throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________________________
`
`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.
`U.S. Patent No. 6,853,142
`IPR Case No. IPR2014-008191
`
`
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS FOR ORAL ARGUMENT
`
`
`
`1 Case Nos. IPR2014-00867, IPR2014-01014, and IPR2014-01046 have been
`joined with this proceeding.
`
`

`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`The ’142 Patent:
`
`GlobalFoundries U.S. Inc., GlobalFoundries Dresden Module One LLC & Co. KG,
`GlobalFoundries Dresden Module Two LLC & Co. KG, The Gillette Company, Fujitsu
`Semiconductor Limited, Fujitsu Semiconductor America, Inc., Advanced Micro Devices, Inc., Renesas
`Electronics Corporation, Renesas Electronics America, Inc., Toshiba America Electronic Components,
`Inc., Toshiba America Inc., Toshiba America Information Systems, Inc., and Toshiba Corporation
`v.
`Zond LLC
`
`IPR2014-00818, IPR2014-00819, IPR2014-00821, and IPR2014-00827
`
`GlobalFoundries U.S. Inc., GlobalFoundries Dresden Module One LLC & Co. KG,
`GlobalFoundries Dresden Module Two LLC & Co. KG, and The Gillette Company
`v.
`Zond LLC
`
`IPR2014-01098
`
`June 12, 2015
`
`1
`
`

`
`Overview
`
`• Overview of the ’142 Patent
`
`• Grounds Instituted
`
`• Overview of Prior Art
`
`• Summary of Disputes and Responses Related to
`Independent Claims
`
`• Summary of Disputes and Responses Related to
`Dependent Claims
`
`2
`
`

`
`The ’142 Patent
`
`US Patent 6,853,142
`
`3
`
`

`
`The ’142 Patent – Fig. 2A
`
`Cathode (204)
`
`Anode (216)
`
`Gap (220)
`
`Pulsed power
`supply (202)
`
`’142 Patent, Fig. 2A
`
`4
`
`

`
`’142 Independent Claims
`Claims 1 & 10
`
`Claim 1
`
`Claim 10
`
`’142 Patent, Claim 1
`
`’142 Patent, Claim 10
`
`5
`
`

`
`’142 Independent Claims
`Claims 21 & 31
`
`Claim 21
`
`Claim 31
`
`’142 Patent, Claim 21
`
`’142 Patent, Claim 31
`
`6
`
`

`
`’142 Independent Claims
`Claims 40 & 41
`
`Claim 40
`
`Claim 41
`
`’142 Patent, Claim 40
`
`’142 Patent, Claim 41
`
`7
`
`

`
`Grounds Instituted
`
`Ground
`
`Claims
`
`Prior Art
`
`818 Petition (IPR 2014-00866, IPR2014-01012, and IPR2014-01075 are joined with the 818)
`
`2
`
`3
`
`1, 3-7, 9, 10, 12, 15,
`19, 20, and 42
`
`Wang+ Lantsman
`
`8, 17, and 18
`
`Wang + Lantsman + Mozgrin
`
`819 Petition (IPR2014-00867, IPR2014-01014, and IPR2014-01046 are joined with the 819)
`
`3
`
`21, 24, 26-28, 31, 32,
`37, and 38
`
`Wang + Kudryavtsev
`
`821Petition (IPR2014-00863, IPR2014-01013, and IPR2014-01057 are joined with the 821)
`
`2
`
`4
`
`6
`
`13 and 14
`
`Wang+ Lantsman
`
`2 and 11
`
`Wang+ Lantsman + Kudryavtsev
`
`16
`
`Wang+ Lantsman + Mozgrin Thesis
`
`8
`
`

`
`Grounds Instituted
`
`Ground
`
`Claims
`
`Prior Art
`
`00827 Petition (IPR 2014-00865, IPR2014-01015, and IPR2014-01063 are joined with the 827)
`
`2
`
`22, 23, 25, 29, 30, 33-
`36, 39, and 43
`
`Wang + Kudryavtsev
`
`01098 Petition (IPR2014-01016 is joined with the 1098)
`
`4
`
`2
`
`40
`
`41
`
`Wang+ Lantsman
`
`Wang+ Kudryavtsev
`
`9
`
`

`
`’142 Patent and Wang Prior Art
`
`’142 Patent
`
`Wang
`
`’ 142 Patent, Fig. 2A
`
`Cathode
`
`Anode
`
`Gap
`
`Pulsed power supply
`
`Wang, Fig. 1 (Ex. 1005)
`
`10
`
`

`
`Asserted Prior Art: Kudryavtsev
`
`Kudryavtsev at 30 (Ex. 1204)
`
`11
`
`

`
`Asserted Prior Art: Lantsman
`
`Lantsman, Fig. 6 (Ex. 1004)
`
`Lantsman, Fig. 5 (Ex. 1004)
`
`12
`
`

`
`Disputes with Respect to Independent Claims
`
`• Independent claims 1, 10, 40, and 41
`
`‒ Whether Wang discloses a “magnitude and rise-time that is sufficient to
`increase the density of the weakly-ionized plasma”
`
`‒ Whether Wang in view of Lantsman discloses “diffusing the strongly-
`ionized plasma with additional feed gas to allow additional power to be
`absorbed by the strongly-ionized plasma”
`
`‒ Whether one of ordinary skill in the art would be motivated to combine
`Wang and Lantsman
`
`‒ Whether one of ordinary skill in the art would be motivated to combine
`Wang and Kudryavtsev (Claim 41 Only)
`
`• Independent claims 21and 31
`
`‒ Whether Wang discloses “a cathode that is positioned adjacent to the
`anode forming a gap there between” (Claim 21 Only)
`
`‒ Whether one of ordinary skill in the art would be motivated to combine
`Wang and Kudryavtsev
`
`13
`
`

`
`Wang Discloses Generating a Voltage Pulse with an
`Amplitude and Rise Time
`(Claims 1, 10, 40, and 41)
`
`Voltage Pulses
`
`Wang at 7:56-63 (Ex. 1005);
`see also Overzet Dec. at ¶ 91(Ex. 1022);
`Kortshagen Dec. at ¶ 125 - 130(Ex. 1002)
`
`Wang, Fig. 7
`
`14
`
`

`
`Wang Discloses Generating a Voltage Pulse with an
`Amplitude and Rise Time
`(Claims 1, 10, 40, and 41)
`
`Amplitude and Rise Time
`
`Wang at 5:24-27 (Ex. 1005);
`see also Overzet Dec. at ¶ 91(Ex. 1022);
`Kortshagen Dec. at ¶ 125 - 130(Ex. 1002)
`
`Wang, Fig. 7
`
`15
`
`

`
`Wang Discloses a Voltage Pulse with an Amplitude and
`a Rise Time that Creates Strongly-Ionized Plasma
`(Claims 1, 10, 40, and 41)
`
`Wang at 7:19-30 (Ex. 1005);
`see also Overzet Dec. at ¶ 91(Ex. 1022);
`Kortshagen Dec. at ¶ 125 - 130(Ex. 1002)
`
`16
`
`

`
`Wang Discloses Diffusing The Strongly-ionized Plasma
`(Claims 1, 10, 40, and 41)
`
`plasma region
`
`Feed gas enters here,
`and then fills the volume
`by diffusive motion
`
`Wang, Fig. 1(Ex.1005);
`Overzet Dec. at ¶¶ 75-76
`
`17
`
`

`
`Wang Discloses Diffusing The Strongly-ionized Plasma
`(Claims 1, 10, 40, and 41)
`
`•
`
`•
`
`In the system of Wang, the Argon feed gas will diffuse into the high
`density plasma, thereby allowing additional power from the pulsed
`power supply to be absorbed by the plasma.
`
`Overzet Dec. at ¶ 78 (Ex. 1022); Kortshagen Dec. at ¶ 134 (Ex. 1002)
`
`The processing region 22 of Wang is a restricted and well-defined
`container, and a volume of Argon gas will expand to fill this region.
`
`Overzet Dec. at ¶ 78 (Ex. 1022)
`
`• Not only will a gas like Argon expand to fill its container, it will also
`mix or “intermingle” with the gasses present in the container.
`
`Overzet Dec. at ¶ 78 (Ex. 1022)
`
`•
`
`Lantsman, which has a two stage plasma process similar to Wang,
`teaches a continuous feed of gas during the plasma process.
`
`Overzet Dec. at ¶ 80 (Ex. 1022)
`
`18
`
`

`
`Person Of Ordinary Skill In The Art Would Be Motivated To
`Apply Lantsman’s Teaching Of A Continuous Feed Gas To Wang
`(Claims 1, 10, 21, and 41)
`
`• Lantsman explicitly states its teachings are broadly applicable to
`other DC sputtering systems:
`
`Lantsman at 6:14-17 (Ex. 1004)
`
`• It is Lantsman’s teaching of continuously supplying feed gas that a
`person of ordinary skill in the art would be motivated to apply to
`Wang, not any physical components
`
`‒ Zond’s focus on the physical differences between Wang and Lantsman is misplaced
`
`19
`
`

`
`A Person of Skill Would Have Been Motivated to
`Combine Wang and Lantsman (Claims 1, 10, 21, and 41)
`
`Nevertheless, Zond is incorrect in stating that Wang and Lantsman
`disclose very different systems
`
`• Wang and Lantsman both disclose magnetron plasma sputtering
`
`Wang
`
`Lantsman
`
`Wang at 3:16-19, (Ex. 1005)
`
`Lantsman at 1:6-8, (Ex. 1004)
`
`• Wang and Lantsman both use two power supplies
`Wang
`
`Lantsman
`
`Wang at 7:57-63, (Ex. 1005)
`
`Lantsman at 3:47-50, (Ex. 1004)
`
`20
`
`

`
`A Person of Skill Would Have Been Motivated to
`Combine Wang and Lantsman (Claims 1, 10, 21, and 41)
`
`• Wang and Lantsman both discuss arc reduction
`
`Wang
`
`Lantsman
`
`Wang at 7:47-49 (Ex. 1005)
`
`Lantsman at 1:51-55 (Ex. 1004)
`
`• Wang and Lantsman both use argon feed gas
`
`Wang
`
`Lantsman
`
`Wang at 4:5-7 (Ex. 1005)
`
`Lantsman at 4:8-10 (Ex. 1004)
`
`21
`
`

`
`A Person of Skill Would Have Been Motivated to
`Combine Wang and Lantsman (Claims 1, 10, 21, and 41)
`
`• Lantsman’s technique uses continuous feed gas throughout process
`
`Lantsman at 3:9-13 (Ex. 1004)
`
`• Lantsman’s technique applies to Wang
`
`Lantsman at 6:14-17 (Ex. 1004)
`
`22
`
`

`
`Kudryavtsev Confirms Wang’s Applied Voltage Pulse
`Creates a Strongly-Ionized Plasma
`(Claims 21, 31, and 41)
`
`“I understand Kudryavtsev to be a study of
`the behavior of plasma, and modeling such
`behavior, which is general in its application”
`
`Overzet Dec. at ¶ 61 (Ex. 1022);
`’759 Kortshagen Deposition at 144:7-12
`
`Kudryavtsev at 30, 31;
`see also Overzet Dec. ¶ 61-65 (Ex. 1036);
`Kortshagen Dec. at ¶ 122-123 (Ex. 1202)
`
`23
`
`

`
`Kudryavtsev’s Teachings are Generally Applicable
`Whenever a Field is Suddenly Applied to a Weakly
`Ionized Plasma (Claims 21, 31, and 41)
`
`Kudyravtsev at p. 34, right col., ¶ 4
`
`Wang, Fig. 6, (Ex. 1005)
`
`24
`
`

`
`Combining Wang and Kudryavtsev
`(Claims 21, 31, and 41)
`• Zond argues that Wang cannot be combined with Kudryavtsev because:
`
`‒ Physical differences in chamber geometry
`
`‒ Absence of magnetic field in Kudryavtsev
`‒ Differences in gas pressure
`
`• Patent Owner’s arguments improperly focus on the physical
`apparatus used by Kudryavtsev to experimentally verify his model.
`
`‒ A person of ordinary skill in the art would be motivated to apply
`Kudryavtsev’s generally-applicable model to Wang’s pulsed plasma system.
`
`Overzet Dec. at ¶ 62 (Ex. 1022)
`
`25
`
`

`
`Kudryavtsev’s Teachings are Not Limited to Any
`Specific Experiment (Claims 21, 31, and 41)
`
`Q. And Kudryavtsev is essentially analogous to a flash tube;
`is that right?
`
`A. . . . Kudryavtsev really consists of two parts. First, the
`description of a model, which as Kudryavtsev states
`himself, should be applied whenever one faces a situation
`of a plasma being exposed to a pulse electric field. And
`then a part two which describes a particular experiment,
`one of many possible in which he chooses to verify this
`model with the understanding that he could have chosen
`a lot other implementations of this particular experiment.”
`
`’759 Kortshagen Deposition at 144:7-19 (interposing objections omitted)
`
`26
`
`

`
`Wang and Kudryavtsev (Claims 21, 31, and 41)
`
`• Wang discloses using electrical pulses to increase plasma density
`
`• Kudryavtsev studies effects of applying a sudden field to a
`weakly-ionized plasma to increase plasma density
`
`Wang at 7:25-30 (Ex. 1005)
`
`Kudryavtsev at p. 34 (Ex. 1204)
`
`27
`
`

`
`Wang and Kudryavtsev (Claims 21, 31, and 41)
`
`• Wang’s goal is to generate “very high plasma density”
`
`• Kudryavtsev provides model for fast-stage ionization via
`increasing number of atoms in excited states
`
`Wang at Abstract (Ex. 1005)
`
`Kudryavtsev at Abstract (Ex. 1204)
`
`28
`
`

`
`Wang Discloses a “Gap” Between Cathode and Anode
`(Claim 21)
`
`• The term gap refers to the space between the anode and
`cathode in which an electric field is generated.
`
`Overzet Dec. at ¶ 122 (Ex. 1022)
`
`• Broadest reasonable interpretation does not require the gap to
`be less than 10 cm as Patent Owner proposes
`
`• Patent Owner’s declarant admitted that all plasma chambers
`inherently have a cathode-anode gap
`
`Q: There was a gap between the anode and the cathode; correct?
`
`A: Well, the anode wasn’t in contact with the cathode. Otherwise,
`it would short out, so -- but the nature of that gap I don’t
`remember.
`
`’716 Hartsough Deposition at 102:9-15 (interposing objections omitted)
`
`29
`
`

`
`Wang Discloses a “Gap” Between Cathode and Anode
`(Claim 21)
`
`• Patent Owner admits that Wang teaches choosing a cathode-
`anode gap distance that is similar to the ’142 gap
`
`IPR2014-00819, Patent Owner Response (Paper 26) at 53
`
`• This purported gap distance in Wang differs from the distance
`put forth by Patent Owner regarding the ’716 Patent
`
`IPR2014-00807, Patent Owner Response (Paper 29) at 36-37
`
`30
`
`

`
`Disputes with Respect to Dependent Claims
`
`• Claims 3 and 12
`
`‒ Whether Wang and Lantsman disclose supplying additional feed
`gas to “exchange the weakly-ionized plasma while applying the
`electrical pulse across.”
`
`• Claims 4, 5, 22, 23, 33, and 34
`
`‒ Whether Wang discloses supplying a “constant power” and a
`“constant voltage”
`
`• Claim 6 and 29
`
`‒ Whether Wang discloses an ionization source comprising “an
`electrode coupled to a DC power supply.”
`
`31
`
`

`
`Disputes with Respect to Dependent Claims
`
`• Claims 13, 24, and 32
`
`‒ Whether Wang discloses a “quasi-static electric field”
`
`• Claims 14, 26, 28, and 36
`
`‒ Whether Wang discloses choosing the rise-time or pulse width of the
`electric field (claims 14, 26, and 36) or choosing the cathode/anode gap
`dimensions (claim 28) to “increase an ionization rate of the excited atoms
`in the weakly-ionized plasma”
`
`• Claims 15, 27, 37, and 38
`
`‒ Whether Wang discloses strongly-ionized plasma that is “substantially
`uniform proximate to the cathode” (claims 27 and 38) or selecting a pulse
`amplitude or width to cause the strongly-ionized plasma to be
`“substantially uniform” (claim 15) or “substantially uniform in an area
`adjacent to a surface of the cathode” (claim 37).
`
`32
`
`

`
`Wang And Lantsman Disclose Exchanging The Weakly-
`ionized Plasma With Feed Gas While Applying The
`Electrical Pulse (Claims 3 and 12)
`• Applying Lantsman’s teaching of continuously supplying feed gas
`during processing, Wang’s feed gas will exchange the weakly-
`ionized plasma while applying its high power pulse, PP .
`
`Kortshagen Dec. at ¶ 146 (Ex. 1002); Overzet Dec. at ¶ 87 (Ex. 1022)
`
`• Lantsman’s use of two DC power supplies does not affect application
`of its disclosed continuous feed gas to the system of Wang
`
`‒ Patent Owner incorrectly focuses on physical differences between
`the systems’ power supplies
`
`Overzet Dec. at ¶ 87 (Ex. 1022)
`
`33
`
`

`
`“Constant power” and “Constant voltage”
`(Claims 4, 5, 22, 23, 33, and 34)
`
`• Wang discloses square
`waveforms for voltage and
`power pulses
`
`Hartsough Dec. ¶ 57, (Ex. 2005)
`
`Wang, Fig. 6 (Ex. 1005)
`
`Wang, Fig. 4 (Ex. 1005)
`
`Wang, Fig. 7 (excerpted) (Ex. 1005)
`
`34
`
`

`
`“Quasi-static electric field” (Claims 13, 24, and 32)
`
`• Wang teaches claimed “quasi static electric field”
`
`50 µs >> 0.188 µs
`
`’142 Patent at 7:16-19
`
`Wang at 5:45-48 (Ex. 1022)
`
`Petition, IPR2014-00818, at 52
`
`35
`
`

`
`“Quasi-static electric field” (Claims 13, 24, and 32)
`
`Ignition
`Phase
`
`Maintenance
`Phase
`
`Patent Owner’s Declarant
`Dr. Hartsough
`
`Q: If the region between T5 and T6 in
`Figure 5 is longer than the collision
`time for electrons, that would meet
`the ‘775 patent’s definition of a
`quasi-static electric field; right?
`
`A: If it were -- yeah, if it were
`constant.
`
`’775 Hartsough Deposition at 137:25-138:8
`(interposing objections omitted)
`
`Overzet Dec. ¶ 110, (Ex. 1022)
`
`36
`
`’775 Patent, Fig. 5
`(Identical to ’142 Fig. 4)
`(Annotated)
`
`

`
`Kudryavtsev Teaches a Voltage Pulse Increases the
`Ionization Rate (Claims 14, 26, 28 and 32)
`
`Slow Stage
`
`Fast Stage
`
`Generation of Excited Atoms
`
`Multi-Step Ionization
`
`Direct Ionization
`
`Korstagen Dec. at ¶ 81 (Ex. 1202);
`see also Decision on Institution at p. 17 (Paper No. 11)
`
`’142 Patent
`
`Kudryavtsev
`
`’142 Patent at 8:19-25 (Ex. 2005)
`
`Kudyravtsev at p. 31, right col., ¶ 6;
`Overzet Dec. at ¶ 62 (Ex. 1022);
`’759 Kortshagen Deposition at 148:14-149:15
`
`37
`
`

`
`Kudryavtsev Teaches a Voltage Pulse Increases the
`Ionization Rate (Claims 14, 26, 28 and 32)
`
`Slow Stage
`
`Fast Stage
`
`Generation of Excited Atoms
`
`Multi-Step Ionization
`
`Direct Ionization
`
`Korstagen Dec. at ¶ 81 (Ex. 1202);
`see also Decision on Institution at p. 17 (Paper No. 11)
`
`’142 Patent
`
`Kudryavtsev
`
`’142 Patent at 8:25-35
`
`Kudyravtsev at p. 31, right col., ¶ 6 (Ex. 1204)
`
`38
`
`

`
`Kudryavtsev Teaches a Voltage Pulse Increases the
`Ionization Rate (Claims 14, 26, 28 and 32)
`
`Q. What causes the increase in electron density?
`
`A. So according to Kudryavtsev, which is a very insightful paper,
`in a pulse discharge electron density increases due to an
`increase in ionization, and this increase in ionization can be
`caused by an increase in stepwise ionization…. The increase
`in stepwise ionization, according to Kudryavtsev’s paper, is
`caused by an increase in the density of excited atoms.… The
`increase of the density of excited atoms is caused by an
`increase in the excitation rate of ground state atoms.
`
`Q. And what increases the excitation rate of ground state atoms?
`
`A. So the excitation rate of ground state atoms is mathematically
`defined as a rate coefficient, which depends on the electric
`field strength, so here the voltage pulse, and times the
`electron density times the density of ground state atoms.
`
`’759 Kortshagen Deposition at 148:14-149:15 (Interposing Questions Omitted)
`
`39
`
`

`
`Wang Discloses An Electrode Coupled To A
`DC Power Supply (Claims 6 and 29)
`
`• A cathode and anode are specific examples of electrodes.
`
`Q. And an anode is an electrode; right?
`
`Zond’s Expert
`Dr. Hartsough
`
`A. An anode is an electrode.
`
`Q. A cathode is an electrode; correct?
`
`A. Yes.
`
`’142 Hartsough Deposition at 35:23-36:4 (objections omitted)
`
`• Patent Owner incorrectly relies on one embodiment when
`concluding that the claimed electrode must be a filament
`separate from the cathode and anode
`
`Zond’s Expert
`Dr. Hartsough
`
`A. It -- in it's broadest possible interpretation, "electrode" would
`include the ionizing filament or other electrodes in the system.
`Q. You're referring now to the word "electrode" in Claim 6; correct?
`A. Yes
`Q. So it would include the anode and the cathode; correct?
`A. It could.
`
`’142 Hartsough Deposition at 35:23-36:4 (Ex. 1024) (objections omitted)
`
`40
`
`

`
`Wang Discloses a Substantially Uniform Plasma
`(Claims 15, 27, 37, and 38)
`
`Overzet, FIG. 2 (Ex. 1022)
`
`Wang, Fig. 1 (Ex. 1005)
`
`41
`
`

`
`Wang Discloses a Substantially Uniform Plasma
`(Claims 15, 27, 37, and 38)
`
`• Wang’s controlled voltage pulse increases plasma density
`
`• Spreading the plasma will result in a uniform plasma
`
`Wang at 7:25-30 (Ex. 1005)
`
`Overzet Decl. at ¶104 (Ex. 1022)
`
`42
`
`

`
`Conclusion
`
`• All disputed claims of the ’142 Patent are invalid.
`
`Ground
`
`Claims
`
`Prior Art
`
`818 Petition (IPR 2014-00866, IPR2014-01012, and IPR2014-01075 are joined with the 818)
`
`2
`
`3
`
`1, 3-7, 9, 10, 12, 15,
`19, 20, and 42
`
`Wang+ Lantsman
`
`8, 17, and 18
`
`Wang + Lantsman + Mozgrin
`
`819 Petition (IPR2014-00867, IPR2014-01014, and IPR2014-01046 are joined with the 819)
`
`3
`
`21, 24, 26-28, 31, 32,
`37, and 38
`
`Wang + Kudryavtsev
`
`821Petition (IPR2014-00863, IPR2014-01013, and IPR2014-01057 are joined with the 821)
`
`2
`
`4
`
`6
`
`13 and 14
`
`2 and 11
`
`Wang+ Lantsman
`
`Wang+ Lantsman + Kudryavtsev
`
`16
`
`Wang+ Lantsman + Mozgrin Thesis
`
`43
`
`

`
`Conclusion
`
`• All disputed claims of the ’142 Patent are invalid.
`
` Ground
`
`Prior Art
`
`Claims
`
`00827 Petition (IPR 2014-00865, IPR2014-01015, and IPR2014-01063 are joined with the 827)
`
`2
`
`22, 23, 25, 29, 30, 33-
`36, 39, and 43
`
`Wang + Kudryavtsev
`
`01098 Petition (IPR2014-01016 is joined with the 1098)
`
`4
`
`2
`
`40
`
`41
`
`Wang+ Lantsman
`
`Wang+ Kudryavtsev
`
`44
`
`

`
`RESERVED SLIDES
`RESERVED SLIDES
`
`45
`
`

`
`The ’142 Patent – Fig. 3
`
`’142 Patent, 11:16-19
`
`’142 Patent, 11:34-38
`
`’142 Patent, 12:19-11
`
`46
`
`’142 Patent, Fig. 3
`
`

`
`The ’142 Patent – Fig. 3
`
`’142 Patent, 6:25-30
`
`’142 Patent, 11:52-56
`
`47
`
`’142 Patent, Fig. 3
`
`

`
`Trial No. IPR2014-00819
`Petitioner’s Demonstrative Exhibits for Oral Argument
`
`
`
`
`Dated: June 9, 2015
`
`Respectfully Submitted,
`
`
`
`/s/ David M. Tennant
`David M. Tennant
`Lead Counsel for Petitioner
`GlobalFoundries
`Registration No. 48,362
`
`
`
`
`
`
`
`
`
`

`
`Trial No. IPR2014-00819
`Petitioner’s Demonstrative Exhibits for Oral Argument
`
`
`CERTIFICATE OF SERVICE
`
`
`
`
`Pursuant to 37 C.F.R. § 42.6(e), this is to certify that I caused to be served a
`
`true and correct copy of the foregoing “PETITIONER’S DEMONSTRATIVE
`
`EXHIBITS FOR ORAL ARGUMENT” as detailed below:
`
`
`
`
`
`Date of service June 9, 2015
`
`Manner of service Email: bbarker@chsblaw.com;
`gonsalves@gonsalveslawfirm.com; kurt@rauschenbach.com
`
`Documents served PETITIONER’S DEMONSTRATIVE EXHIBITS FOR
`ORAL ARGUMENT
`
`Persons Served Bruce Barker
`Chao Hadidi Stark & Barker LLP
`176 East Mail Street, Suite 6
`Westborough, MA 01581
`
`Dr. Gregory J. Gonsalves
`2216 Beacon Lane
`Falls Church, Virginia 22043
`
`
`
`/s/ Anna Goodall
`Anna Goodall
`White & Case LLP
`3000 El Camino Real
`Five Palo Alto Square, 9th Floor
`Palo Alto, CA 94306
`Tel: (650) 213-0367
`Email: agoodall@whitecase.com

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

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.

throbber

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.

Become a Member

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

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket