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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________________
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`THE PETITIONERS COMPANY
`Petitioner
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`v.
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`ZOND, LLC
`Patent Owner
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`U.S. Patent No. 7,808,184
`Claims 1 – 5, 11 - 15
`Claims 6 – 10, 16 - 20
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`_____________________
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`Inter Partes Review Case No. 2014-00799
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`Inter Partes Review Case No. 2014-00803
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`_____________________
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`DECLARATION OF LARRY D. HARTSOUGH, Ph.D.
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`TABLE OF CONTENTS
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`I. Education and Professional Background ................................................................................... 1
`II. Summary of Opinions: Claims 1 - 20 ...................................................................................... 5
`III. Legal Standards ........................................................................................................................ 7
`A. Level of Ordinary Skill in the Art ............................................................................ 7
`B. Claim Interpretation Issues for Claims 1 - 20 .......................................................... 8
`C. Legal Standards for Anticipation ........................................................................... 10
`D. Legal Standards for Obviousness ........................................................................... 10
`IV. Background Topics ................................................................................................................ 12
`A. Voltage, current, impedance and power ................................................................. 13
`B. Control systems ...................................................................................................... 15
`C. Set point (Controlled Parameter) ............................................................................ 18
`D. Power Control vs Voltage Control ......................................................................... 19
`E. Magnetron Sputtering History and Operation ........................................................ 21
`II. Patent 7,808,184 ..................................................................................................................... 26
`A. The Programmable Power Modes: Low Power Mode vs. High Power Mode ....... 28
`B. Fig 2. Of the ‘184 patent: Plasma Current and Voltage ........................................ 32
`C. Figure 3 of the ‘184 patent ..................................................................................... 35
`D. Plasma Density ....................................................................................................... 37
`E. Figure 4 of the ‘184 Patent ..................................................................................... 38
`F. Figs 5A – 5C ........................................................................................................... 42
`G. Figs. 6A – 6B; 7A,B ............................................................................................... 45
`a. Stability of plasma transition to high density and risk of arc .......................................... 45
`H. Fig. 8 ...................................................................................................................... 47
`III. Prior Art .................................................................................................................................. 48
`A. Wang ...................................................................................................................... 48
`a. Wang’s Power Pulses ...................................................................................................... 48
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`b. Arcing in Wang ............................................................................................................... 52
`c. Variances between Wang’s Target Power Levels and Actual Power ............................. 55
`B. Kudryavtsev ........................................................................................................... 59
`a. Arcing in Kudryastev ...................................................................................................... 60
`b. Lack of Disclosure of Controlled Rise Time or Amplitude ............................................ 68
`c. A person of ordinary skill in the art would not combine Wang with Kudryavtsev ......... 71
`IV. Conclusions and Opinions Regarding Claims 1 - 20 ............................................................. 74
`V. Additional Conclusions and Opinions Regarding the Dependent Claims ............................. 77
`A. Claims 5, 15 .......................................................................................................... 77
`B. Dependent Claims 7, 17 ......................................................................................... 80
`V. Response to the Institution Decision ...................................................................................... 82
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`I, Larry D. Hartsough, Ph.D., hereby declare:
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`1.
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`I am making this declaration at the request of patent owner
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`Zond, LLC, in the matter of the Inter Partes Reviews (IPRs) of U.S. Patent
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`No. 7,808,184 (the “’184 Patent”), as set forth in the above caption.
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`2.
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`I am being compensated for my work in this matter at the rate of
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`$300 per hour. My compensation in no way depends on the outcome of this
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`proceeding.
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`3.
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`The list of materials I considered in forming the opinions set
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`forth in this declaration includes the ‘184 patent, the file history of the ‘184
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`patent, the Petitions for Inter Partes Review and the exhibits, the PTAB’s
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`Institution Decisions, and the prior art references discussed below.
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`I. Education and Professional Background
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`4. My formal education is as follows. I received a Bachelors of
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`Science degree in 1965, Master of Science degree in 1967, and Ph.D. in
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`1971, all in Materials Science/Engineering from the University of California,
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`Berkeley.
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`5.
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`I have worked in the semiconductor industry for approximately
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`30 years. My experience includes thin film deposition, vacuum system
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`design, and plasma processing of materials. I made significant contributions
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`to the development of magnetron sputtering hardware and processes for the
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`metallization of silicon integrated circuits. Since the late 1980’s, I have also
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`been instrumental in the development of standards for semiconductor
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`fabrication equipment published by the SEMI trade organization.
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`6.
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`From 1971-1974, I was a research metallurgist in the thin film
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`development lab of Optical Coating Laboratory, Inc. In 1975 and 1976, I
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`developed and demonstrated thin film applications and hardware for an in-
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`line system at Airco Temescal. During my tenure (1977-1981) at Perkin
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`Elmer, Plasma Products Division, I served in a number of capacities from
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`Senior Staff Scientist, to Manager of the Advanced Development activity, to
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`Manager of the Applications Laboratory. In 1981, I co-founded a
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`semiconductor equipment company, Gryphon Products, and was VP of
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`Engineering during development of the product. From 1984-1988, I was the
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`Advanced Development Manager for Gryphon, developing new hardware
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`and process capabilities. During 1988-1990, I was Project Manager at
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`General Signal Thinfilm on a project to develop and prototype an advanced
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`cluster tool for making thin films. From 1991-2002, I was Manager of PVD
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`(physical vapor deposition) Source Engineering for Varian Associates, Thin
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`Film Systems, and then for Novellus Systems, after they purchased TFS.
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`Since then, I have been consulting full time doing business as UA
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`Associates, where my consulting work includes product development
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`projects, film failure analysis, project management, technical presentations
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`and litigation support.
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`7.
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`Throughout my career, I have developed and/or demonstrated
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`processes and equipment for making thin films, including Al, Ti-W, Ta, and
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`Cu metallization of silicon wafers, RF sputtering and etching, and both RF
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`and dc magnetron reactive sputtering, for example SiO2, Al2O3, ITO
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`(Indium-Tin Oxide), TiN, and TaN. I have been in charge of the
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`development of two sputter deposition systems from conception to prototype
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`and release to manufacturing. I have also specialized in the development and
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`improvement of magnetically enhanced sputter cathodes. I have experience
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`with related technology areas, such as wafer heating, power supply
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`evaluation, wafer cooling,
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`ion beam sources, wafer handling by
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`electrostatics, process pressure control, in-situ wafer/process monitoring,
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`cryogenic pumping, getter pumping, sputter target development, and
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`physical, electrical and optical properties of thin films.
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`8.
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`I am a member of a number of professional organizations
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`including the American Vacuum Society, Sigma Xi (the Scientific Research
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`Society), and as a referee for the Journal of Vacuum Science & Technology.
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`I have been a leader in the development of SEMI Standards for cluster tools
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`and 300mm equipment, including holding various co-chair positions on
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`various standards task forces. I have previously served as a member of the
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`US Department of Commerce’s Semiconductor Technical Advisory
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`Committee.
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`9.
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`I have co-authored many papers, reports, and presentations
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`relating to semiconductor processing, equipment, and materials, including
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`the following:
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`a. P. S. McLeod and L. D. Hartsough, "High-Rate Sputtering of
`Aluminum for Metalization of Integrated Circuits", J. Vac. Sci.
`Technol., 14 263 (1977).
`b. D. R. Denison and L. D. Hartsough, "Copper Distribution in
`Sputtered Al/Cu Films", J. Vac. Sci. Technol., 17 1326 (1980).
`c. D. R. Denison and L. D. Hartsough, "Step Coverage in Multiple
`Pass Sputter Deposition" J. Vac. Sci. Technol., A3 686 (1985).
`d. G. C. D’Couto, G. Tkach, K. A. Ashtiani, L. Hartsough, E. Kim,
`R. Mulpuri, D. B. Lee, K. Levy, and M. Fissel; S. Choi, S.-M.
`Choi, H.-D. Lee, and H. –K. Kang, “In situ physical vapor
`deposition of ionized Ti and TiN thin films using hollow cathode
`magnetron plasma source” J. Vac. Sci. Technol. B 19(1) 244
`(2001).
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`10. My areas of expertise include sputter deposition hardware and
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`processes, thin film deposition system design and thin film properties. I am a
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`named inventor on twelve United States patents covering apparatus, methods
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`or processes in the fields of thin film deposition and etching. A copy of my
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`CV is attached as Exhibit A.
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`II. Summary of Opinions: Claims 1 - 20
`In my opinion, the plasma generation methods described in
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`11.
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`claims 1 through 20 of the ‘184 patent are neither taught by Wang and
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`Kudryavtsev, nor are obvious in view of them.
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`12. Neither Wang nor Kudryavtsev teach the claimed method that
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`generates at least one of a controlled voltage amplitude or voltage rise time
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`to form a strongly-ionized plasma without forming an arc. Wang does not
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`teach controlling voltage at all, but instead teaches controlling power pulses
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`to a desired power level. As I explain below, such control of a pulse’s
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`power level is very different from controlling the voltage amplitude and rise
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`time of a pulse. Any voltage pulses disclosed by Wang are merely a
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`consequence of the system attempting to deliver the desired power level, i.e.,
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`the voltage (and current) are driven by the power supply of Wang based
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`upon the desired power level but are determined by the plasma impedance.
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`13. Moreover, Wang does not teach pulsing at all without forming
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`an arc. Wang’s controlled power level pulses will cause an arc condition
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`when used to ignite a plasma. The ‘184 patent, in contrast, shows many
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`examples of pulses whose voltage amplitude and rise time are controlled so
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`that they can ignite plasma without arcing. The control of pulse voltage
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`amplitude/rise time are very different from controlling pulse power level,
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`and such control has advantages that Wang overlooked.
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`14. Kudryavtsev also does not teach the claimed power supply or
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`suggest it, even if its teachings are considered together with those of Wang.
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`Importantly, the system of Kudryavtsev is a flash tube which is designed to
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`apply a high voltage greater than the breakdown voltage across an inert gas,
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`resulting in a brilliant flash of light for a short duration. Flash tubes apply a
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`voltage greater than the breakdown voltage, which may initiate the flash by
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`an arc between the cathode and the anode.
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`15. Kudryavtsev describes a voltage pulse
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`that causes an
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`“explosion” in electron density that appears to cause an arcing condition as
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`shown in his measured voltage and current waveforms. In fact, the paper
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`cited by Mr. DeVito to explain arcing includes a waveform which
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`demonstrates arcing, and this waveform shows similar conditions to those
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`shown by Kudryavtsev. Thus, the flash tube of Kudryavtsev is designed to,
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`and likely does in fact, form an arc which initiates its “explosive” increase in
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`electron density and its brilliant flash of light. A person of ordinary skill in
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`the art would therefore not refer to Kudryavtsev at all when designing a
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`plasma generator whose very purpose is to form a strongly-ionized plasma
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`without forming an arc.
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`16. Thus, for these reasons and the reasons described below, a
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`person of ordinary skill in the art would look to neither the Wang nor
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`Kudryavtsev references in attempting to design the claimed invention of
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`generating a strongly-ionized plasma using a voltage pulse with a controlled
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`rise time or amplitude to form a strongly-ionized plasma without forming an
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`arc. Wang does not teach a person of ordinary skill in the art how to
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`generate such a voltage pulse to avoid arcing, and the flash tube of
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`Kudryavtsev is designed with arcing as a desirable condition, putting it at
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`odds with the very purpose of the ‘184 patent.
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`III. Legal Standards
`In this section I describe my understanding of certain legal
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`17.
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`standards. I have been informed of these legal standards by Zond’s
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`attorneys. I am not an attorney and I am relying only on instructions from
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`Zond’s attorneys for these legal standards.
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`A. Level of Ordinary Skill in the Art
`18.
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`I understand that a person of ordinary skill in the art provides a
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`reference point from which the prior art and claimed invention should be
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`viewed. This reference point prevents one from using his or her own insight
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`or hindsight in deciding whether a claim is obvious.
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`19.
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`In my opinion, given the disclosure of the ‘184 patent and the
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`disclosure of the prior art references considered here, I consider a person of
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`ordinary skill in the art at the time of filing of the ‘184 patent to be someone
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`who holds at least a bachelor of science degree in physics, material science,
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`or electrical/computer engineering with at least two years of work
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`experience or equivalent in the field of development of` plasma-based
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`processing equipment. I met or exceeded the requirements for one of
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`ordinary skill in the art at the time of the invention and continue to meet
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`and/or exceed those requirements.
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`B. Claim Interpretation Issues for Claims 1 - 20
`20.
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`I understand that the Board tentatively construed the following
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`language of claims 1 - 20:
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`1.
`2.
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`“Strongly ionized plasma;” and
`“Generating a voltage pulse … having at least one of a
`controlled amplitude and a controlled rise time …”
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`21. The Board construed “strongly-ionized plasma” as “a plasma
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`with a relatively high peak density of ions.”1 For purposes of this analysis, I
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`have used this interpretation.
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`22. The Board construed the above “pulse control” terminology as
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`1 IPR2014-00799, Decision at p. 11; IPR 2014-00803, Decision at p. 11.
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`proposed by Zond and reproduced below:2
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`Generating a voltage pulse whose amplitude and/or rise time
`are directed or restrained 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.
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`However, I understand that the Board also concluded that the claimed pulse
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`control encompasses any change in voltage amplitude that is incidental to
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`directing a pulse to a target power level (or set point) as in Wang, regardless
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`of whether the voltage amplitude is the parameter under control. Therefore,
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`Zond has proposed the following clarification to the Board’s tentative
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`construction:
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`Claim Language at Issue
`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
`…”
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`Proposed Construction
`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.
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`2 IPR2014-00799, Decision at p. 12; IPR 2014-00803, Decision at p. 12.
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`For purposes of this declaration, I have used the proposed clarified
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`interpretation, which is consistent with my understanding of the language
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`and the specification.
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`C. Legal Standards for Anticipation
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`23.
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`I understand that a claim is anticipated under 35 U.S.C. § 102 if
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`(i) each and every element and limitation of the claim at issue is found either
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`expressly or inherently in a single prior art reference, and (ii) the elements
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`and limitations are arranged in the prior art reference in the same way as
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`recited in the claims at issue.
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`D. Legal Standards for Obviousness
`24.
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`I understand that obviousness must be analyzed from the
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`perspective of a person of ordinary skill in the relevant art at the time the
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`invention was made. In analyzing obviousness, I understand that it is
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`important to understand the scope of the claims, the level of skill in the
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`relevant art, the scope and content of the prior art, the differences between
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`the prior art and the claims, and any secondary evidence of non-obviousness.
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`I have not been asked to study or analyze any secondary considerations of
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`non-obviousness. As discussed further below, the Wang and Kudryavtsev
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`prior art references describe systems that are so far different than what is
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`claimed that they do not form the basis for an obviousness determination of
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`the claimed subject matter.
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`25.
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`I understand that even if a patent is not anticipated, it is still
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`invalid if the differences between the claimed subject matter and the prior art
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`are such that the subject matter as a whole would have been obvious at the
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`time the invention was made to a person of ordinary skill in the pertinent art.
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`26.
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`I also understand that a party seeking to invalidate a patent as
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`obvious must demonstrate that a person of ordinary skill in the art would
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`have been motivated to combine the teachings of the prior art references to
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`achieve the claimed invention, and that the person of ordinary skill in the art
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`would have had a reasonable expectation of success in doing so. This is
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`determined at the time the invention was made. I understand that this
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`temporal requirement prevents the forbidden use of hindsight. I also
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`understand that rejections for obviousness cannot be sustained by mere
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`conclusory statements and that the Petitioners must show some reason why a
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`person of ordinary skill in the art would have thought to combine particular
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`available elements of knowledge, as evidenced by the prior art, to reach the
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`claimed invention.” I also understand that the motivation to combine
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`inquiry focuses heavily on “scope and content of the prior art” and the “level
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`of ordinary skill in the pertinent art.”
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`27.
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`I have been informed and understand that the obviousness
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`analysis requires a comparison of the properly construed claim language to
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`the prior art on a limitation-by-limitation basis.
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`IV. Background Topics
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`28. The ‘184 patent describes a system for forming a strongly
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`ionized plasma using a controlled voltage pulse. The pulse’s amplitude
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`and/or rise time is controlled to increase an ionization rate so that a rapid
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`increase in electron density and a formation of a strongly-ionized plasma
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`occurs without forming an arc.
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`29. The prior art references cited in the Petition and the Board’s
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`Decision (Wang and Kudryavtsev) describe pulses for generating a plasma,
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`but do not disclose the type of “control” described in the ‘184 patent and its
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`claims.
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`30. The ‘184 patent describes a system that controls the amplitude
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`of a voltage pulse and the rise time of that voltage to achieve certain plasma
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`conditions that I will discuss ahead.
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` But to provide context for
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`understanding the issues identified in the Board’s Decision and addressed in
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`this report, I briefly review well-known, basic relationships between voltage,
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`current, impedance and power. I also review some basic concepts of control
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`systems, such as used to control the output of power supplies for magnetron
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`sputtering. I then give a brief overview of magnetron sputtering before
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`discussing the ‘184 patent and the prior art.
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`A. Voltage, current, impedance and power
`31. As is commonly known, when a voltage “V” is applied across
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`an impedance “I,” an electric field is generated that forces a current I to flow
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`through the impedance. For purely resistive impedance, the relation
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`between the voltage and the resultant current is given by: V = I * R
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`32. A common analogy is that voltage is like a pressure that causes
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`charge particles like electrons and ions to flow (i.e., current), and the amount
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`of current depends on the magnitude of the pressure (voltage) and the
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`amount of resistance or impedance that inhibits the flow. The ‘184 patent
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`and the prior art considered here involve the flow of current through an
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`assembly having a pair of electrodes with a plasma in the region between
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`them. The effective impedance of such an assembly varies greatly with the
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`density of charged particles in the region between the electrodes. Although
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`such an impedance is more complex than the simple resistive impedance of
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`the above equation, the general relation is similar: a voltage between the
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`electrode assembly forces a current to flow through the plasma, such that the
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`amount of current is determined by the amplitude of the voltage and the
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`impedance of the plasma. Thus, the current through the electrode assembly
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`increases with the electrode voltage and, for a given electrode voltage, the
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`current will increase with a drop in the impedance of the plasma.
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`33. The impedance varies with the charge density of the plasma:
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`With a high density of charged particle the impedance is relatively small,
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`and with a low density of charge particles the impedance is relatively large.
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`Simply, the more ions and electrons to carry the charge, the less resistance.
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`However, the charges and fields react with each other in a very complicated
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`manner.
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`34.
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`In response to the electric field in the region between the
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`electrodes (i.e., the voltage across the electrodes), all charged particles in the
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`region (the electrons and positive ions) feel a force that propels them to
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`flow. This flow is an electric current “I.” Obviously, the amount of current
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`depends upon the number of charged particles. When there are no charged
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`particles (i.e., no plasma), there is no current flow in response to the electric
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`field. In this condition, the impendence of the electrode assembly is
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`extremely high, like that of an open circuit. But when there is a dense
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`plasma between the electrodes (with many charged particles), a substantial
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`current will flow in response to the electric field. In this condition, the
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`impendence of the electrode assembly is very low. Thus, in general, the
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`impedance of an electrode assembly varies greatly with the charge density of
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`the plasma: The impedance is effectively infinite (an open circuit) when
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`there is no plasma, and is very low when the charge density is very high.
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`35.
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` It is also well known that electric power (P) is the product of
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`voltage (V) and current (I): P = V * I. Thus, for a given voltage across an
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`electrode assembly, the amount of power will depend on the amount of
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`corresponding current flowing through the electrode assembly. If there is
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`no current flow (such as when there is no plasma between the electrodes),
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`the power is zero, even if the voltage across the electrodes is very large.
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`Similarly, at very low electrode voltages, the power can still be quite high if
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`the current is large.
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`36. The claims of the ‘184 patent refer to “a controlled amplitude”
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`of a voltage pulse and a “controlled rise time” of the voltage pulse. The
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`‘184 patent describes many examples of such control and how a
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`programmable power supply can be used to achieve this control. I will
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`describe these examples from the ‘184 patent ahead.
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`37. But first, to provide context for understanding this aspect of the
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`‘184 patent, I consider below some known basic principles of control
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`systems (such as used in all power supplies and all such control systems) for
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`controlling a parameter such as voltage amplitude.
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`B. Control systems
`38. The programmable power supply mentioned in the ‘184 patent
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`is an example of a control system. This system controls the voltage
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`amplitude of a voltage pulse. A simplified block diagram of a common
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`feedback control system is shown the figure below from a text by Eronini.3
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`Figure 1 Control system simplified block diagram
`39. The “reference input signal” represents a “desired value” or
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`“set-point” of the controller. The control system directly controls the
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`“controlled variable.” In response to the difference between the set-point
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`and a feedback signal (which represents the condition of the controlled
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`variable), the control system directs the controlled variable in an attempt to
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`reduce the difference to zero, thereby causing the controlled variable to
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`equal the set point value.
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`3 Ex. 2021, Eronini Umez-Eronini, System Dynamics and Control, Brooks
`Cole Publishing Co., CA, 1999, pp. 10-13.
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`40. For example, the set-point for filling a water tank may be 1,000
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`gallons, or full. The desired value, set-point or desired level is the value
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`“full” or “1000 gallons.” An open loop control system might just fill the
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`tank for a pre-calibrated time that result in the tank being full. The control
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`system might be set to fill the tank once per day based on historical water
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`usage. However, if water usage is not consistent, the tank may run empty
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`before it is filled, or may overflow because there was less water usage than
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`normal. On the other hand, a closed loop system such as shown above uses
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`feedback control. For example, it measures the water level, and only adds
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`the needed amount. It might have a switch or sensor that detects when the
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`tank is full, and turns off the flow of water. The set-point is the desired
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`value. “Here the comparison of the tank level signal with the desired value
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`of the tank level (entered into the system as a set-point setting) and the
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`turning of the pump on or off are all performed by appropriate hardware in
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`the controller.” 4 Further, a closed loop system could be left on to fill the
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`tank if the level dropped too low. “In feedback control, a measurement of the
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`output of a system is used to modify its input in such a way that the output
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`4 Ex. 2021, Eronini Umez-Eronini, System Dynamics and Control, Brooks
`Cole Publishing Co., CA, 1999, pp. 10-13.
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`stays near the desired value5.”
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`Set point (Controlled Parameter)
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`C.
`41. The parameter that is directed to a desired value is called the
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`“controlled variable,” as shown in the figure from Eronini. Eronini’s
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`diagram also shows that while controlling the “controlled variable,” the
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`system may “manipulate” another control parameter that Eronini calls the
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`“manipulated variable.”
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`42. This terminology is commonly used in other references that
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`describe control systems. A reference by Weyrick, for example, uses the
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`same terminology as Eronini:
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`• “The controlled output is the process quantity being controlled.”
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`• “The manipulated variable is the control signal which the control
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`elements process.”6
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`43. Similarly, Kua and Sinka also show that the “controlled
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`parameter” is widely understood to mean the parameter being controlled by
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`the control system.7
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`
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`44. With this understanding, I now consider the difference between
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`5 Ex. 2021, Eronini Umez-Eronini, p. 12.
`6 Ex. 2011, Weyrick at 13
`7 Ex. 2012, Kua; Ex. 2013, Sinka.
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`controlling the amplitude of a voltage and controlling the power.
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`Power Control vs Voltage Control
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`D.
`45. To demonstrate the difference between the control of voltage
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`and the control of power, I will refer to the generic diagram of a feedback
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`control system from Eronini. In a system for controlling voltage, the set
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`point is a specified voltage and the “controlled variable” obviously is
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`voltage. Thus, in a feedback control system as shown in Eronini, a feedback
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`signal representative of the measured voltage is fed back and compared to
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`the desired voltage level or “set point.” Based on the difference between the
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`measured voltage and the desired voltage or set point, the control system
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`drives or restrains the voltage in an attempt to move the actual voltage to
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`match the desired voltage.
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`46.
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`In a system for controlling power, the set point is a specified
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`power value and the controlled variable is power. In such a system, the
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`voltage and/or current can be driven by the control system to whatever levels
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`are needed to achieve the target power level. Thus, in the example of a
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`system for controlling the power of a plasma electrode assembly, if there is
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`no plasma between the electrodes (and therefore little or no current) a
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`controller attempting to achieve a target power level will drive the voltage
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`extremely high in an attempt to achieve the target power P, i.e., P = V * I,
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`(because I is very low or zero in this situation).
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`47.
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` Thus, in a control system for controlling power to a desired set
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`point, voltage will vary as the controller attempts to achieve the desired
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`power level (i.e., a desired product of voltage and current). However, the
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`amplitude of the voltage is not controlled and instead the voltage and/or the
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`current vary as needed to achieve the desired power.
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`48. The rise t