Attorney Docket N0.: ZON-001
`
`PATENT
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`APPLICANTS:
`
`Chistyakov
`
`SERIAL NO.:
`
`10/065,277
`
`GROUP NO.:
`
`1753
`
`FILING DATE:
`
`September 30, 2002
`
`EXAMINER:
`
`Rodney G. McDonald
`
`TITLE:
`
`High-Power Pulsed Magnetron Sputtering
`
`Mail Stop RCE
`Commissioner of Patents
`
`PO. Box 1450
`
`Alexandria, Virginia 22313-1450
`
`AMENDMENT AND RESPONSE FOR RCE
`
`Sir:
`
`The Applicant requests non—entry of the Amendment and Response After Final that was
`
`filed March 8, 2006, which was not entered. Instead, the Applicant request entry of this
`
`Amendment and Response for RCE. The following remarks are responsive to the final Office
`
`Action mailed on January 11, 2006 in the above-identified patent application. Consideration of
`
`the following remarks, and allowance of the claims, as presented, is respectfully requested. A
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`Request for Continued Examination (RCE) and a Petition for a one-month extension of time, up
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`to and including May 11, 2006 are submitted herewith. Authorization to charge Attorney’s
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`charge card for the RCE fee, the extension fee and any other proper fees is given in the EFS-
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`Web filing submission papers.
`
`Amendments to the Claims begin on page 2 of this paper.
`
`Remarks are on page 9 of this paper.
`
`TSMC v. Zond, Inc.
`Page 1 of 17
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`TSMC-1014
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`TSMC-1014
`TSMC v. Zond, Inc.
`Page 1 of 17
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`

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`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial N0.: 10/065,277
`Page 2 of 17
`
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`Amendments to the Claims:
`
`Please amend claims 1, 20, and 40 as follows:
`
`1.
`
`(currently amendment) A magnetically enhanced sputtering source comprising:
`
`a)
`
`b)
`
`an anode;
`
`a cathode assembly that is positioned adjacent to the anode, the cathode assembly
`
`including a sputtering target;
`
`0)
`
`an ionization source that generates a weakly-ionized plasma proximate to the
`
`anode and the cathode assembly;
`
`(1)
`
`a magnet that is positioned to generate a magnetic field proximate to the weakly-
`
`ionized plasma, the magnetic field substantially trapping electrons in the weakly—
`
`ionized plasma proximate to the sputtering target; and
`
`e)
`
`a power supply generating a voltage pulse that produces an electric field between
`
`the cathode assembly and the anode, the power supply being configured to
`
`generate the voltage pulse with an amplitude and a rise time ef—tlaeyeltagejaulse
`
`beingehesen—te that increases an excitation rate of ground state atoms that are
`
`present in the weakly-ionized plasma to create a multi-step ionization process that
`
`generates a strongly—ionized plasma, which comprises ions that sputter target
`
`
`material from the weakly-ionized plasma, the multi-step ionization process
`
`comprising exciting the ground state atoms to generate excited atoms, and then
`
`ionizing the excited atoms within the weakly—ionized plasma without forming an
`
`We.
`
`2.
`
`(original) The sputtering source of claim 1 wherein the power supply generates a
`
`constant power.
`
`3.
`
`(original) The sputtering source of claim 1 wherein the power supply generates a
`
`constant voltage.
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`TSMC-1014 / Page 2 of 17
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`TSMC-1014 / Page 2 of 17
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`

`

`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial No.: 10/065,277
`Page 3 of 17
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`4.
`
`(original) The sputtering source of claim 1 wherein the electric field comprises a quasi-
`
`static electric field.
`
`5.
`
`(original) The sputtering source of claim 1 wherein the electric field comprises a pulsed
`
`electric field.
`
`6.
`
`(previously presented) The sputtering source of claim 1 wherein the rise time of the
`
`voltage pulse is chosen to increase the ionization rate of the excited atoms in the weakly—
`
`ionized plasma.
`
`7.
`
`(previously presented) The sputtering source of claim 1 wherein the weakly-ionized
`
`plasma reduces the probability of developing an electrical breakdown condition between
`
`the anode and the cathode assembly.
`
`8.
`
`(original) The sputtering source of claim 1 wherein the ions in the strongly-ionized
`
`plasma impact the surface of the sputtering target in a manner that causes substantially
`
`uniform erosion of the sputtering target.
`
`9.
`
`(original) The sputtering source of claim 1 wherein the strongly-ionized plasma is
`
`substantially uniform proximate to the sputtering target.
`
`10.
`
`(original) The sputtering source of claim 1 further comprising a substrate support that is
`
`positioned in a path of the sputtering flux.
`
`11.
`
`(original) The sputtering source of claim 10 further comprising a temperature controller
`
`that controls the temperature of the substrate support.
`
`12.
`
`(original) The sputtering source of claim 10 further comprising a bias voltage power
`
`supply that applies a bias voltage to a substrate that is positioned on the substrate support.
`
`13.
`
`(original) The sputtering source of claim 1 wherein a volume between the anode and the
`
`cathode assembly is chosen to increase the ionization rate of the excited atoms in the
`
`weakly-ionized plasma.
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`TSMC-1014 / Page 3 of 17
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`TSMC-1014 / Page 3 of 17
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`

`

`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial No.: 10/065,277
`Page 4 of 17
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`14.
`
`(original) The sputtering source of claim 1 wherein the ionization source comprises an
`
`electrode.
`
`15.
`
`(original) The sputtering source of claim 1 wherein the ionization source comprises a DC
`
`power supply that generates an electric field proximate to the anode and the cathode
`
`assembly.
`
`16.
`
`(original) The sputtering source of claim 1 wherein the ionization source comprises an
`
`AC power supply that generates an electric field proximate to the anode and the cathode
`
`assembly.
`
`17.
`
`(original) The sputtering source of claim 1 wherein the ionization source is chosen from
`
`the group comprising a UV source, an X-ray source, an electron beam source, and an ion
`
`beam source.
`
`18.
`
`(original) The sputtering source of claim 1 wherein the magnet comprises an electro—
`
`magnet.
`
`19.
`
`(original) The sputtering source of claim 1 wherein the sputtering target is formed of a
`
`material chosen from the group comprising a metallic material, a polymer material, a
`
`superconductive material, a magnetic material, a non-magnetic material, a conductive
`
`material, a non-conductive material, a composite material, a reactive material, and a
`
`refractory material.
`
`20.
`
`(currently amended) A method of generating sputtering flux, the method comprising:
`
`a)
`
`ionizing a feed gas to generate a weakly-ionized plasma proximate to a sputtering
`
`target;
`
`b)
`
`generating a magnetic field proximate to the weakly-ionized plasma, the magnetic
`
`field substantially trapping electrons in the weakly-ionized plasma proximate to
`
`the sputtering target; and
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`TSMC-1014 / Page 4 of 17
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`TSMC-1014 / Page 4 of 17
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`

`

`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial No: 10/065,277
`Page 5 of 17
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`c)
`
`applying a voltage pulse to the weakly-ionized plasma, an amplitude and a rise
`
`time of the voltage pulse being chosen to increase an excitation rate of ground
`
`state atoms that are present in the weakly-ionized plasma to create a multi-step
`
`ionization process that generates a strongly-ionized plasma, which comprises ions
`
`that sputter target material, from the weakly-ionized plasma, the multi-step
`
`ionization process comprising exciting the ground state atoms to generate excited
`
`atoms, and then ionizing the excited atoms within the weakly—ionized plasma
`
`without forming an arc discharge te—sputtestsrget—mater—ialrfiem—the—sputtermg
`
`target.
`
`21.
`
`(original) The method of claim 20 wherein the applying the electric field comprises a
`
`applying a quasi-static electric field.
`
`22.
`
`(original) The method of claim 20 wherein the applying the electric field comprises
`
`applying a substantially uniform electric field.
`
`23.
`
`(original) The method of claim 20 wherein the applying the electric field comprises
`
`applying an electrical pulse across the weakly-ionized plasma.
`
`24.
`
`(original) The method of claim 23 further comprising selecting-at least one of a pulse
`
`amplitude and a pulse width of the electrical pulse that increases an ionization rate of the
`
`strongly—ionized plasma.
`
`25.
`
`(original) The method of claim 23 further comprising selecting at least one of a pulse
`
`amplitude and a pulse width of the electrical pulse that reduces a probability of
`
`developing an electrical breakdown condition proximate to the sputtering target.
`
`26.
`
`(original) The method of claim 23 further comprising selecting at least one of a pulse
`
`amplitude and a pulse width of the electrical pulse that causes the strongly~ionized
`
`plasma to be substantially uniform in an area adjacent to a surface of the sputtering target.
`
`27.
`
`(original) The method of claim 23 wherein the electrical pulse comprises a pulse having
`
`a current density that is greater than lA/cm2.
`
`TSMC-1014 / Page 5 of 17
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`TSMC-1014 / Page 5 of 17
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`

`

`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial No.: 10/065,277
`Page 6 of 17
`
`28.
`
`(original) The method of claim 23 wherein the electrical pulse comprises a pulse having
`
`a pulse width that is greater than 1.0 microseconds.
`
`29.
`
`(original) The method of claim 23 wherein the electrical pulse comprises a pulse train
`
`having a repetition rate that is substantially between 0.1Hz and lkHz.
`
`30.
`
`(original) The method of claim 20 wherein the ions in the strongly-ionized plasma
`
`impact the surface of the sputtering target in a substantially uniform manner.
`
`31.
`
`(original) The method of claim 20 wherein the strongly-ionized plasma is substantially
`
`uniform proximate to the sputtering target.
`
`32.
`
`(original) The method of claim 20 wherein the peak plasma density of the weakly-
`
`ionized plasma is less than about 1012 cm'3.
`
`33.
`
`(original) The method of claim 20 wherein the peak plasma density of the strongly-
`
`ionized plasma is greater than about 1012 cm'3.
`
`34.
`
`(previously presented) The method of claim 20 further comprising forming a film on a
`
`surface of a substrate from the material sputtered from the sputtering target.
`
`35.
`
`(original) The method of claim 34 further comprising controlling a temperature of the
`
`film.
`
`36.
`
`(original) The method of claim 34 further comprising applying a bias voltage to the film.
`
`37.
`
`(original) The method of claim 20 wherein the ionizing the feed gas comprises exposing
`
`the feed gas to an electric field.
`
`38.
`
`(original) The method of claim 20 wherein the ionizing the feed gas comprises exposing
`
`the feed gas to an electrode that is adapted to emit electrons.
`
`39.
`
`(original) The method of claim 20 wherein the ionizing the feed gas comprises exposing
`
`the feed gas to at least one of a UV source, an X-ray source, an electron beam source, and
`
`an ion beam source.
`
`TSMC-1014 / Page 6 of 17
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`TSMC-1014 / Page 6 of 17
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`

`

`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial No.: 10/065,277
`Page 7 of 17
`
`40.
`
`(currently amended) A magnetically enhanced sputtering source comprising:
`
`a)
`
`means for ionizing a feed gas to generate a weakly—ionized plasma proximate to a
`
`sputtering target;
`
`b)
`
`means for generating a magnetic field proximate to the weakly-ionized plasma,
`
`the magnetic field substantially trapping electrons in the weakly-ionized plasma
`
`proximate to the sputtering target; and
`
`c)
`
`means for applying a voltage pulse to the weakly-ionized plasma, an amplitude
`
`and a rise time of the voltage pulse being chosen to increase an excitation rate of
`
`ground state atoms that are present in the weakly-ionized plasma to create a multi—
`
`step ionization process that generates a strongly-ionized plasma from the weakly—
`
`ionized plasma, the multi—step ionization process comprising exciting the ground
`
`state atoms to generate excited atoms, and then ionizing the excited atoms within
`
`the weakly-ionized plasma, without forming an arc discharge, to ions that sputter
`
`target material from the sputtering target.
`
`(previously presented) The sputtering source of claim 1 wherein the cathode assembly
`
`and the anode are positioned so as to form a gap therebetween.
`
`(previously presented) The sputtering source of claim 1 wherein the weakly-ionized
`
`plasma is generated from a feed gas that comprises the ground state atoms.
`
`(previously presented) The sputtering source of claim 1 wherein the excited atoms within
`
`the weakly—ionized plasma are ionized by electrons to create the ions that sputter material
`
`from the sputtering target.
`
`(previously presented) The sputtering source of claim 1 wherein the rise time of the
`
`voltage pulse is approximately between 0.01 and lOOV/usec.
`
`(previously presented) The sputtering source of claim 1 wherein the amplitude of the
`
`voltage pulse is approximately between 100V and 30kV.
`
`41.
`
`42.
`
`43.
`
`44.
`
`45.
`
`TSMC-1014 / Page 7 of 17
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`TSMC-1014 / Page 7 of 17
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`

`

`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial No.: 10/065,277
`Page 8 of 17
`
`46.
`
`47.
`
`48.
`
`49.
`
`50.
`
`(previously presented) The method of claim 20 wherein the weakly-ionized plasma is
`
`generated from a feed gas that comprises the ground state atoms.
`
`(previously presented) The method of claim 20 wherein a duration of the weakly-ionized
`
`plasma is approximately between one microsecond and one hundred seconds.
`
`(previously presented) The method of claim 20 wherein the ionizing the excited atoms
`
`within the weakly-ionized plasma to create ions that sputter material from the sputtering
`
`target comprises ionizing the excited atoms with electrons.
`
`(previously presented) The method of claim 20 wherein the rise time of the voltage pulse
`
`is approximately between 0.01 and 100V/usec.
`
`(previously presented) The method of claim 20 wherein the amplitude of the voltage
`
`pulse is approximately between 100V and 30kV.
`
`TSMC-1014 / Page 8 of 17
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`TSMC-1014 / Page 8 of 17
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`

`

`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial No.: 10/065,277
`Page 9 of 17
`
`REMARKS
`
`Reguest for an Examiner’s Interview
`
`The Applicant and the Applicant’s Attorney hereby request an interview with the
`
`Examiner in order to expedite the prosecution of this case.
`
`Pending Claims
`
`Claims 1-50 are currently pending. Independent claims 1, 20, and 40 have been
`
`amended.
`
`Re'ections under 35 U.S.C. 102 b As Bein Antici ated b Kouznetsov
`
`
`Claims 1, 5-10, 13-14, 16, 19-20, 22-31, 34, 37-38, and 40-50 are rejected under 35
`
`U.S.C. §102(b) as being anticipated by Kouznetsov (WO98/40532) (hereinafter “Kouznetsov”).
`
`To anticipate a claim under 35 U.S.C. §102, a single reference must teach every aspect of
`
`the claimed invention either explicitly or impliedly. Any feature not directly taught by the
`
`reference must be inherently present in the reference. Thus, a claim is anticipated by a reference
`
`only if each and every element of the claim is described, either expressly or inherently, in a
`
`single prior art reference.
`
`Independent Claim 1 and Dependent Claims 5-10, 13, 14, 16, and 19
`
`The Applicant respectfully submits that Kouznetsov does not describe each and every
`
`element of independent claim 1 as currently amended. Independent claim 1 has been amended to
`
`recites that the power supply is configured to generate a voltage pulse with an amplitude and a
`
`rise time that increases the excitation rate of ground state atoms that are present in the weakly-
`
`ionized plasma to create a multi—step ionization process that generates a strongly-ionized plasma
`
`comprising ions that sputter target material from the sputtering target. In addition, independent
`
`claim 1 has been amended to recite that the multi-step ionization process comprises exciting the
`
`ground state atoms to generate excited atoms, and then ionizing the excited atoms within the
`
`weakly-ionized plasma Without forming an arc discharge.
`
`TSMC-1014 / Page 9 of 17
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`TSMC-1014 / Page 9 of 17
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`

`

`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial No.: 10/065,277
`Page 10 of 17
`
`The Applicant submits that there is no description in Kouznetsov of the power supply
`
`claimed in independent claim 1. In particular, the Applicant submits that there is no description
`
`in Kouznetsov of a multi-step ionization process that first excites ground state atoms to generate
`
`excited atoms, and then ionizes the excited atoms without forming an arc discharge. In contrast,
`
`Kouznetsov specifically describes a power supply that causes the gas to very rapidly transition to
`
`a fully ionized state by using an arc discharge. According to Kouznetsov, the gas first adapts the
`
`state of a glow discharge and then continues to the state of an arc discharge in order to finally
`
`adopt a fully ionized state. See Kouznetsov, page 5, lines 6-8. Thus, the Applicant respectfully
`
`submits that Kouznetsov does not describe each and every element of independent claim 1 as
`
`currently amended for at least the reason that amended independent claim 1 requires a multi-step
`
`ionization process that prevents the formation of an arc discharge.
`
`In addition, Kouznetsov does not teach the multi-step ionization process claimed in
`
`amended independent claim 1. Independent claim 1 as currently amended recites that the
`
`amplitude and the rise time of the voltage pulse are specifically chosen to increase an excitation
`
`rate of ground state atoms that are present in the weakly-ionized plasma to create a multi-step
`
`ionization process at the atomic level that generates a strongly-ionized plasma from the weakly-
`
`ionized plasma. This argument was presented in the Response filed on February 24, 2005 and in
`
`the Response for RCE filed on October 27, 2005. In the Office Action dated January 11, 2006,
`
`the Examiner stated that this argument was not persuasive because Kouznetsov teaches utilizing
`
`a pulse which has an amplitude and a rise time and that such a pulse will allow the plasma to go
`
`from a partially ionized state to a fully ionized state.
`
`The Applicant agrees with the Examiner’s statement that Kouznetsov teaches utilizing a
`
`pulse that allows the plasma to go from a partially ionized state to a fully ionized state.
`
`However, the method described in Kouznetsov of transitioning from a partially ionized state to a
`
`fully ionized state using an arc discharge is not equivalent to the claimed multi-step process.
`
`The description in Kouznetsov of the terms “partial ionization” and “more ionized” refer to the
`
`state of the plasma macroscopically that is used to generate the ions in the plasmas. The term
`
`“partially ionized” plasma refers to plasmas that have some ionized ground state atoms and many
`
`neutral ground state atoms. The term “more ionized” plasma refers to plasmas that have more
`
`TSMC-1014 / Page 10 of 17
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`TSMC-1014 / Page 10 of 17
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`

`

`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial No.: 10/065,277
`Page 11 of 17
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`ionized ground state atoms and less neutral ground state atoms compared with the “partially
`
`ionized” plasma. The macroscopic state of ionization (i.e. the “partially ionized” or “more
`
`ionized” plasma state) does not imply anything about the particular ionization process at the
`
`atomic level (i.e. direct ionization or the multi-step ionized described in the present application)
`
`that is used to ionize the ground state atoms to form the “partially ionized” or “more ionized”
`
`plasma.
`
`The term “multi—step” ionization as used in the present application does not mean an
`
`ionization process where the plasma goes from a partially ionized state to a fully ionized state as
`
`suggested by the Examiner in the Office Action dated January 11, 2006. Instead, the term
`
`“multi—step” ionization as used in the present application refers to an ionization process that
`
`requires ground state atoms and molecules to transition from the ground state to at least one
`
`intermediate excited state before being fully ionized. The present specification provides an
`
`example of Ar multivstep ionization in paragraph 63. This paragraph states that an argon atom
`
`requires an energy of about 11.55eV at the atomic level to become excited. The excited atoms
`
`then require about 4eV of energy at the atomic level to ionize. In contrast, neutral argon atoms
`
`ionized by the direct ionization process described in Kouznetsov require about 15.76eV of
`
`energy at the atomic level.
`
`In View of the above remarks, the Applicant respectfully submits that Kouznetsov does
`
`not describe each and every element of independent claim 1 as currently amended, either
`
`expressly or inherently. Therefore, the Applicant submits that Kouznetsov does not anticipate
`
`independent claim 1 under 35 U.S.C. §102(b). Thus, the Applicant submits that independent
`
`claim 1 is allowable. The Applicant also submits that dependent claims 5—10, 13, l4, l6, and 19
`
`are allowable as depending from an allowable base claim.
`
`
`Independent Claim 20 and Dependent Claims 22-31, 34,_and 37—38
`
`The Applicant respectfully submits that Kouznetsov does not describe each and every
`
`element of independent claim 20 as currently amended. Amended independent claim 20 recites
`
`the step of applying a voltage pulse to the weakly-ionized plasma where an amplitude and a rise
`
`time of the voltage pulse are chosen to increase an excitation rate of ground state atoms that are
`
`TSMC-1014 / Page 11 of 17
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`TSMC-1014 / Page 11 of 17
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`

`

`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial No.: 10/065,277
`Page 12 of 17
`
`present in the weakly-ionized plasma to create a multi-step ionization process that generates a
`
`strongly-ionized plasma, which comprises ions that sputter target material, from the weakly-
`
`ionized plasma. The claimed multi-step ionization process comprises exciting the ground state
`
`atoms to generate excited atoms, and then ionizing the excited atoms within the weakly-ionized
`
`plasma without forming an arc discharge.
`
`The Applicant respectfully submits that Kouznetsov does not describe each and every
`
`element of independent claim 20 as currently amended for at least the reason that amended
`
`independent claim 20 requires a multi-step ionization process that prevents the formation of an
`
`arc discharge. In addition, the Applicant submits that Kouznetsov does not teach the multi—step
`
`ionization process claimed in amended independent claim 20 in View of the arguments made in
`
`connection with the rejection of amended independent claim 1. Therefore, the Applicant submits
`
`that Kouznetsov does not anticipate independent claim 20. Thus, the Applicant submits that
`
`independent claim 20 and dependent claims 22—3 1, 34, 37, and 38 are allowable under 35 U.S.C.
`
`§102(b).
`
`Independent Claim 40 and Dependent Claims 41-50
`
`The Applicant respectfully submits that Kouznetsov does not describe each and every
`
`element of independent claim 40 as currently amended. Amended independent claim 40 recites
`
`a means for applying a voltage pulse to the weakly-ionized plasma where an amplitude and a rise
`
`time of the voltage pulse is chosen to increase an excitation rate of ground state atoms that are
`
`present in the weakly—ionized plasma to create a multi-step ionization process that generates a
`
`strongly-ionized plasma from the weakly-ionized plasma. The claimed multi-step ionization
`
`process comprises exciting the ground state atoms to generate excited atoms, and then ionizing
`
`the excited atoms within the weakly-ionized plasma without forming an arc discharge.
`
`The Applicant respectfully submits that Kouznetsov does not describe each and every
`
`element of independent claim 40 as currently amended for at least the reason that amended
`
`independent claim 40 requires a multi-step ionization process that prevents the formation of an
`
`arc discharge. In addition, the Applicant submits that Kouznetsov does not teach the multi-step
`
`ionization process claimed in amended independent claim 40 in View of the arguments made in
`
`TSMC-1014 / Page 12 of 17
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`TSMC-1014 / Page 12 of 17
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`

`

`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial No.: 10/065,277
`Page 13 of 17
`
`connection with the rejection of amended independent claim 1. Therefore, the Applicant submits
`
`that Kouznetsov does not anticipate independent claim 40. Thus, the Applicant submits that
`
`independent claim 40 and dependent claims 41-50 are allowable under 35 U.S.C. §102(b).
`
`Re'ections under 35 U.S.C. 102 b as Bein Antici ated b Moz rin
`
`Claims 1, 4-5, 7, 13-14, 16, 19-25, 27-29, 32-33, 37, and 40 are rejected under 35 U.S.C.
`
`§102(b) as being anticipated by Mozgrin et a1. entitled “High Current Low-Pressure Quasi-
`
`Stationary Discharge in a Magnetic Field: Experimental Research”, Plasma Physics Reports,
`
`Vol. 21, No. 5, 1995, pp. 400-409 (hereinafter “Mozgrin”).
`
`To anticipate a claim under 35 U.S.C. §102, a single reference must teach every aspect of
`
`the claimed invention either explicitly or impliedly. Any feature not directly taught by the
`
`reference must be inherently present in the reference. Thus, a claim is anticipated by a reference
`
`only if each and every element of the claim is described, either expressly or inherently, in a
`
`single prior art reference.
`
`Independent Claim 1 and Dependent Claims 4-5, 7I 13-14, 16, and 19
`
`The Applicant respectfully submits that Mozgrin does not describe each and every
`
`element of independent claim 1 as currently amended. Independent claim 1 has been amended to
`
`recites that the power supply is configured to generate a voltage pulse with an amplitude and a
`
`rise time that increases the excitation rate of ground state atoms that are present in the weakly-
`
`ionized plasma to create a multi-step ionization process that generates a strongly-ionized plasma
`
`comprising ions that sputter target material. In addition, independent claim 1 has been amended
`
`to recite that the multi-step ionization process comprises exciting the ground state atoms to
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`generate excited atoms, and then ionizing the excited atoms within the weakly-ionized plasma
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`without forming an arc discharge.
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`The Applicant submits that there is no description in Mozgrin of the power supply
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`claimed in independent claim 1. In particular, the Applicant submits that there is no description
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`in Mozgrin of a multi—step ionization process that first excites ground state atoms to generate
`
`excited atoms, and then ionizes the excited atoms without forming an arc discharge. In contrast,
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`TSMC-1014 / Page 13 of 17
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`TSMC-1014 / Page 13 of 17
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`

`

`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial N0.: 10/065,277
`Page 14 of 17
`
`Mozgrin describes a power supply that generates a current-voltage characteristic that includes a
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`high-current, low-voltage arc discharge regime. See Mozgrin discussion of quasi-stationary
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`discharge regimes beginning on page 402. Part 4 of the voltage oscillogram of the quasi-
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`stationary discharge corresponds to the high-current low-voltage arc discharge. Thus, the
`
`Applicant respectfully submits that Mozgrin does not describe each and every element of
`
`independent claim 1 as currently amended for at least the reason that amended independent claim
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`1 requires a multi-step ionization process that prevents the formation of an arc discharge.
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`In addition, Mozgrin does not teach the multi-step ionization process claimed in
`
`amended independent claim 1. The method of generating the stationary discharge that pre—
`
`ionizes the process gas and the method of generating the quasi-stationary discharge described
`
`in Mozgrin are not equivalent to the claimed multi-step process. Mozgrin describes
`
`generating a stationary discharge that is used to pre-ionize the process gas (See Mozgrin page
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`401, col. 2, lines 12-13) and then generating a quasi-stationary discharge by applying a
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`square voltage pulse to a gap that contains either neutral or pre—ionized gas (See Mozgrin
`
`page 401 , col. 1, lines 35-38). The Applicant believes that both of the stationary discharge
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`and the quasi-stationary discharge are generated using a single-step ionization process known
`
`as direct ionization by electron impact.
`
`The term “multi-step” ionization as used in the present application refers to an
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`ionization process that requires ground state atoms and molecules to transition from the
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`ground state to at least one intermediate excited state before being fully ionized. The present
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`specification provides an example of Ar multi-step ionization in paragraph 63. In this
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`paragraph it is stated that an argon atom requires an energy of about 11.55eV at the atomic
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`level to become excited. The excited atoms then require about 4eV of energy at the atomic
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`level to ionize. In contrast, neutral argon atoms ionized by the direct ionization process
`
`described in Kouznetsov require about 15.76eV of energy at the atomic level.
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`Furthermore, there is no description in Mozgrin of choosing an amplitude and a rise
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`time as claimed in independent claim 1. In contrast, Mozgrin describes varying the plasma
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`discharge conditions by changing the pressure and magnetic field strength. See Mozgrin
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`page 403 lines 8-13.
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`TSMC-1014 / Page 14 of 17
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`TSMC-1014 / Page 14 of 17
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`

`

`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial No.2 10/065,277
`Page 15 of 17
`
`In view of the above remarks, the Applicant respectfully submits that Mozgrin does
`
`not describe each and every element of independent claim 1, either expressly or inherently.
`
`Therefore, the Applicant submits that Mozgrin does not anticipate independent claim 1.
`
`Thus, the Applicant submits that independent claim 1 and dependent claims 4-5, 7, 13-14, 16,
`
`and 19 are allowable under 35 U.S.C. §102(b).
`
`Independent Claim 20 and Dependent Claims 21-25, 27-29, 32, 33, and 37
`
`The Applicant respectfully submits that Mozgrin does not describe each and every
`
`element of independent claim 20 as currently amended. Amended independent claim 20 recites
`
`the step of applying a voltage pulse to the weakly-ionized plasma where an amplitude and a rise
`
`time of the voltage pulse are chosen to increase an excitation rate of ground state atoms that are
`
`present in the weakly-ionized plasma to create a multi-step ionization process that generates a
`
`strongly-ionized plasma comprising ions that sputter target material from the weakly-ionized
`
`plasma. The claimed multi-step ionization process comprises exciting the ground state atoms to
`
`generate excited atoms, and then ionizing the excited atoms within the weakly-ionized plasma
`
`without forming an arc discharge.
`
`The Applicant respectfully submits that Mozgrin does not describe each and every
`
`element of independent claim 20 as currently amended for at least the reason that amended
`
`independent claim 20 requires a multi-step ionization process that prevents the formation of an
`
`arc discharge. In addition, the Applicant submits that Mozgrin does not teach the multi-step
`
`ionization process claimed in amended independent claim 20 in View of the arguments made in
`
`connection with the rejection of amended independent claim 1. Therefore, the Applicant submits
`
`that Mozgrin does not anticipate independent claim 20. Thus, the Applicant submits that
`
`independent claim 20 and dependent claims 22—31, 34, 37, and 38 are allowable under 35 U.S.C.
`
`§102(b).
`
`Independent Claim 40
`
`The Applicant respectfully submits that Mozgrin does not describe each and every
`
`element of independent claim 40 as currently. Amended independent claim 40 recites a means
`
`for applying a voltage pulse to the weakly-ionized plasma where an amplitude and a rise time of
`
`TSMC-1014 / Page 15 of 17
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`TSMC-1014 / Page 15 of 17
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`

`

`Amendment and Response for RCE
`Applicant: Chistyakov
`Serial No.: 10/065,277
`Page 16 of 17
`
`the voltage pulse is chosen to increase an excitation rate of ground state atoms that are present in
`
`the weakly-ionized plasma to create a multi—step ionization process that generates a strongly-
`
`ionized plasma from the weakly-ionized plasma. The claimed multi-step ionization process
`
`comprises exciting the ground state atoms to generate excited atoms, and then ionizing the
`
`excited atoms within the weakly-ionized plasma, without forming an arc discharge, to ions that
`
`sputter target material from the sputtering target.
`
`The Applicant respectfully submits that Mozgrin does not describe each and every
`
`element of independent claim 40 as currently amended for at least the reason that amended
`
`independent claim 40 requires a multi-step ionization process that prevents the formation of an
`
`arc discharge. In addition, the Applicant submits that Mozgrin does not teach the multi-step
`
`ionization process claimed in amended independent claim 40 in view of the arguments made in
`
`connection with the rejection of amended independent claim 1. Therefore, the Applicant submits
`
`that Mozgrin does not anticipate independent claim 40. Thus, the Applicant submits that
`
`independent claim 40 and dependent claims 41-50 are allowable under 35 U.S.C. §102(b).
`
`Rejections under 35 U.S.C. §103§az
`
`Claims 1-3 are rejected under 35 U.S.C. §103(a) as being unpatentable over
`
`Kouznetsov. Claims 1-3, 17, 20, and 39 are rejected under 35 U.S.C. §103(a) as being
`
`unpatentable over Moz