1131). (“A. [T]he figures in light of the text make it
`
`clear what the authors of the '184 are using or meaning by the word stage
`
`and region. There are two or three regions, let's say, three regions shown in
`
`Figure 7A and Figure 8. One I am sure can define many other regions in
`
`some abstract way, but I didn't do that. I used what the authors of the
`
`patent, of the '184 Patent themselves, said about those regions.”)
`
`Third, the excerpt cited by the Patent Owner demonstrates that Dr.
`
`Bravman did not testify that “the definition is circular.” Observation at 13.
`
`Rather, Dr. Bravman merely explained that the claim term “stage” is used
`
`interchangeably in the specification of the ‘184 Patent as either “stage” or
`
`“region” and any circularity is a result of the patent’s own ambiguity. See
`
`Bravman Dep. at 183:2-14; emphases added (Ex. 1131) (“I am dealing with
`
`linguistic ambiguity in the patent itself. So a stage in quotes refers to
`
`different stages or regions of plasma generation. Stages or regions making
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`direct reference to the language of the patent itself.”).
`
`Thus, Dr. Bravman’s testimony further confirms and explains the
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`broadest reasonable interpretation of the term “multi-stage voltage pulse”
`
`applied by the Petitioners is based on the descriptions provided in the ’184
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`12
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`Trial No. IPR2014-00803
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`patent itself.
`
`Observation 9
`
`I.
`The Patent Owner contends that Dr. Bravman’s “testimony shows that the
`
`alleged example of ‘stages’ in Mozgrin’s Voltage Waveform (which Bravman
`
`improperly imports into the teachings of Wang) may have been due merely to an
`
`abrupt change in the impedence of the plasma, not due to any changes generated by
`
`a power supply.” Observation at 15. The Patent Owner again mischaracterizes Dr.
`
`Bravman’s testimony.
`
`Dr. Bravman’s testimony cited by the Patent Owner is in relation to the
`
`figure from the ‘775 Patent. Moreover, the Patent Owner cites only a portion of
`
`Dr. Bravman’s full testimony. Dr. Bravman’s full testimony explains that one
`
`skilled in the art would understand the different stages to be generated by changes
`
`generated by the power supply.
`
`A. But I believe strongly that a worker of skill would
`
`understand in the context of the full documents that the power
`
`supply was directed by some agency to step down the voltage when
`
`this stage or region of steady state was achieved. But, again, looking
`
`just, out of context, looking at the figure one cannot say.
`
`Q. So the full documents you referred to, you are referring to
`
`the teaching of that '775 Patent from which this diagram came?
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`A. Yes. And what a worker of skill I think would understand
`
`in the context of this kind of technology.
`
`Bravman Dep. at 191:13-192:16; emphases added (Ex. 1131). In fact, Dr.
`
`Bravman testified in the same manner when discussing Mozgrin’s voltage
`
`waveform as well. See Bravman Dep. at 187:6 – 188:5; emphases added (Ex.
`
`1131).
`
`
`
`Finally, Dr. Bravman did not improperly import “Mozgrin’s Voltage
`
`Waveform” into Wang. Rather, Dr. Bravman testified that both the ‘775 Patent and
`
`Mozgrin are being used to illustrate what one skilled in the art would understand
`
`from the teachings of Wang.
`
`Q. Now, are you relying upon the Mozgrin reference for your
`
`conclusions concerning Claims 5 and 15?
`
`A. No, I am just showing that a worker of skill who would have
`
`access to these kind of documents, that is the Mozgrin paper and the
`
`power supply of Wang, how it would just be additional evidence or
`
`bolstering of the opinions I have offered. It is consistent with and it is
`
`certainly prior art.
`
`Bravman Dep. at 183:19 – 184:5; see also id. at 189:11-25 (Ex. 1131).
`
`Accordingly, Dr. Bravman’s testimony confirms that one skilled in the art
`
`would understand the different stages to be generated by changes generated by the
`
`14
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`Trial No. IPR2014-00803
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`power supply described in Wang, as illustrated using examples found in Mozgrin
`
`and the ‘775 Patent.
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`
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`Dated: May 14, 2015
`
`Respectfully Submitted,
`
`/David L. Cavanaugh/
`
`David L. Cavanaugh
`Registration No. 36,476
`WILMER CUTLER PICKERING
`HALE AND DORR LLP
`1875 Pennsylvania Avenue, N.W.
`Washington, D.C. 20006
`david.cavanaugh@wilmerhale.com
`Tel.: 202-663-6000
`Fax: 202-663-6363
`
`
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`15
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`Trial No. IPR2014-00803
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`CERTIFICATE OF SERVICE
`
`I hereby certify that on May 14, 2015, I caused a true and correct copy of the
`
`foregoing materials:
`
` Petitioner’s Response to Patent Owner Zond’s Motion for Observation
`on Cross-Examination of Dr. Bravman
` Exhibit 1131
` Exhibit Appendix
`
`to be served via e-mail, as previously agreed by the parties, on the following
`
`attorneys of record:
`
`
`
`Dr. Gregory J. Gonsalves
`2216 Beacon Lane
`Falls Church, VA 22043
`(571) 419-7252
`gonsalves@gonsalveslawfirm.com
`
`Bruce Barker
`Chao Hadidi Start & Barker LLP
`176 East Mail Street, Suite 6
`Westborough, MA 01581
`bbarker@chsblaw.com
`
`
`
`
`
` /Yung-Hoon Ha/
` Yung-Hoon Ha
` Registration No. 56,368
`
`
`
`16
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`EXHIBIT APPENDIX
`
`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”)
`
`17
`
`Exhibit
`1101
`1102
`
`1103
`
`1104
`1105
`
`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
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`

`

`Trial No. IPR2014-00803
`Petitioner’s Response to Patent Owner’s Motion for Observation
`
`
`Leipold et al., High Electron Density, Atmospheric Pressure
`Air 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
`Declaration of Brett Rismiller in support of Petitioner’s
`motion for Pro Hac Vice Admission
`Dr. Bravman’s Deposition Transcript and Signed Errata Sheet
`
`1118
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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
`
`1130
`1131
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`
`
`18
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`