`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Exhibit 2005
`Exhibit 2005
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`
` TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`TSMC NORTH AMERICA CORPORATION,
`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.,
`TOSHIBA CORPORATION, and
`THE GILLETTE COMPANY,
`Petitioners
`
`v.
`
`ZOND, LLC
`Patent Owner
`
`U.S. Patent No. 6,853,142
`
`_____________________
`
`Inter Partes Review Case Nos. IPR2014-
`00818, 00819, 00821, 00827, 01098
`
`
`
`_____________________
`
`DECLARATION OF LARRY D. HARTSOUGH, Ph.D.
`
`
`
`
`
`
`
`
`I, Larry Hartsough, do hereby declare:
`
`1.
`
`I am making this declaration at the request of patent
`
`owner Zond, LLC, in the matter of the Inter Partes Reviews (IPRs) of
`
`U.S. Patent No. 6,853,142 (the “’142 Patent”), as set forth in the above
`
`caption.
`
`2.
`
`I am being compensated for my work in this matter at
`
`the rate of $300 per hour. My compensation in no way depends on the
`
`outcome of this proceeding.
`
`3.
`
`This list of materials I considered in forming the
`
`opinions set forth in this declaration includes the ’142 patent, the file
`
`history of the ’142 patent, the Petitions for Inter Partes Review and the
`
`exhibits, the PTAB’s Institution Decisions, the transcript of the
`
`deposition of the Petitioners’ expert on the ’142 patent, and the prior
`
`art references discussed below.
`
`I.
`
`Education and Professional Background
`
`4. My formal education is as follows. I received a Bachelors
`
`of Science degree in 1965, Master of Science degree in 1967, and
`
`Ph.D. in 1971, all in Materials Science/Engineering from the University
`
`of California, Berkeley.
`
`5.
`
`I have worked
`
`in
`
`the semiconductor
`
`industry
`
`for
`
`
`
`approximately 30 years. My experience includes thin film deposition,
`
`vacuum system design, and plasma processing of materials. I made
`
`significant contributions to the development of magnetron sputtering
`
`hardware and processes for the metallization of silicon integrated
`
`circuits. Since the late 1980’s, I have also been instrumental in the
`
`development of standards for semiconductor fabrication equipment
`
`published by the SEMI trade organization.
`
`6.
`
`From 1971-1974, I was a research metallurgist in the thin
`
`film development lab of Optical Coating Laboratory, Inc. In 1975 and
`
`1976, I developed and demonstrated thin film applications and
`
`hardware for an in-line system at Airco Temescal. During my tenure
`
`(1977-1981) at Perkin Elmer, Plasma Products Division, I served in a
`
`number of capacities from Senior Staff Scientist, to Manager of the
`
`Advanced Development activity, to Manager of the Applications
`
`Laboratory. In 1981, I co-founded a semiconductor equipment
`
`company, Gryphon Products, and was VP of Engineering during
`
`development of the product. From 1984-1988, I was the Advanced
`
`Development Manager for Gryphon, developing new hardware and
`
`process capabilities. During 1988-1990, I was Project Manager at
`
`General Signal Thinfilm on a project to develop and prototype an
`
`
`
`advanced cluster tool for making thin films. From 1991-2002, I was
`
`Manager of PVD (physical vapor deposition) Source Engineering for
`
`Varian Associates, Thin Film Systems, and then for Novellus Systems,
`
`after they purchased TFS. Since then, I have been consulting full time
`
`doing business as UA Associates, where my consulting work includes
`
`product development projects,
`
`film
`
`failure analysis, project
`
`management, technical presentations and litigation support.
`
`7.
`
`Throughout my career,
`
`I have developed and/or
`
`demonstrated processes and equipment for making thin films,
`
`including Al, Ti-W, Ta, and Cu metallization of silicon wafers, RF
`
`sputtering and etching, and both RF and dc magnetron reactive
`
`sputtering, for example SiO2, Al2O3, ITO (Indium-Tin Oxide), TiN, and
`
`TaN. I have been in charge of the development of two sputter
`
`deposition systems from conception to prototype and release to
`
`manufacturing. I have also specialized in the development and
`
`improvement of magnetically enhanced sputter cathodes. I have
`
`experience with related technology areas, such as wafer heating,
`
`power supply evaluation, wafer cooling, ion beam sources, wafer
`
`handling by electrostatics, process pressure control,
`
`in-situ
`
`wafer/process monitoring, cryogenic pumping, getter pumping, sputter
`
`
`
`target development, and physical, electrical and optical properties of
`
`thin films.
`
`8.
`
`I am a member of a number of professional organizations
`
`including the American Vacuum Society, Sigma Xi (the Scientific
`
`Research Society), and as a referee for the Journal of Vacuum Science
`
`& Technology. I have been a leader in the development of SEMI
`
`Standards for cluster tools and 300mm equipment, including holding
`
`various co-chair positions on various standards task forces. I have
`
`previously served as a member of the US Department of Commerce’s
`
`Semiconductor Technical Advisory Committee.
`
`9.
`
`I have co-authored many papers,
`
`reports, and
`
`presentations relating to semiconductor processing, equipment, and
`
`materials, including the following:
`
`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).
`
`
`
` My areas of expertise include sputter deposition hardware and
`
`processes, thin film deposition system design and thin film properties.
`
`I am a named inventor on twelve United States patents covering
`
`apparatus, methods or processes in the fields of thin film deposition
`
`and etching. A copy of my CV is attached as Attachment A.
`
`II. Summary of Opinions
`
`10.
`
` It is my opinion that none of the claims of the ‘142 patent
`
`are obvious.
`
`III. LEGAL STANDARDS
`
`11.
`
`In this section I describe my understanding of certain legal
`
`standards. I have been informed of these legal standards by Zond’s
`
`attorneys. I am not an attorney and I am relying only on instructions
`
`from Zond’s attorneys for these legal standards.
`
`
`
`A. Level of Ordinary Skill in the Art
`
`In my opinion, given the disclosure of the ‘142 Patent, I
`
`12.
`
`consider a person of ordinary skill in the art at the time of filing of the
`
`‘142 Patent to be someone who holds at least a bachelor of science
`
`degree in physics, material science, or electrical/computer engineering
`
`with at least two years of work experience or equivalent in the field of
`
`development of` plasma-based processing equipment. I met or
`
`exceeded the requirements for one of ordinary skill in the art at the time
`
`of
`
`the
`
`invention and continue
`
`to meet and/or exceed
`
`those
`
`requirements.
`
`B. Legal Standards for Anticipation
`
`I understand that a claim is anticipated under 35 U.S.C. §
`
`13.
`
`102 if (i) each and every element and limitation of the claim at issue is
`
`found either expressly or inherently in a single prior art reference, and
`
`(ii) the elements and limitations are arranged in the prior art reference
`
`in the same way as recited in the claims at issue.
`
`C. Legal Standards for Obviousness
`
`I understand that obviousness must be analyzed from the
`
`14.
`
`perspective of a person of ordinary skill in the relevant art at the time
`
`the invention was made. In analyzing obviousness, I understand that
`
`
`
`it is important to understand the scope of the claims, the level of skill
`
`in the relevant art, and the scope and content of the prior art, the
`
`differences between the prior art and the claims.
`
`15.
`
`I understand that even if a patent is not anticipated, it is still
`
`invalid if the differences between the claimed subject matter and the
`
`prior art are such that the subject matter as a whole would have been
`
`obvious at the time the invention was made to a person of ordinary skill
`
`in the pertinent art.
`
`16.
`
`I understand that a person of ordinary skill in the art
`
`provides a reference point from which the prior art and claimed
`
`invention should be viewed. This reference point prevents one from
`
`using his or her own insight or hindsight in deciding whether a claim is
`
`obvious.
`
`17.
`
`I also understand that an obviousness determination
`
`includes the consideration of various factors such as (1) the scope and
`
`content of the prior art; (2) the differences between the prior art and
`
`the asserted claims; and (3) the level of ordinary skill in the pertinent
`
`art.
`
`18.
`
`I also understand that a party seeking to invalidate a patent
`
`as obvious must demonstrate that a person of ordinary skill in the art
`
`
`
`would have been motivated to combine the teachings of the prior art
`
`references to achieve the claimed invention, and that the person of
`
`ordinary skill in the art would have had a reasonable expectation of
`
`success in doing so. This is determined at the time the invention was
`
`made. I understand that this temporal requirement prevents the
`
`forbidden use of hindsight. I also understand that rejections for
`
`obviousness cannot be sustained by mere conclusory statements and
`
`that the Petitioners must show some reason why a person of ordinary
`
`skill in the art would have thought to combine particular available
`
`elements of knowledge, as evidenced by the prior art, to reach the
`
`claimed invention.” I also understand that the motivation to combine
`
`inquiry focuses heavily on “scope and content of the prior art” and the
`
`“level of ordinary skill in the pertinent art.”
`
`19.
`
`I have been informed and understand that the obviousness
`
`analysis requires a comparison of the properly construed claim
`
`language to the prior art on a limitation-by-limitation basis.
`
`IV. TECHNOLOGY BACKGROUND AND THE ’142 PATENT
`
`
`
`20.
`
`The prior art references cited in the Petition and the
`
`Board’s Decision (Wang, Lantsman, Mozgrin and Kudryavtsev)
`
`
`
`describe pulses for generating a plasma, but do not disclose the type
`
`of method and apparatus described in the ‘142 patent and its claims.
`
`A. Voltage, current, impedance and power
`
`21.
`
`As is commonly known, when a voltage “V” is applied
`
`across an impedance “I,” an electric field is generated that forces a
`
`current I to flow through the impedance. For purely resistive
`
`impedance, the relation between the voltage and the resultant current
`
`is given by: V = I * R.
`
`22.
`
`A common analogy is that voltage is like a pressure that
`
`causes charge particles like electrons and ions to flow (i.e., current),
`
`and the amount of current depends on the magnitude of the pressure
`
`(voltage) and the amount of resistance or impedance that inhibits the
`
`flow. The ‘142 patent and the prior art considered here involve the flow
`
`of current through an assembly having a pair of electrodes with a
`
`plasma in the region between them. The effective impedance of such
`
`an assembly varies greatly with the density of charged particles in the
`
`region between the electrodes. Although such an impedance is more
`
`complex than the simple resistive impendence of the above equation,
`
`the general relation is similar: a voltage between the electrode
`
`assembly forces a current to flow through the plasma, such that the
`
`
`
`amount of current is determined by the amplitude of the voltage and
`
`the impedance of the plasma. Thus, the current through the electrode
`
`assembly increases with the electrode voltage and, for a given
`
`electrode voltage, the current will increase with a drop in the
`
`impedance of the plasma.
`
`23.
`
`The impedance varies with the charge density of the
`
`plasma: With a high density of charged particle the impedance is
`
`relatively small, and with a low density of charge particles the
`
`impedance is relatively large. Simply, the more ions and electrons to
`
`carry the charge, the less resistance. However, the charges and fields
`
`react with each other in a very complicated manner.
`
`24.
`
`In response to the electric field in the region between the
`
`electrodes (i.e., the voltage across the electrodes), all charged
`
`particles in the region (the electrons and positive ions) feel a force that
`
`propels them to flow. This flow is an electric current “I.” Obviously,
`
`the amount of current depends upon the number of charged particles.
`
`When there are no charged particles (i.e., no plasma), there is no
`
`current flow in response to the electric field. In this condition, the
`
`impendence of the electrode assembly is extremely high, like that of
`
`an open circuit. But when there is a dense plasma between the
`
`
`
`electrodes (with many charged particles), a substantial current will flow
`
`in response to the electric field. In this condition, the impendence of
`
`the electrode assembly is very low. Thus, in general, the impedance
`
`of an electrode assembly varies greatly with the charge density of the
`
`plasma: The impedance is effectively infinite (an open circuit) when
`
`there is no plasma, and is very low when the charge density is very
`
`high.
`
`25.
`
`It is also well known that electric power (P) is the product
`
`of voltage (V) and current (I): P = V * I. This too is a complex
`
`relationship. When the voltage and current are perfectly in phase, then
`
`one may simply multiply them to yield the power. Thus, for a given
`
`voltage across an electrode assembly, the amount of power will
`
`depend on the amount of corresponding current flowing through the
`
`electrode assembly. If there is no current flow (such as when there is
`
`no plasma between the electrodes), the power is zero, even if the
`
`voltage across the electrodes is very large. Similarly, at very low
`
`electrode voltages, the power can still be quite high if the current is
`
`large.
`
`26.
`
`To provide context for understanding this aspect of the ‘142
`
`patent, I consider below some known basic principles of control
`
`
`
`systems (such as used in all power supplies and all such control
`
`systems) for controlling a parameter such as voltage amplitude.
`
`B. Control systems
`
`27.
`
`The power supply mentioned in the ‘142 patent is an
`
`example of a control system. This system controls the voltage
`
`amplitude of a voltage pulse. A simplified block diagram of a common
`
`feedback control system is shown the figure below from a text by
`
`Eronini.1
`
`
`
`Figure 1 Control system simplified block diagram
`
`The “reference input signal” represents a “desired value” or “set-
`
`
`1 Ex. 2010, Eronini Umez-Eronini, System Dynamics and Control, Brooks Cole
`
`Publishing Co., CA, 1999, pp. 10-13.
`
`
`
`
`
`point” of the controller. The “forward elements” directly control the
`
`“controlled variable.” In response to the difference between the set-
`
`point and a feedback signal (which represents the condition of the
`
`controlled variable), the forward elements direct the controlled variable
`
`in an attempt to reduce the difference to zero, thereby causing the
`
`controlled variable to equal the set point value.
`
`28.
`
`For example, the set-point for filling a water tank may be
`
`1,000 gallons, or full. The desired value, set-point or desired level is
`
`the value “full” or “1000 gallons.” An open loop control system might
`
`just fill the tank for a pre-calibrated time that result in the tank being
`
`full. The control system might be set to fill the tank once per day based
`
`on historical water usage. However, if water usage is not consistent,
`
`the tank may run empty before it is filled, or may overflow because
`
`there was less water usage than normal. On the other hand, a closed
`
`loop system such as shown above uses feedback control. For
`
`example, it measures the water level, and only adds the needed
`
`amount. It might have a switch or sensor that detects when the tank is
`
`full, and turns off the flow of water. The set-point is the desired value.
`
`“Here the comparison of the tank level signal with the desired value of
`
`the tank level (entered into the system as a set-point setting) and the
`
`
`
`turning of the pump on or off are all performed by appropriate hardware
`
`in the controller.” 2 Further, a closed loop system could be left on to fill
`
`the tank if the level dropped to low. “In feedback control, a
`
`measurement of the output of a system is used to modify its input in
`
`such a way that the output stays near the desired value3.”
`
`
`
`C. Set point (Controlled Parameter)
`29. The parameter that is directed to a desired value is called
`
`the “controlled variable,” as shown in the figure from Eronini. Eronini’s
`
`diagram also shows that while controlling the “controlled variable,” the
`
`system may “manipulate” another control parameter that Eronini calls
`
`the “manipulated variable.”
`
`For example, Eronini’s text on control systems shows a control
`
`system that directs the “controlled variable” to its desired value (or “set
`
`point”):
`
`
`2 Ex. 2007, Eronini Umez-Eronini, System Dynamics and Control, Brooks
`
`Cole Publishing Co., CA, 1999, pp. 10-13.
`
`3 Id. at p. 12.
`
`
`
`
`
`30.
`
`Eronini’s diagram also shows that while controlling the
`
`“controlled variable,” the system may “manipulate” another control
`
`parameter that Eronini calls the “manipulated variable.” Another
`
`reference by Weyrick uses the same terminology as Eronini:
`
` “The controlled output is the process quantity being
`
`controlled.”
`
` “The manipulated variable is the control signal which the
`
`control elements process.”
`
`
`
`31.
`
` Similarly, Kua and Sinka also show that the “controlled
`
`parameter” is widely understood to mean the parameter being
`
`controlled by the control system.4
`
`
`4 Ex. 2009, Kua; Ex. 2006, Sinka.
`
`
`
`32.
`
` With this understanding, I now consider the difference
`
`between controlling the amplitude of a voltage and controlling the
`
`power.
`
`D. Power Control vs Voltage Control
`
`33.
`
` To demonstrate the difference between the control of
`
`voltage and the control of power, I will refer to the generic diagram of
`
`a feedback control system from Eronini, shown above. In a system for
`
`controlling voltage, the set point is a specified voltage and the
`
`“controlled variable” obviously is voltage. Thus, in a feedback control
`
`system as shown, a feedback signal representative of the measured
`
`voltage is fed back and compared to the desired voltage level or “set
`
`point.” Based on the difference between the measured voltage and
`
`the desired voltage or set point, the forward elements are instructed to
`
`drive or restrain the voltage in an attempt to move the actual voltage to
`
`match the desired voltage.
`
`34.
`
`In a system for controlling power, the set point is a specified
`
`power value and the controlled variable is power. In such a system,
`
`the voltage and/or current can be driven by the feed forward elements
`
`to whatever levels are needed to achieve the target power level. Thus,
`
`in the example of a system for controlling the power of a plasma
`
`
`
`electrode assembly, if there is no plasma between the electrodes (and
`
`therefore little or no current) a controller attempting to achieve a target
`
`power level will drive the voltage extremely high in an attempt to
`
`achieve the target power P, i.e., P = V * I, (because I is very low or zero
`
`in this situation).
`
`35.
`
`Thus, in a control system for controlling power to a desired
`
`set point, voltage will vary as the controller attempts to achieve the
`
`desired power level (i.e., a desired product of voltage and current).
`
`However, the amplitude of the voltage is not controlled and instead the
`
`voltage and/or the current vary as needed to achieve the desired
`
`power.
`
`36.
`
`The rise time of a voltage therefor is a different parameter
`
`than the rise time of power. For example, consider a scenario in which
`
`a voltage source outputs a constant voltage. If that source is
`
`connected across an impedance that gradually drops, the current will
`
`increase as the impedance drops. Since power is the product of
`
`voltage (here a constant) and current, the power too will rise as the
`
`current increases. Thus, in this situation, power rises at rate
`
`determined by the rate at which the impedance decreases. But there
`
`is no rise in voltage because the source maintains a static, constant
`
`
`
`voltage at its output in this example. This demonstrates that a rise time
`
`in voltage is a different parameter than rise time in power.
`
`37.
`
`This example can also be used to demonstrate the
`
`difference between a controlled change in the output of a voltage
`
`source, and a reaction to a change in impedance. If the impedance
`
`drops so fast that the voltage source cannot maintain the voltage at its
`
`target level, the voltage output by the source can drop due to limitations
`
`of the voltage source. This drop in voltage is not a controlled drop,
`
`caused by the power supply in response to a programmed change in
`
`the voltage set point: It is a transient drop caused by a change in the
`
`impedance load that exceeds the capacity of the voltage source.
`
`E. Magnetron Sputtering History and Operation
`
`38.
`
` Since the late 1970s, DC magnetron sputtering has
`
`become the preferred method for the deposition of thin metal films for
`
`many applications, including semiconductor devices and protective
`
`layers on cutting tools. Several significant advantages of this method
`
`over alternatives, such as thermal evaporation or diode sputter
`
`deposition, are higher deposition rate and improved film structure.
`
`39.
`
` The higher deposition rate is possible because the closed
`
`loop magnetic field of the magnetron traps the secondary electrons
`
`
`
`(produced when the inert gas ions bombard the metal target that is
`
`attached to the cathode assembly held at a negative voltage of several
`
`hundreds of volts). These electrons gain energy as they are
`
`accelerated across the dark space. Since most of the voltage drop
`
`from anode to cathode occurs in this region, the electrons arrive in the
`
`discharge region with more than enough energy to ionize the neutral
`
`gas atom there. The crossed electric and magnetic fields create a
`
`force on the electrons that causes them to circulate in a path that
`
`follows the shape of the magnetic loop and is only a few mm from the
`
`face of the target. The circulating current in this loop is about 10x the
`
`anode-cathode current of the sputtering discharge. It is these
`
`electrons that collide with, and create large numbers of ions of, the inert
`
`neutral sputtering gas atoms (usually argon) that have diffused into this
`
`region. The ions are accelerated toward the target and bombard it with
`
`energies that are nearly the full cathode-anode voltage. As the
`
`secondary electrons create an ion, they lose energy and move closer
`
`to the anode. After several ionizing collisions they no longer have
`
`enough energy to create ions. It is the secondary electrons that sustain
`
`a normal magnetron discharge.
`
`40.
`
` The magnetron discharge is characterized by higher
`
`
`
`current and lower voltage (i.e., lower impedance) compared to a diode
`
`discharge. This allows higher powers to be delivered than would be
`
`possible with diode sputtering, because the drop in yield with lower
`
`voltage is more than made up for by the increase in the number of ions.
`
`In DC magnetron sputtering, repeatability of film thickness is usually
`
`achieved by operating the power supply in power control mode and
`
`depositing for a specific time.
`
`41.
`
` The sputtered metal atoms are ejected from the target with
`
`high velocity, compared to evaporation, which contributes to film
`
`adhesion and microstructure. However, this high velocity means that
`
`relatively few of the metal atoms have a chance to become ionized as
`
`they traverse the thin zone of high energy electrons on their way from
`
`the source target to the substrate workpiece (e.g., silicon wafer or razor
`
`blade).
`
`42.
`
` As research progressed over the ensuing decades, the
`
`advantages of increasing the ionization of the sputtered atoms became
`
`evident. Ions impacting the growing film improved qualities such as
`
`hardness, adhesion and density even further. Furthermore, the
`
`trajectories of the incoming ions could be made more perpendicular to
`
`the substrate surface by application of a negative bias. This allowed
`
`
`
`more film to be deposited in the bottom of high aspect ratio holes
`
`enabling
`
`the production of semiconductor devices with ever-
`
`decreasing geometries.
`
`43.
`
` The challenge of increasing the degree of ionization of the
`
`sputtered atoms could be met by increasing the chances that they
`
`would encounter an ionizing collision in the space between target and
`
`substrate. This could be achieved by expanding the high density
`
`plasma into that space. Just increasing the DC power to the
`
`magnetron would do this and would increase the power density
`
`delivered to the target, increasing the sputtering rate and the ionization
`
`of the sputtered atoms. However, this approach, if applied steady
`
`state, would require large power supplies and would overheat the
`
`target. Therefore, other techniques were developed to meet the
`
`challenge.
`
`44. One approach, introduced by Rossnagel and Hopwood5
`
`was to create a separately sustained plasma in the target-substrate
`
`space. Another was to use the hollow cathode magnetron invention of
`
`
`5 S.M. Rossnagel and J. Hopwood, Journal of Vacuum Science &
`
`Technology 12B (449-453) 1994.
`
`
`
`Helmer6 Yet another approach was to use pulsed DC magnetron
`
`sputtering to create a short-lived high density magnetron plasma with
`
`enough time between pulses such that the average power delivered
`
`over many pulses did not exceed the steady state power delivery
`
`capability of the power supply or the cooling capacity of the cathode.
`
`As the density of the plasma increases it also expands, at least partially
`
`due to reduced trapping of the electrons circulating within the magnetic
`
`field loop. The large circulating current in this loop forms a one-turn
`
`(very high amperage) electromagnet that creates a magnetic field
`
`opposing the magnetic field produced by the magnetron magnets. This
`
`reduction in effective magnetic field allows an increase in width of the
`
`sputtering zone and an expansion of the plasma away from the
`
`cathode.
`
`45. However, this pulsed approach is accompanied by several
`
`risks. An abrupt large increase in applied voltage can cause localized
`
`instabilities in electric fields to be large enough to initiate an arc on the
`
`cathode, even if a low density discharge is already present. If the high
`
`density plasma is driven to over-expansion it can essentially form a
`
`
`6 U.S. Patent No. 5,482,611.
`
`
`
`short between the cathode and anode leading to a breakdown mode
`
`in which no sputtering occurs.
`
`46. There are large changes in plasma impedance that occur
`
`during a pulsed DC magnetron discharge. The more charged particles
`
`within it, the more electrically conducting it becomes. During ignition,
`
`the impedance may be in the hundreds of ohms, dropping to the tens
`
`of ohms in the low density mode. In the transition from a low to a high
`
`density plasma, the impedance drops to a few ohms, accompanied by
`
`up to two orders of magnitude increase in current. Depending on
`
`power supply design and control settings, the density of the plasma
`
`may increase quite unevenly, also leading to the possibility of plasma
`
`breakdown or arcs, if the transitions are uncontrolled.
`
`47.
`
` Power supplies in the art prior to the ‘142 patent for DC
`
`magnetron sputtering include those that set power for the duration of a
`
`deposition step. In power control mode, the output is controlled until
`
`the product of discharge voltage and current equals the set power. In
`
`pulsed power mode, as described by Wang, the total energy delivered
`
`during a pulse is controlled.7
`
`
`7 Ex. 1005, Wang, col. 6, lines 16 – 24.
`
`
`
`48. However, such pulsed power systems are prone to arcing
`
`upon igniting the plasma, especially when working with high-power
`
`pulses.8 Such arcing can result in the release of undesirable particles
`
`in the chamber that can contaminate the sample, which is especially
`
`undesirable in semiconductor processing.9
`
`V. Patent 6,853,142
`
`49.
`
` Sputtering systems generate and direct ions from plasma
`
`“to a target surface where the ions physically sputter target material
`
`atoms.”10 Then, “[t]he target material atoms ballistically flow to a
`
`substrate where they deposit as a film of target material.”11 “The
`
`plasma is replenished by electron-ion pairs formed by the collision of
`
`neutral molecules with secondary electrons generated at the target
`
`surface.”12
`
`
`8 Ex. 1001, ‘142 patent, col. 1, lines 38-40; see also Ex. 1005, Wang, col. 7
`
`lines 3-6, 46-48.
`
`9 Ex. 1001, ‘142 patent, col. 1, lines 40-42; see also Ex. 1005, Wang, col. 7
`
`lines 3-6, 46-48.
`
`10 Exhibit 1001, ‘142 patent, col. 1, ll. 9-11.
`
`11 Id. at col. 1, ll. 11-13.
`
`12Id. at col. 1, ll. 32-34.
`
`
`
`50. A planar magnetron sputtering system is one type of
`
`sputtering system.13 “Magnetron sputtering systems use magnetic
`
`fields that are shaped to trap and to concentrate secondary electrons,
`
`which are produced by ion bombardment of the target surface.”14 “The
`
`trapped electrons enhance the efficiency of the discharge and reduce
`
`the energy dissipated by electrons arriving at the substrate.”15
`
`51. But prior art planar magnetron sputtering systems at the
`
`time of the invention of the ‘142 patent experienced “non-uniform
`
`erosion or wear of the target that results in poor target utilization.”16 To
`
`address these problems, researchers increased the applied power and
`
`later pulsed the applied power.17 But increasing the power increased
`
`“the probability of establishing an undesirable electrical discharge (an
`
`electrical arc) in the process chamber.”18 In addition, “very large power
`
`
`13 Id. at col. 1, ll. 36-54.
`
`14 Id. at col. 1, ll. 36-38.
`
`15 Id. at col 1, ll. 52-54.
`
`16 Id. at col. 2, ll. 57-59.
`
`17 Id. at col. 2, l. 60 to col. 3, l. 9.
`
`18 Id. at col. 2, ll. 65-67.
`
`
`
`pulses can still result in undesirable electrical discharges and
`
`undesirable target heating regardless of their duration.”19
`
`52. To overcome the deficiencies of the prior art, Dr.
`
`Chistyakov invented a magnetically enhanced sputtering source
`
`having a particular structure of an anode, cathode, ionization source,
`
`magnet and power supply generating a particular type of voltage pulse
`
`to perform a particular multi-step ionization process without forming an
`
`arc discharge as recited in independent claim 1 and as illustrated in
`
`Fig. 2 of the ’142 patent, reproduced below:
`
`
`
`
`19 Id. at col. 3, ll. 7-9.
`
`
`
`
`
`
`
`53. As illustrated by FIG. 2, Dr. Chistyakov’s magnetically
`
`enhanced sputtering source includes an anode 238 and a cathode
`
`assembly 216. The anode 238 is positioned adjacent to the cathode
`
`assembly “so as to form a gap 244 between the anode 238 and the
`
`cathode assembly 216 that is sufficient to allow current to flow through
`
`a region 245 between the anode 238 and the cathode assembly 216.”20
`
`“The gap 244 and the total volume of region 245 are parameters in the
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
