throbber
EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`References cited herein:
`
` U.S. Patent No. 7,604,716 (“‘716 Patent”)
`
` D.V. Mozgrin, et al, High-Current Low-Pressure Quasi-Stationary Discharge in a
`Magnetic Field: Experimental Research, Plasma Physics Reports, Vol. 21, No. 5, 1995
`(“Mozgrin”)
`
` Dennis M. Manos & Daniel L. Flamm, Plasma Etching: An Introduction, Academic Press
`1989 (“Manos”)
`
` Milton Ohring, The Material Science of Thin Films, Academic Press, 1992 (“Ohring”)
`
`
`
`Claims 1-5, 8-11,
`and 33
`
`1. An apparatus
`for generating a
`strongly-ionized
`plasma, the
`apparatus
`comprising:
`
`a. an ionization
`source that
`generates a
`weakly-ionized
`plasma from a
`feed gas
`contained in a
`chamber,
`
`Mozgrin
`
`Mozgrin discloses an apparatus for generating a strongly-ionized plasma.
`
`‘716 Patent at claim 24 (“wherein the peak plasma density of the strongly-
`ionized plasma is greater than about 1012 cm˗3”)
`
`Mozgrin at Fig 1
`
`Mozgrin at 400, right col, ¶ 4 (“To study the high-current forms of the
`discharge, we used two types of devices: a planar magnetron and a ystem
`with specifically shaped hollow electrodes.”)
`
`Mozgrin at 401, right col, ¶2 (“For pre-ionization … the initial plasma
`density in the 109 – 1011 cm-3 range.”)
`
`Mozgrin at 409, left col, ¶ 4 (“The implementation of the high-current
`magnetron discharge (regime 2) in sputtering … plasma density
`(exceeding 2x1013 cm-3).”)
`
`Mozgrin at 409, left col, ¶5 (“The high-current diffuse discharge (regime
`3) is useful for producing large-volume uniform dense plasmas ni 
`1.5x1015cm-3…”).
`
`Mozgrin discloses an ionization source that generates a weakly-ionized
`plasma from a feed gas contained in a chamber.
`
`‘716 Patent at 5:14-15 (“The weakly-ionized plasma 232 is also
`referred to as a pre-ionized plasma.”)
`
`‘716 Patent at claim 23 (“wherein the peak plasma density of the
`weakly-ionized plasma is less than about 1012 cm˗3”)
`
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`

`

`Claims 1-5, 8-11,
`and 33
`
`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`Mozgrin at Figs. 1, 2, 3, 6, 7
`
`Mozgrin at 401, left col, ¶ 1 (“The [plasma] discharge had an
`annular shape and was adjacent to the cathode.”)
`
`Mozgrin at 401, left col, ¶ 4 (“[A]pplying a square voltage pulse to
`the discharge gap which was filled up with either neutral or pre-
`ionized gas.”)
`
`Mozgrin at 402, right col, ¶2 (“Figure 3 shows typical voltage and
`current oscillograms.…
` Part I in the voltage oscillogram
`represents the voltage of the stationary discharge (pre-ionization
`stage).”)
`
`Mozgrin at 401, right col, ¶2 (“[f]or pre-ionization, we used a
`stationary magnetron discharge; … provided the initial plasma
`density in the 109 – 1011 cm˗3 range.”)
`
`Mozgrin at 400, right col, ¶ 3 (“We investigated the discharge
`regimes in various gas mixtures at 10-3 – 10 torr…”)
`
`Mozgrin at 402, ¶ spanning left and right cols (“We studied the
`high-current discharge in wide ranges of discharge current…and
`operating pressure…using various gases (Ar, N2, SF6, and H2) or
`their mixtures of various composition…”)
`
`the weakly-
`ionized plasma
`substantially
`eliminating the
`probability of
`developing an
`electrical
`breakdown
`condition in the
`chamber; and
`
`Mozgrin discloses the weakly-ionized plasma substantially eliminating
`the probability of developing an electrical breakdown condition in the
`chamber.
`
`Mozgrin at 406, right col, ¶3 (“pre-ionization was not necessary; however,
`in this case, the probability of discharge transferring to arc mode
`increased.”).
`
`Mozgrin at Figs. 4 and 7.
`
`Mozgrin at 400, left col, ¶ 3 (“Some experiments on magnetron systems
`of various geometry showed that discharge regimes which do not transit
`to arcs can be obtained even at high currents.”)
`
`Mozgrin at 400, right col, ¶ 1 (“A further increase in the discharge
`currents caused the discharges to transit to the arc regimes…”).
`
`Mozgrin at 404, left col, ¶ 4 (“The parameters of the shaped-electrode
`discharge transit to regime 3, as well as the condition of its transit to arc
`
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`

`Claims 1-5, 8-11,
`and 33
`
`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`regime 4, could be well determined for every given set of the discharge
`parameters.”).
`
`Mozgrin at 403, left col, ¶ 2. (“Then, we studied regimes 2 and 3
`separately to determine the boundary parameters of their occurrence, such
`as current, voltage….”).
`
`Mozgrin at 400, right col, ¶ 1 (“A further increase in the discharge
`currents caused the discharges to transit to the arc regimes….”).
`
`Mozgrin 404, left col, ¶ 4 (“If the current was raised above 1.8 kA or the
`pulse duration was increase to 2 – 10 ms, an instability development and
`discharge contraction was observed.”).
`
`Background:
`Manos at 231 (“We shall … [include] information on unipolar arcs.
`These are a problem…”)
`
`Manos at 237 (“When such an arc occurs, the metal object is melted at
`the arc spot. The metal is explosively released…. How does one prevent
`such an arc? There are several methods…”)
`
`Mozgrin discloses a power supply that supplies power to the weakly-
`ionized plasma though an electrical pulse that is applied across the
`weakly-ionized plasma, the electrical pulse having at least one of a
`magnitude and a rise-time that is sufficient to transform the weakly-
`ionized plasma to a strongly-ionized plasma without developing an
`electrical breakdown condition in the chamber.
`
`‘716 Patent at claim 23 (“wherein the peak plasma density of the
`weakly-ionized plasma is less than about 1012 cm˗3”)
`
`‘716 Patent at claim 24 (“wherein the peak plasma density of the strongly-
`ionized plasma is greater than about 1012 cm˗3”)
`
`Mozgrin at Fig. 1
`
`b. a power supply
`that supplies
`power to the
`weakly-ionized
`plasma though an
`electrical pulse
`that is applied
`across the
`weakly-ionized
`plasma, the
`electrical pulse
`having at least
`one of a
`magnitude and a
`rise-time that is
`sufficient to
`transform the
`weakly-ionized
`plasma to a
`strongly-ionized
`plasma without
`developing an
`
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`

`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`Claims 1-5, 8-11,
`and 33
`
`electrical
`breakdown
`condition in the
`chamber.
`
`
`
`
`
`
`
`
`
`Mozgrin at Fig. 2
`
`Mozgrin at Fig. 3
`
`
`Mozgrin at 402, right col, ¶ 2 (“Part 1 in the voltage oscillogram
`
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`

`Claims 1-5, 8-11,
`and 33
`
`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`represents the voltage of the stationary discharge (pre-ionization stage).”)
`Mozgrin at 401, right col, ¶ 1 (“Thus, the supply unit was made providing
`square voltage and current pulses with [rise] times (leading edge) of 5 –
`60 µs…”).
`Mozgrin 403, right col, ¶4 (“Regime 2 was characterized by intense
`cathode sputtering…”) (emphasis added).
`Mozgrin at 409, left col, ¶ 4 (“The implementation of the high-current
`magnetron discharge (regime 2) in sputtering … plasma density
`(exceeding 2x1013 cm-3).”).
`Mozgrin at 409, left col, ¶5 (“The high-current diffuse discharge (regime
`3) is useful for producing large-volume uniform dense plasmas ni 
`1.5x1015cm-3…”)
`Mozgrin at 401, ¶ spanning left and right columns (“Designing the [pulsed
`supply] unit, we took into account the dependences which had been
`obtained in [Kudryavtsev] of ionization relaxation on pre-ionization
`parameters, pressure, and pulse voltage amplitude.”)
`Mozgrin at 400, left col, ¶ 3 (“Some experiments on magnetron systems
`of various geometry showed that discharge regimes which do not transit
`to arcs can be obtained even at high currents.”)
`Mozgrin at 400, right col, ¶ 1 (“A further increase in the discharge
`currents caused the discharges to transit to the arc regimes…”).
`Mozgrin at 401, right col, ¶2 (“For pre-ionization … the initial plasma
`density in the 109 – 1011 cm-3 range.”)
`Mozgrin at 404, left col, ¶ 3 (“The parameters of the shaped-electrode
`discharge…transit to arc regime 4, could be well determined… The point
`of the planar-magnetron discharge transit to the arc regime was
`determined by discharge voltage and structure changes...”).
`Mozgrin at 404, left col, ¶ 4 (“If the current was raised above 1.8 kA or
`the pulse duration was increase to 2 – 10 ms, an instability development
`and discharge contraction was observed.”).
`Mozgrin at Fig. 4
`
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`

`Claims 1-5, 8-11,
`and 33
`
`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`Mozgrin at Fig. 7
`
`
`
`2. The apparatus
`of claim 1
`wherein the
`pulsed power
`supply is a
`component in the
`ionization source.
`
`
`Mozgrin discloses the pulsed power supply is a component in the
`ionization source.
`
`See evidence cited in claim 1.
`
`Mozgrin at Fig. 2.
`
`Mozgrin at 401, left col, ¶5 (“Figure 2 presents a simplified scheme of the
`discharge supply system. The supply unit involved a pulsed discharge
`supply unit and a system for pre-ionization.”).
`
`3. The apparatus
`of claim 1
`wherein the
`ionization source
`
`Mozgrin discloses the ionization source is chosen from the group
`comprising an electrode coupled to a DC power supply, an electrode
`coupled to an AC power supply, a UV source, an X-ray source, an
`electron beam source, an ion beam source, an inductively coupled plasma
`
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`

`Claims 1-5, 8-11,
`and 33
`
`is chosen from
`the group
`comprising an
`electrode coupled
`to a DC power
`supply, an
`electrode coupled
`to an AC power
`supply, a UV
`source, an X-ray
`source, an
`electron beam
`source, an ion
`beam source, an
`inductively
`coupled plasma
`source, a
`capacitively
`coupled plasma
`source, and a
`microwave
`plasma source.
`
`4. The apparatus
`of claim 1
`wherein the
`power supply
`generates a
`constant power.
`
`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`source, a capacitively coupled plasma source, and a microwave plasma
`source.
`
`See evidence cited in claim 1.
`
`Mozgrin at Figs. 1-2.
`
`Mozgrin at 401, left col, ¶ 5 (“…The pre-ionization system provided
`direct current up to 0.3A and voltage up to 3 kV.”) (emphasis added).
`
`Mozgrin discloses wherein the power supply generates a constant power.
`
`See evidence cited in claim 1.
`
`’716 Patent, 12:55-56. (“Between time t1 and time t2, the voltage 326, the
`current 328, and the power 326 remain constant…”).
`
`Mozgrin at Fig. 3.
`
`Mozgrin, at 402, right col ¶2 (“Figure 3 shows typical voltage and current
`oscillograms of the quasi-stationary discharge.”).
`
`Mozgrin Fig. 3 shows constant power in region 3
`
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`

`Claims 1-5, 8-11,
`and 33
`
`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`
`Mozgrin discloses the power supply generates a constant voltage.
`
`See evidence cited in claim 1.
`
`Mozgrin at Fig. 3
`
`5. The apparatus
`of claim 1
`wherein the
`power supply
`generates a
`constant voltage.
`
`8. The apparatus
`of claim 1
`wherein the
`cathode is
`generally formed
`in the shape of at
`least one circular
`disk.
`
`
`Mozgrin discloses the cathode is generally formed in the shape of at least
`one circular disk.
`
`See evidence cited in claim 1.
`
`Mozgrin at 400, right col, ¶ 5 (“The planar magnetron (Fig. 1) involved a
`plane cathode 120 mm in diameter….”) (emphasis added).
`
`Mozgrin at Figs. 1 and 6.
`
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`

`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`Mozgrin discloses the ionization source generates the weakly-ionized
`plasma from a reactive feed gas contained in a chamber.
`
`See evidence cited in claim 1.
`
`Mozgrin at 402, spanning left and right cols (“We studied the high-current
`discharge … using various gases (Ar, N2, SF6, He, and H2) ….”)
`(emphasis added).
`
`Mozgrin at 401, left col, ¶ 1 (“The cathodes we used were made of Cu,
`Mo, Ti, Al, or stainless steel.”) (emphasis added).
`
`Mozgrin discloses a magnet that is positioned to generate a magnetic field
`proximate to the weakly-ionized plasma, the magnetic field trapping
`electrons in the weakly-ionized plasma.
`
`See evidence cited in claim 1.
`
`‘716 Patent at 1:39-42 [in the Background of the Invention] (“Magnetron
`sputtering systems use magnetic fields that are shaped to trap and
`concentrate secondary electrons….”).
`
`‘716 Patent at 3:13-15 [describing the prior art Fig. 1] (“This has led to
`the use of a DC magnetic field near the cathode 114 to confine the
`secondary electrons.”)
`
`Mozgrin at Fig. 1.
`
`Mozgrin at 401, left col, ¶ 1 (“The electrodes were immersed in a
`magnetic field of annular permanent magnets.”).
`
`Mozgrin at 401, left col, ¶ 1 (“The [plasma] discharge had an annular
`shape and was adjacent to the cathode.”)
`
`Mozgrin at 401, right col, ¶2 (“We found out that only the regimes with
`magnetic field strength not lower than 400 G provided the initial plasma
`density in the 109-1011 cm-3 range.”).
`
`Mozgrin at 407, left col, ¶ 3 (“The action of the magnetic field serves only
`to limit the electron thermal conductivity and to provide collisions
`sufficient for efficient energy transfer from electrons to heavy particles.”)
`
`Mozgrin discloses the magnet generates a magnetic field that is shaped to
`trap secondary electrons that are produced by ion bombardment.
`
`- 9 -
`
`Claims 1-5, 8-11,
`and 33
`
`9. The apparatus
`of claim 1
`wherein the
`ionization source
`generates the
`weakly-ionized
`plasma from a
`reactive feed gas
`contained in a
`chamber.
`
`10. The apparatus
`of claim 1 further
`comprising a
`magnet that is
`positioned to
`generate a
`magnetic field
`proximate to the
`weakly-ionized
`plasma, the
`magnetic field
`trapping electrons
`in the weakly-
`ionized plasma.
`
`11. The apparatus
`of claim 10
`wherein the
`
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`

`

`Claims 1-5, 8-11,
`and 33
`
`magnet generates
`a magnetic field
`that is shaped to
`trap secondary
`electrons that are
`produced by ion
`bombardment.
`
`33. An apparatus
`for generating a
`strongly-ionized
`plasma, the
`apparatus
`comprising:
`
`a. means for
`ionizing a feed
`gas in a chamber
`to form a weakly-
`ionized plasma
`that substantially
`eliminates the
`probability of
`developing an
`electrical
`breakdown
`condition in the
`chamber; and
`
`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`See evidence cited in claim 10.
`
` ‘716 Patent at 1:37-39 [in the Background of the Invention] (“The plasma
`is replenished by electron-ion pairs formed by the collision of neutral
`molecules with secondary electrons generated at the target surface.”)
`
`Mozgrin at Fig. 1.
`
`Mozgrin 403, right col, ¶4 (“Regime 2 was characterized by intense
`cathode sputtering due to both high energy and density of ion flow.”).
`
`Mozgrin at 407, left col, ¶ 3 (“The action of the magnetic field serves only
`to limit the electron thermal conductivity and to provide collisions
`sufficient for efficient energy transfer from electrons to heavy particles.”).
`
`Background:
`
`Ohring at 104 (“Microscopically, positive gas ions in the discharge strike
`the cathode plate and eject neutral target atoms…. In addition, other
`particles (secondary electrons, desorbed gases, and negative ions) … are
`emitted from the target.”)
`
`Mozgrin discloses an apparatus for generating a strongly-ionized plasma.
`
`See evidence cited in claim 1 preamble.
`
`Mozgrin discloses means for ionizing a feed gas in a chamber to form a
`weakly-ionized plasma that substantially eliminates the probability of
`developing an electrical breakdown condition in the chamber.
`
`Claimed function
`
`Claim 33 recites “means for ionizing a feed gas in a chamber to form a
`weakly-ionized plasma that substantially eliminates the probability of
`developing an electrical breakdown condition in the chamber.”
`
`Mozgrin discloses the function corresponding to “means for ionizing…”
`
`‘716 Patent at 5:14-15 (“The weakly-ionized plasma 232 is also
`referred to as a pre-ionized plasma.”)
`
`‘716 Patent at claim 23 (“wherein the peak plasma density of the
`
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`

`

`Claims 1-5, 8-11,
`and 33
`
`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`weakly-ionized plasma is less than about 1012 cm˗3”)
`
`Mozgrin at Figs. 1, 2, 3, 6, 7
`
`Mozgrin at 401, left col, ¶ 1 (“The [plasma] discharge had an
`annular shape and was adjacent to the cathode.”)
`
`Mozgrin at 401, left col, ¶ 4 (“[A]pplying a square voltage pulse to
`the discharge gap which was filled up with either neutral or pre-
`ionized gas.”)
`
`Mozgrin at 402, right col, ¶2 (“Figure 3 shows typical voltage and
`current oscillograms.…
` Part I in the voltage oscillogram
`represents the voltage of the stationary discharge (pre-ionization
`stage).”)
`
`Mozgrin at 401, right col, ¶2 (“[f]or pre-ionization, we used a
`stationary magnetron discharge; … provided the initial plasma
`density in the 109 – 1011 cm˗3 range.”)
`
`Mozgrin at 400, right col, ¶ 3 (“We investigated the discharge
`regimes in various gas mixtures at 10-3 – 10 torr…”)
`
`Mozgrin at 402, ¶ spanning left and right cols (“We studied the high-
`current discharge in wide ranges of discharge current…and operating
`pressure…using various gases (Ar, N2, SF6, and H2) or their mixtures of
`various composition…”)
`
`Corresponding Structure
`
`The ‘716 Patent discloses the following structure that corresponds to the
`means for ionizing:
`a power supply, generating the voltage, current and power values shown
`in Fig. 4 (e.g., between t1 – t2 and t6 – t7), electrically coupled to cathode
`(e.g., 204), anode (e.g., 216) and/or an electrode (e.g., 452, 452’), wherein
`the cathode, anode and/or electrode are arranged relative to a sputtering
`target as shown in Figs. 2A-2D and 6A-6D, and as described in the text of
`the ‘716 Patent at 5:1-32, 16:10-25, 17:24-61, 17:62-15, and 18:16-27.
`Mozgrin discloses the structure corresponding to the “means for
`ionizing…” limitation. For example:
`
`The combination of Mozgrin and Kudryavstev discloses the structure
`corresponding to the “means for ionizing…” limitation. For example:
`
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`

`

`Claims 1-5, 8-11,
`and 33
`
`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`Mozgrin at Figs. 1, 2, 3.
`
`
`Mozgrin at 401, right col, ¶2 (For pre-ionization, we used a stationary
`magnetron discharge … provided the initial plasma density in the 109 –
`1011 cm-3 range.)
`
`Mozgrin at 406, right col, ¶3 (“pre-ionization was not necessary; however,
`in this case, the probability of discharge transferring to arc mode
`increased.”)
`
`Mozgrin at 401, left col, ¶ 1 (“The [plasma] discharge had an annular
`shape and was adjacent to the cathode.”) (emphasis added)
`
`Any differences between Mozgrin’s and the ‘716 patent’s mechanical
`arrangement of the anode and cathode is nothing more than the
`mechanical rearrangement of well-known components. Rearranging
`Mozgrin’s components to match that of the ‘716 patent would be obvious
`to one of ordinary skill.
`
`Background:
`
`Manos at 231 (“arcs…are a problem…” )
`
`b. means for
`supplying an
`electrical pulse
`across the
`weakly-ionized
`plasma to
`transform the
`weakly-ionized
`plasma to a
`strongly-ionized
`plasma without
`developing an
`electrical
`breakdown
`condition in the
`
`Mozgrin discloses means for supplying an electrical pulse across the
`weakly-ionized plasma to transform the weakly-ionized plasma to a
`strongly-ionized plasma without developing an electrical breakdown
`condition in the chamber.
`
`Claimed function
`
`Claim 33 recites “means for supplying an electrical pulse across the
`weakly-ionized plasma to transform the weakly-ionized plasma to a
`strongly-ionized plasma without developing an electrical breakdown
`condition in the chamber.”
`
`Mozgrin discloses the function corresponding to “means for
`supplying…”
`
` ‘716 Patent at claim 23 (“wherein the peak plasma density of the
`
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`

`

`Claims 1-5, 8-11,
`and 33
`
`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`chamber.
`
`weakly-ionized plasma is less than about 1012 cm˗3”)
`
`‘716 Patent at claim 24 (“wherein the peak plasma density of the strongly-
`ionized plasma is greater than about 1012 cm˗3”)
`
`Mozgrin at Fig. 1
`
`
`
`
`
`
`
`
`
`Mozgrin at Fig. 2
`
`Mozgrin at Fig. 3
`
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`

`

`Claims 1-5, 8-11,
`and 33
`
`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`
`Mozgrin at 402, right col, ¶ 2 (“Part 1 in the voltage oscillogram
`represents the voltage of the stationary discharge (pre-ionization stage).”)
`Mozgrin at 401, right col, ¶ 1 (“Thus, the supply unit was made providing
`square voltage and current pulses with [rise] times (leading edge) of 5 –
`60 µs…”).
`Mozgrin 403, right col, ¶4 (“Regime 2 was characterized by intense
`cathode sputtering…”) (emphasis added).
`Mozgrin at 409, left col, ¶ 4 (“The implementation of the high-current
`magnetron discharge (regime 2) in sputtering … plasma density
`(exceeding 2x1013 cm-3).”).
`Mozgrin at 409, left col, ¶5 (“The high-current diffuse discharge (regime
`3) is useful for producing large-volume uniform dense plasmas ni 
`1.5x1015cm-3…”)
`Mozgrin at 401, ¶ spanning left and right columns (“Designing the [pulsed
`supply] unit, we took into account the dependences which had been
`obtained in [Kudryavtsev] of ionization relaxation on pre-ionization
`parameters, pressure, and pulse voltage amplitude.”)
`Mozgrin at 400, left col, ¶ 3 (“Some experiments on magnetron systems
`of various geometry showed that discharge regimes which do not transit
`to arcs can be obtained even at high currents.”)
`Mozgrin at 400, right col, ¶ 1 (“A further increase in the discharge
`currents caused the discharges to transit to the arc regimes…”).
`
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`
`

`

`Claims 1-5, 8-11,
`and 33
`
`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`Mozgrin at 401, right col, ¶2 (“For pre-ionization … the initial plasma
`density in the 109 – 1011 cm-3 range.”)
`Mozgrin at 404, left col, ¶ 3 (“The parameters of the shaped-electrode
`discharge…transit to arc regime 4, could be well determined… The point
`of the planar-magnetron discharge transit to the arc regime was
`determined by discharge voltage and structure changes...”).
`Mozgrin at 404, left col, ¶ 4 (“If the current was raised above 1.8 kA or
`the pulse duration was increase to 2 – 10 ms, an instability development
`and discharge contraction was observed.”).
`Mozgrin at Fig. 4
`
`Mozgrin at Fig. 7
`
`Corresponding Structure
`
`ActiveUS 122367643v.1
`
`- 15 -
`
`
`
`
`
`

`

`Claims 1-5, 8-11,
`and 33
`
`EXHIBIT B.01
`U.S. Patent No. 7,604,716
`
`Mozgrin
`
`The ‘716 Patent discloses the following structure that corresponds to the
`“means for applying…”:
`
`pulsed power supply (e.g., 202), generating the voltage, current and power
`values shown in Fig. 4 (e.g., between t2 – t4), electrically coupled to a
`cathode (e.g., 204) and anode (e.g., 216), wherein the cathode and anode
`are arranged relative to a sputtering target as shown in Figs. 2A-2D and
`6A-6D, and as described in the text of the ‘716 Patent at 6:53-7:24, 8:9-
`19, 11:59-12:6, 13:14-44, 13:52-60, 16:64-17:18, 18:50-61, and 19:1-11
`
`Mozgrin discloses the structure corresponding to the “means for
`supplying…” limitation. For example:
`
`Mozgrin at Figs. 1, 2, 3
`
`Any difference between Mozgrin’s and the ‘716 Patent’s mechanical
`arrangement of the anode and cathode is nothing more than the
`mechanical rearrangement of well-known components. Rearranging
`Mozgrin’s components to match that of the ‘716 Patent would be obvious
`to one of ordinary skill.
`
`
`
`ActiveUS 122367643v.1
`
`- 16 -
`
`

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