`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`FUJITSU SEMICONDUCTOR AMERICA, INC., THE GILLETTE COMPANY, 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
`
`U.S. Patent Nos. 7,808,184 and 8,125,155
` _____________________
`
`Cases IPR2014-00477; IPR2014-0479; IPR2014-00799;IPR2014-00803
`
`
`
`Patent Owner’s Demonstrative Exhibits
`
`
`Page 1
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Dr. Chistyakov’s Disclosure
`
`Control Voltage Amplitude
`
`
`“The pulsed power supply 102 can be
`programmed to generate voltage pulses having
`various shapes.” (‘184 Patent, col. 6, lines 8 – 9).
`
`
`“The desired pulse shapes requested from the
`pulsed power supply 102 are superimposed in
`do9ed lines 304, 304', and 304'' onto each of
`the respecIve mulI-‐stage voltage pulses 302,
`302', and 302’” (‘184 Patent, col. 11, lines 56 –
`60).
`
`“The pulsed power supply 102 aKempts to
`maintain a constant voltage.” (‘184 Patent, col.
`7, lines 62 – 63).
`
`“The magnitude of the voltage 280 in the
`second transient stage 278 is chosen to
`generate a strong enough electric field … “ (‘184
`Patent, col. 9, lines 61 – 63).
`
`
`Page 2
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Dr. Chistyakov’s Disclosure
`Selectable Output Energy Capacity
`“In the low power mode, the pulsed power supply
`102 supplies energy to the iniIal plasma at a
`relaIvely slow rate.” (‘184 patent, col. 7, lines 39 –
`40).
`“[T]he pulsed power supply 102 does not supply
`enough energy in the low-‐power mode to drive the
`transient plasma into the strongly-‐ionized
`state…” (184 patent, col. 12, lines 33 – 39”
`“Since there is insufficient energy stored in the
`pulsed power supply 102 in the low-‐power mode
`to create condiIons that can sustain a strongly-‐
`ionized plasma, …” (184 patent, col. 12, lines 20 –
`23).
`“[T]he pulsed power supply 102 transiHons from
`the low-‐power mode to the high-‐power
`mode.” (184 patent, col. 14, lines 62 – 63).
`“[T]he pulsed power supply 102 (in the high-‐power
`mode) supplies a sufficient amount of
`uninterrupted power to drive the weakly-‐ionized
`plasma from the transient non-‐steady state to a
`strongly-‐ionized state.” (‘184 Patent col. 14, lines 1
`– 5).
`
`
`Page 3
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Dr. Chistyakov’s Disclosure
`
`Control Rise Time
`
`“The pulsed power supply 102 can be
`programmed to generate voltage pulses having
`various shapes.” (‘184 Patent, col. 6, lines 11 –
`12).
`
`
`“The peak plasma density can be controlled by
`controlling the slope of the rise Hme of the
`voltage pulse 252.”(‘184 Patent, col. 8, lines 4 –
`17).
`
`
`“The rise Hme of the voltage 280 in the second
`transient stage 278 is chosen.” ( ‘184 Patent,
`col. 9, lines 55 – 59).
`
`
`Page 4
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Dr. Chistyakov’s Disclosure
`
`Fig. 5A Fig. 5B Fig. 5C
`
`Page 5
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Claim 1
`
`Claim 17
`An apparatus for generating a strongly-ionized
`
`a) means for supplying feed gas proximate to an
`
`‘155 Patent: Apparatus Claims
`A strongly-ionized plasma generator comprising:
`plasma, the apparatus comprising:
`a) a chamber for confining a feed gas;
`anode and a cathode assembly;
`b) an anode that is positioned inside the chamber;
`
`
`the anode inside the chamber; and
`cathode assembly,
`and the cathode; and
`rise time of the voltage pulse to
`amplitude and a controlled rise time that
`anode and the cathode assembly.
`cathode assembly.
`
`increases an ionization rate of sputtered material
`atoms so that a rapid increase in electron density
`and a formation of a strongly-ionized plasma occurs
`without forming an arc between the anode and the
`
`c) a cathode assembly that is positioned adjacent to
`d) a pulsed power supply having an output that is
`electrically connected between the anode and the
`
`the pulsed power supply generating at the output a
`voltage pulse having at least one of a controlled
`
`b) means for generating a voltage pulse that
`FORMS A PLASMA between the anode
`c) means for controlling an amplitude AND a
`
`increase an ionization rate of sputtered material
`atoms so that a rapid increase in electron density
`and a formation of a strongly-ionized plasma
`occurs without forming an arc between the
`
`Page 6
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Claim 1
`A method of generating a strongly-ionized
`
`a) supplying feed gas proximate to an anode and
`
`Claim 11
`A method of generating a strongly-ionized
`plasma, the method comprising:
`a) supplying feed gas proximate to an anode and
`
`‘184 Patent: Method Claims
`plasma, the method comprising:
`
`a cathode assembly; and
`a cathode assembly; and
`and the cathode assembly,
`anode and the cathode assembly,
`time
`time
`and the cathode assembly.
`
`that increases an ionization rate so that a
`rapid increase in electron density and a
`formation of a strongly-ionized plasma occurs
`without forming an arc between the anode
`
`b) generating a voltage pulse between the anode
`
`b) generating a voltage pulse between the
`
`the voltage pulse having at least one of a
`controlled amplitude and a controlled rise
`
`the voltage pulse having at least one of a
`controlled amplitude and a controlled rise
`
`that shifts an electron energy distribution in
`the plasma to higher energies that increase an
`ionization rate so as to result in a rapid
`increase in electron density and a formation
`of a strongly-ionized plasma without
`forming an arc between the anode and the
`
`cathode assembly.
`
`Page 7
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Controlled Variable: Eronini
`
`Page 8
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Controlled Variable: Kuo & Sinha
`
`Kuo
`
`
`
`
`
`
`
`
`Sinha
`
`Page 9
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Voltage Control: DeVito
`
`Q: What does it mean to direct the amplitude of a voltage pulse?
`A: Well in this context, you would set the power supply to a specific
`
`magnitude and you would make the power supply go to that magnitude.
`
`You would control it to go for that power – I’m sorry -‐-‐ that voltage.
`
`***
`
`Q: So again, the quesIon is, what does it mean to direct the amplitude of a
`
`voltage pulse?
`
`A: You would set the – you would set the peak magnitude of the voltage
`
`pulse on our power supply and you would control -‐-‐-‐ -‐it would go to that
`
`voltage.
`
`Ex. 2014, DeVito Deposi@on, page 173, line 14 – page 174, line 20.
`
`Page 10
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Control: Bravman
`
`
`A. In general, one understands that if you are going to have a controlled system, it's
`to control some desired output variable. (Zond Ex. 2022, Page 100, line 24 – page 101, line 15, lines 7 -‐
`16 )
`
`Q. So now we menIoned earlier the programmable controller referred to in the
`'155 Patent. Does the programmable controller bear any relaIon to the specified
`target levels shown here in Figure 5C?
`A. It would be typically one job of some means of control or a controller to
`maintain the desired or target voltage pulse waveform. That's the funcIon of
`whatever the controller is or comprises, that would be one of its tasks. ( Zond Ex. 2022,
`Page 44, lines 3 – 14).
`
`
`
`Page 11
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Proposed Claim InterpretaIon
`
`Claim Language at Issue
`
`Proposed Construction
`
`Generating a voltage pulse … having at
`least one of a controlled amplitude and a
`controlled rise time that increases an
`ionization rate so that a rapid increase in
`electron density and a formation of a
`strongly ionized plasma occurs without
`forming an arc …
`
`Generating a voltage pulse whose amplitude
`and/or rise time are controlled variables
`that are directed or restrained to a target
`voltage level and/or a rise time level
`to increase an ionization rate so that a rapid
`increase in electron density and a formation
`of a strongly ionized plasma occurs without
`forming an arc.
`
`
`Page 12
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Proposed InterpretaIon for Claim 17
`
`Claim Language at Issue
`
`Proposed Construction
`
`Controlling and amplitude and rise
`time of the voltage pulse 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 …”
`
`Directing or restraining the
`controlled variables of voltage
`amplitude AND voltage rise time
`to target levels to cause an 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.
`
`Page 13
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Wang: Power Control
`
`Page 14
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Wang: Power Control
`
`“[I]it is advantageous to use a
`target power waveform
`illustrated in figure 6 … “
`Wang, col. 7, lines 13 – 14
`
`
`“[T]he actual waveforms will
`differ from the idealized
`illustrated ones.” (Wang, col.
`7, lines 40 -‐ 41
`
`Page 15
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Kudryavtsev
`“Specially Designed Electrical Circuit”
`
`Measured
`Current
`
`
`Measured
`Voltage
`
`Kudryavtsev, page 33, leJ col.
`
`Page 16
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`DeVito:
`Measured Waveforms Do Not Reveal
`Power Supply Control
`
`Mr. DeVito:
`
`
`Q: When does the pulse in 2B end?
`A: We don’t know that from this diagram. I don’t know that from
`this diagram.
` Ex. 2014, DeVito Deposi@on, page 303, lines 3 – 6.
`
`
`Q; [W]hy does Kudryavtsev bring his voltage so low, way below the
`pre-‐ionizaIon voltage?
`A: I mean, I don’t know the -‐-‐-‐ it could be a physical phenomenon
`of his power supply interacIng with his plasma. I don’t know.
`***
`Q: But apart from that, you don’t have any understanding as to
`why Kudryavtsev would drop the voltage?
`A: I mean, you keep saying Kudryavtsev dropping the voltage as if
`he’s doing it on purpose. I think that is wrong – a wrong
`interpretaIon. I mean the voltage is dropping as a result of -‐ he’s
`not telling it to go there.
` Ex. 2014, DeVito Deposi@on, page 300, lines 10 –
` page 310, lines 7 – 15.
`
` 16;
`
`
`
`Measured
`Current
`
`
`Measured
`Voltage
`
`Page 17
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`Bravman:
`Measured Waveforms Do Not Reveal
`Power Supply Control
`Q. And I think, isn't this true, generally, that when you measure the voltage across a set of electrodes, that
`because of the other variables, you can't deduce from the waveforms alone the status or condiIon of the
`power supply?
` A. So I think I understand that quesIon. It is a very -‐-‐ it is a raIonale but very broad quesIon. One can
`measure the voltage across terminals precisely as a funcIon of Ime with high temporal resoluIon. And that
`will tell you, and, in fact, does tell you what the power supply is actually capable of developing as a funcIon
`of Ime in terms of voltage across a load. That can be done with high precision.
` Q. Right. But from that waveform alone, you can't tell what the power supply's target voltage amplitude or
`energy capacity is just from the measured waveform alone; is that correct?
`A. If the only informaIon one had available was that measured actual voltage and nothing else, then if I
`understand your quesIon correctly, right, one could not say if, for instance, the power supply exhausted its
`total energy supply or whether it was operaIng at 1% of peak load. That single piece of data I don't see how
`it could tell you that. You would have to know other things. (Ex. 2022, Bravman, page 145, line 16 – page
`146, line 23).
`
`Q. So, again, since it is a measured waveform, when the voltage drops at the end of the stage that you have
`highlighted in red or pink, can you tell from looking at this waveform whether that drop in voltage was the
`result of the power supply controller deciding to step the voltage down or the power supply controller
`lacking the capacity to maintain the voltage where it wanted it to be?
`A. Again, in the abstract by itself, no, you cannot. (Ex. 2022,Bravman, page 191, line 13 – page 192, line 2).
`
`
`Page 18
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`‘184 Patent: MulI-‐Stage Pulse
`pulse comprise a mulI-‐stage voltage pulse.
`pulse comprise a mulI-‐stage voltage pulse
`
`The method of claim 1 wherein the voltage
`
`The method of claim 11 wherein the voltage
`
`Claim 5
`
`Claim 15
`
`Page 19
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`‘184 Patent: Long Plasma LifeIme
`than 200 μsec.
`than 200 μsec.
`
`Claim 7
`The method of claim 1 wherein a lifeIme
`of the strongly-‐ionized plasma is greater
`
`Claim 17
`The method of claim 11 wherein a lifeIme
`of the strongly-‐ionized plasma is greater
`
`Page 20
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`‘155 Patent: Long Plasma LifeIme
`plasma for greater than 200 μsec.
`than about 200 μsec.
`
`
`The plasma generator of claim 1 wherein a
`lifeIme of the strongly-‐ionized plasma is greater
`
`The apparatus of claim 17 further comprising a
`means for sustaining the strongly-‐ionized
`
`Claim 16
`
`Claim 19
`
`Page 21
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`
`
`‘155 Patent: Supplemental Energy Store
`
`Claim 9
`The plasma generator of claim 1 further
`comprising an energy storage device that is
`electrically coupled to the cathode assembly,
`the energy storage device discharging energy
`into the plasma to enhance the rapid
`increase in electron density and the
`
`formaIon of the strongly-‐ionized plasma
`
`Speci0ication
`“In some embodiments, the plasma
`spuKering apparatus includes an energy
`storage device that provides a source of
`energy that can be controllably released into
`the plasma.” Ex. 1001, ‘155 patent, col. 3,
`lines 43 – 45.
`
`
`
`Page 22
`
`Fujitsu et. al. v. Zond
`IPR Nos. 2014-00477; 2014-00479; 2014-00799; and 2014-00803
`Zond Exhibit 2023
`
`