UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2014-00828, 829, 1073, 917, and 1076
`Patent 6,805,779
`
`PATENT OWNER ZOND LLC’S
`DEMONSTRATIVE EXHIBIT
`
`1
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2014-00828, 829, 1073, 917, and 1076
`Patent 6,805,779
`
`PATENT OWNER ZOND LLC’S
`DEMONSTRATIVE EXHIBIT
`
`1
`
`
`
`SUMMARY OF ARGUMENT
`
`Listing Of Claim
`Limitations That Are
`Not Taught or Disclosed
`By the Prior Art
`
`2
`
`
`
`OBVIOUSNESS
`Claims 1-42, 44, and 45 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
` Iwamura, Angelbeck, and Pinsley do not teach:
`“generating a magnetic field proximate to a volume of ground state
`atoms to substantially trap electrons proximate to the volume of ground
`state atoms” as recited in independent claim 30, and as similarly recited
`in independent claim 40,
`“generating a volume of metastable atoms from the volume of ground
`state atoms,” As Recited In Claim 30, And As Similarly Recited in Claim 40,
`“raising an energy of the metastable atoms so that at least a portion of
`the volume of metastable atoms is ionized,” As Recited In Claim 30, and
`as similarly recited in claim 40,
`“generating the volume of metastable atoms comprises generating a
`discharge that excites at least a portion of the ground state atoms in the
`volume of ground state atoms to a metastable state,” As Recited In Claim
`32,
`“generating the magnetic field proximate to the volume of ground state
`atoms increases excitation of at least a portion of the ground state atoms
`in the volume of ground state atoms to a metastable state,” as recited in
`claim 33,
`
`3
`
`
`
`OBVIOUSNESS
`Claims 1-42, 44, and 45 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
` Iwamura, Angelbeck, and Pinsley do not teach:
`“the raising the energy of the metastable atoms comprises exposing the
`metastable atoms to an electric field,” as recited in claim 35, and as similarly
`recited in claim 37,
`“generating the volume of metastable atoms comprises generating an electron
`beam that excites at least a portion of the ground state atoms in the volume of
`ground state atoms to a metastable state,” As Recited In Dependent Claim 34,
`And As Similarly Recited In Dependent Claim 39,
`“an excited atom source that receives ground state atoms from the feed gas
`source … the excited atom source generating excited atoms from the ground
`state atoms” As Recited in Claim 1 And As Similarly Recited In Independent Claim
`18,
`“the excited atom source comprising a magnet that generates a magnetic field for
`substantially trapping electrons proximate to the ground state atoms” as recited
`in independent claim 1 and as similarly recited in independent claim 18
`“a plasma chamber that is coupled to the excited atom source,” as recited in
`independent claim 1 and as similarly recited in independent claim 18,
`“the plasma chamber confining a volume of excited atoms generated by the
`excited atom source” as recited in independent claim 1 and as similarly recited in
`independent claim 18,
`
`4
`
`
`
`OBVIOUSNESS
`Claims 1-42, 44 And 45 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
` Iwamura, Angelbeck, and Pinsley do not teach:
`“an energy source that is coupled to the volume of excited atoms
`confined by the plasma chamber” as recited in independent claim 1 and
`as similarly recited in independent claim 18,
`“the energy source raising an energy of excited atoms in the volume of
`excited atoms so that at least a portion of the excited atoms in the
`volume of excited atoms is ionized,” as recited in independent claim 1
`and as similarly recited in independent claim 18,
`“an electron/ion absorber that receives the excited atoms from the
`excited atom source, the electron/ion absorber trapping electrons and
`ions,” as recited in dependent claim 16, and as similarly recited in
`dependent claims 28 and 42, “means for generating a volume of
`metastable atoms from the volume of ground state atoms,” As Recited In
`Independent Claim 41, And As Similarly Recited in Claim 46,
`“means for generating a magnetic field proximate to a volume of ground
`state atoms to substantially trap electrons proximate to the volume of
`ground state atoms,” as recited in independent claim 41 and as similarly
`recited in independent claim 46,
`
`5
`
`
`
`OBVIOUSNESS
`Claims 1-42, 44, And 45 Are Not Obvious Over
`Iwamura, Angelbeck, and Pinsley
` Iwamura, Angelbeck, and Pinsley do not teach:
`“means for raising an energy of the metastable atoms so that at least a
`portion of the volume of metastable atoms is ionized,” as recited in
`independent claim 41 and as similarly recited in independent claim 46,
`“an excited atom source that is coupled to the feed gas source, the
`excited atom source generating excited atoms from the ground state
`atoms,” As Recited In Independent Claim 45,
`“an electron/ion absorber that receives the excited atoms generated by
`the excited atom source and then traps electrons and ions,” as recited in
`independent claim 45,
`“a plasma chamber that is coupled to the electron/ion absorber, the
`plasma chamber confining a volume of excited atoms generated by the
`excited atom source,” as recited in independent claim 45,
`“an energy source that is coupled to the volume of excited atoms
`confined by the plasma chamber,” as recited in independent claim 45,
`“the energy source raising an energy of excited atoms in the volume of
`excited atoms so that at least a portion of the excited atoms in the
`volume of excited atoms is ionized,” as recited in independent claim 45.
`
`6
`
`
`
`OBVIOUSNESS
`Claims 1-42, 44, and 45 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
` Iwamura, Angelbeck, and Pinsley do not teach:
`“the excited atom source is positioned inside the plasma
`chamber,” as recited in dependent claim 10 and as similarly recited
`in dependent claim 24,
`“the excited atom source is positioned outside the plasma
`chamber,” As Recited In Dependent Claim 11 And As Similarly
`Recited In Dependent Claim 25,
`“wherein the energy source is chosen from the group comprising
`… an AC discharge source,” As Recited In Dependent Claim 13,
`“wherein the energy source comprises a power supply,” As Recited
`In Dependent Claim 14, Or
`“wherein the power supply is chose from the group comprising …
`an AC power supply…,” As Recited In Dependent Claims 15 and 27
`“trapping electrons and ions in the volume of metastable atoms,”
`as recited in dependent claim 38
`
`7
`
`
`
`OBVIOUSNESS
`Claims 7, 9, 20, 21, And 44 Are Not Obvious Over
`Iwamura, Angelbeck, Pinsley And Wells or Gruber
` Iwamura, Angelbeck, Pinsley and Wells do not teach:
`that “the excited atom source comprises an electron gun that
`directs an electron beam into the ground state atoms, the
`electron beam exciting the ground state atoms,” As Recited
`In Dependent Claim 7, And As Similarly Recited In Dependent
`Claim 20,
` Iwamura, Angelbeck, Pinsley and Gruber do not teach:
`that “the excited atom source comprises an inductively
`coupled discharge source that generates a discharge that
`excites ground state atoms,” As Recited In Dependent Claim
`9, And As Similarly Recited In Dependent Claim 21,
`“an inductively coupled discharge source that is coupled to
`the feed gas source, the inductively coupled discharge source
`generating excited atoms from the ground state atoms,” As
`Recited In Independent Claim 44,
`
`8
`
`
`
`OBVIOUSNESS
`Claim 44 Is Not Obvious Over Iwamura, Angelbeck,
`Pinsley, And Gruber
` Iwamura, Angelbeck, Pinsley and Gruber do not teach:
`“a plasma chamber that is coupled to the inductively coupled
`discharge source, the plasma chamber confining a volume of
`excited atoms generated by the excited atom source” as
`recited in independent claim 44,
`“an energy source that is coupled to the volume of excited
`atoms confined by the plasma chamber” as recited in
`independent claim 44,
`“the energy source raising an energy of excited atoms in the
`volume of excited atoms so that at least a portion of the
`excited atoms in the volume of excited atoms is ionized,” as
`recited in independent claim 44,
`
`9
`
`
`
`OBVIOUSNESS
`Claims 1-42, 44, and 45 Are Not Obvious Over Iwamura,
`Angelbeck, And Pinsley
` Iwamura, Angelbeck, and Pinsley do not teach:
`“the excited atom source comprises a first electrode and a second
`electrode, the first electrode and the second electrode generating a
`discharge that excites the ground state atoms,” As Recited In Claim 5,
`“the metastable atom source comprises a first electrode and a second
`electrode, the first electrode and the second electrode generating a
`discharge that excites the ground state atoms to a metastable state,” As
`Recited In Claim 19,
`“the magnetic field that substantially traps electrons proximate to the
`ground state atoms increases at least one of a rate at which the excited
`atoms are generated from the ground state atoms and a density of
`excited atoms” as recited in dependent claim 6 and as similarly recited in
`dependent claim 22;
`“a pressure differential exists between a pressure in the excited atom
`source and a pressure in the plasma chamber, the pressure differential
`increasing at least one of a rate at which the excited atoms are generated
`from the ground state atoms and a density of the excited atoms,” As
`Recited In Dependent Claim 8, And As Similarly Recited In Dependent
`Claim 23
`
`10
`
`
`
`ANTICIPATION
`Claim 43 Is Not Anticipated By Iwamura
`
` Iwamura does not disclose:
`“an excited atom source generating excited atoms from the ground
`state atoms,”
`“a plasma chamber that is coupled to the excited atom source,”
`“the plasma chamber confining a volume of excited atoms
`generated by the excited atom source”
`“a pressure differential exists between a pressure in the excited
`atom source and a pressure in the plasma chamber, the pressure
`differential increasing at least one of a rate at which the excited
`atoms are generated from the ground state atoms and a density
`of the excited atoms,”
`“an energy source that is coupled to the volume of excited atoms
`confined by the plasma chamber,” or
`“the energy source raising an energy of excited atoms in the
`volume of excited atoms so that at least a portion of the excited
`atoms in the volume of excited atoms is ionized.”
`
`11
`
`
`
`ANTICIPATION
`Claim 46 Is Not Anticipated By Iwamura
`
`Iwamura does not disclose:
`“generating a volume of metastable
`atoms from the volume of ground state
`atoms,”
`“trapping electrons and ions in the
`volume of metastable atoms,” or
`“raising an energy of the metastable
`atoms so that at least a portion of the
`volume of metastable atoms is ionized.”
`
`12
`
`
`
`ARGUMENT
`
`Explanation Of Why
`The Claim Limitations
`Are Not Taught or
`Disclosed By the Prior
`Art
`
`13
`
`
`
`OBVIOUSNESS
`Claims 1-42, 44, and 45 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
`Iwamura, Angelbeck and Pinsley would
`not have taught:
`“generating a magnetic field proximate
`to a volume of ground state atoms to
`substantially trap electrons proximate to
`the volume of ground state atoms” as
`recited in independent claim 30, and as
`similarly recited in independent claims 1,
`18, and 40.
`
`14
`
`
`
`OBVIOUSNESS
`Claims 1-42, 44, and 45 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
` Angelbeck instead teaches:
`
`producing a plasma: “[t]he current-excited discharge passed through the
`gas within tube 10 creates a plasma in which the atoms are ionized and
`electrons are freed.” (Angelbeck, col. 2, ll. 55-57).
`
`“[t]he transverse magnetic field increases the loss of electrons to the
`tube walls which results in an increase of the axial electric field in order
`to maintain a power balance in the discharge.” (col. 2, ll. 57-60).
`
`“[t]he configuration of Angelbeck’s anode and cathode and, hence, the
`electric field there between, relative to the transverse magnetic field will
`actually result in force directed across the flow of electrons from cathode
`to anode and to the tube walls, where they are removed from the
`plasma.” (Dr. Hartsough’s Declaration, ¶ 193).
`
`15
`
`
`
`OBVIOUSNESS
`Claims 1-42, 44, and 45 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
` Pinsley instead teaches:
`“the orientation of the anode and cathode
`relative to the magnets is rotated 90° when
`compared to the configuration taught by
`Angelbeck in Fig. 1. This naturally and
`unambiguously results in a 90° rotation of the
`‘force vector 32’ cited by Petitioners. The result
`is exactly as described by Angelbeck in that the
`transverse magnetic field ‘increases the loss of
`electrons to the tube walls,’” (Dr. Hartsough’s
`Declaration, ¶ 193).
`
`16
`
`
`
`OBVIOUSNESS
`Claims 1-42, 44, and 45 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
` Iwamura, Angelbeck and Pinsley would not have taught:
`“an excited atom source that receives ground state atoms from the
`feed gas source … the excited atom source generating excited
`atoms from the ground state atoms,” as recited in claim 1
`“a metastable atom source that receives ground state atoms from
`the feed gas source … the metastable atom source generating
`metastable atoms from the ground state atoms” as recited in claim
`18, and as similarly recited in claim 30
`“generating a volume of metastable molecules from the volume of
`ground state molecules,” as recited in independent claims 40.
`“The term ‘metastable atoms’ is defined herein to mean excited
`atoms having energy levels from which dipole radiation is
`theoretically forbidden. Metastable atoms have relatively long
`lifetimes compared with other excited atoms.”
`
`17
`
`
`
`OBVIOUSNESS
`Claims 1-42, 44, and 45 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
`
` Petitioners argued:
`
`that the first plasma generation unit or the combination of the preexcitation unit with the first
`plasma generation unit [of Iwamura] can generate excited atoms from the ground state atoms
`received from the feed gas source. (Petition, pp. 49-50).
`
` But Iwamura instead discloses that the plasma generation unit generates plasma, not metastable
`atoms as claimed:
`
`“[a] plurality of plasma generation units for activating the gas to generate a plasma are provided
`at different locations along the flow path of the gas through the gas supply.” (col. 2, ll. 7-10).
`
`Petitioners’ arguments for claims 18, 30, and 40 have “no merit because it refers to the
`generation of excited atoms and the claim recites the generation of metastable atoms.” (Dr.
`Hartsough’s Declaration, ¶ 196).
`
`Iwamura’s first plasma generation unit generates a plasma or “activated gas” per Iwamura’s
`teaching, just as the description of the Iwamura’s unit implies (i.e., a first plasma generation
`unit).” (Dr. Hartsough’s Declaration, ¶ 196).
`
`18
`
`
`
`OBVIOUSNESS
`Claims 30-40 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
`Iwamura, Angelbeck and Pinsley
`would not have taught:
`“raising an energy of the metastable
`atoms so that at least a portion of
`the volume of metastable atoms is
`ionized,” As Recited In Claim 30, and
`as similarly recited in claim 40.
`
`19
`
`
`
`OBVIOUSNESS
`Claims 30-40 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
` Petitioners argued:
`
`“[t]he power supply coupled to the electrodes of Iwamura’s plasma
`chamber provides energy to the metastable atoms within the
`chamber (Petition, p. 51).
`
` But Iwamura instead teaches that the gas that enters the chamber is a
`plasma and that the energy of the activated atoms in the plasma, not
`the metastable atoms or molecules required by claims 30 and 40
`respectively, is increased: :
`
`“it is possible to increase the density of activated gas species and
`their excitation levels using the gas activated upstream…” (col. 9, ll. 9-
`11).
`
`20
`
`
`
`OBVIOUSNESS
`Claim 32 Is Not Obvious Over Iwamura, Angelbeck, and
`Pinsley
`Iwamura, Angelbeck and Pinsley
`would not have taught:
`“generating the volume of
`metastable atoms comprises
`generating a discharge that excites at
`least a portion of the ground state
`atoms in the volume of ground state
`atoms to a metastable state,” As
`Recited In Claim 32.
`
`21
`
`
`
`OBVIOUSNESS
`Claim 32 Is Not Obvious Over Iwamura, Angelbeck, and
`Pinsley
`
` Petitioners argued:
`
`“’the first plasma generation unit may include a first pair of electrodes
`and a first alternating current power source connected across the first
`pair of electrodes.’” (Petition, p. 54, quoting Iwamura at 2:66 – 3:2).
`
` But the first plasma generation unit generates plasma, not metastable
`atoms:
`
`“[t]he inert gas, with a raised excitation level, is activated in a plasma
`region A between first pair of plasma generation electrodes 26, and a
`plasma is thus generated.” (col. 7, ll. 61-63).
`
`“In a plasma region B between second pair of plasma generation
`electrodes 30, the activated helium gas is further activated, generating a
`plasma at or about atmospheric pressure.” (col. 8, ll. 4-7).
`
`22
`
`
`
`OBVIOUSNESS
`Claim 33 Is Not Obvious Over Iwamura, Angelbeck, and
`Pinsley
`Iwamura, Angelbeck and Pinsley
`would not have taught that:
`“generating the magnetic field
`proximate to the volume of ground
`state atoms increases excitation of at
`least a portion of the ground state
`atoms in the volume of ground state
`atoms to a metastable state,” as
`recited in claim 33.
`
`23
`
`
`
`OBVIOUSNESS
`Claim 33 Is Not Obvious Over Iwamura, Angelbeck, and
`Pinsley
` Petitioners provided only about 1 page of argument for claim
`33 and did not explain where they would apply the magnetic
`field taught by Pinsley in Iwamura’s system (Petition, pp. 54-
`55).
`
` Also, the first plasma generation unit [of Iwamura] does not
`excite ground state atoms to a metastable state and instead,
`generates ionized atoms (i.e., a plasma or activated gas).
`
` And Angelbeck teaches deflecting the electrons toward the
`tube walls which, in a flowing feed gas, would have no
`trapping effect whatsoever on the electrons.” (Dr. Hartsough’s
`Declaration, ¶ 222.).
`
`24
`
`
`
`OBVIOUSNESS
`Claims 35 and 37 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
`Iwamura, Angelbeck and Pinsley
`would not have taught that:
`“raising the energy of the metastable
`atoms comprises exposing the
`metastable atoms to an electric
`field,” as recited in claim 35, and as
`similarly recited in claim 37.
`
`25
`
`
`
`OBVIOUSNESS
`Claims 35 and 37 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
` Petitioners argued that “[t]he power supply coupled to the electrodes of
`Iwamura’s plasma chamber provides energy to the metastable atoms
`within the chamber” (Petition, p. 56).
`
` But “the density of the activated gas species mentioned in Iwamura refers
`to the density of the plasma, not to raising the energy of the metastable
`atoms as required by claims 35 and 37. In addition, the electrodes of
`Iwamura referenced by the Petitioners do not, in fact, ‘receive metastable
`atoms,’ … Rather, these electrodes receive activated atoms, i.e., a plasma”
`(Dr. Hartsough Declaration, ¶ 225).
`
` Iwamura clearly states that the upper electrode 30a and lower electrode
`30b, receive activated atoms (i.e., the plasma generated between the first
`pair of electrodes):
`“[t]he inert gas, with a raised excitation level, is activated in plasma
`region A between first pair of plasma generation electrodes 26, and a
`plasma is thus generated.” (Iwamura, col. 7, ll. 61-63).
`
`26
`
`
`
`OBVIOUSNESS
`Claims 34 and 39 Are Not Obvious Over Iwamura,
`Angelbeck, Pinsley and Wells
`Iwamura, Angelbeck and Pinsley would
`not have taught:
`“generating the volume of metastable
`atoms comprises generating an electron
`beam that excites at least a portion of
`the ground state atoms in the volume of
`ground state atoms to a metastable
`state,” As Recited In Dependent Claim
`34, And As Similarly Recited In
`Dependent Claim 39
`
`27
`
`
`
`OBVIOUSNESS
`Claims 34 and 39 Are Not Obvious Over Iwamura,
`Angelbeck, Pinsley, and Wells
` Wells instead teaches a gas laser that requires a mixture of two gases:
`“The invention comprises a novel way to provide inversions, in that
`energy can be stored in one atom species in the upper laser levels,
`whereas the lower levels of the other atom or molecule of the collision
`pair can be depopulated as by a rapid decay mechanism.” (Wells, col 1, ll.
`25-29).
`
` Petitioners failed to explain:
`“why a POSA would be motivated to modify the plasma treatment
`apparatus of Iwamura or how such modifications could be
`accommodated. Specifically, Petitioners failed to explain why or how
`Wells’ two gas mixture in which one atom species stores energy in an
`upper level and the other atom or molecule collides and is depopulated
`can be adapted to Iwamura’s system” (Dr. Hartsough’s Declaration, ¶
`232.)
`“why or how Wells’ photon source, which is a necessary and required
`feature to produce the claimed invention, may be adapted to Iwamura’s
`system.” (Dr. Hartsough’s Declaration, ¶ 232.)
`
`28
`
`
`
`OBVIOUSNESS
`Claims 1-29 and 45 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
`Iwamura, Angelbeck and Pinsley would not
`have taught:
`“a plasma chamber that is coupled to the
`excited atom source” As Recited In
`Independent Claim 1 and As Similarly
`Recited In Independent Claim 18, or
`“an excited atom source that is coupled to
`the feed gas source, the excited atom source
`generating excited atoms from the ground
`state atoms,” as Recited in Independent
`claim 45
`
`29
`
`
`
`OBVIOUSNESS
`Claims 1-29 Are Not Obvious Over Iwamura, Angelbeck,
`and Pinsley,
`
` Petitioner argued:
`Iwamura’s pre-excitation unit and the first plasma generation unit
`meet the excited or metastable atom source, are positioned upstream
`from, and coupled, to the plasma treatment chamber (Petition, pp.
`55-56).
` But the first plasma generation unit generates a plasma, not excited or
`metastable atoms (Dr. Hartsough’s Declaration, ¶¶ 64-65.)
` Petitioner’s expert was unable to identify the location on Iwamura’s
`figure at which its plasma chamber is coupled to a metastable or
`excited atom source:
`Q. Are you refusing to mark the Figure 1 where you believe, in your
`opinion, the plasma chamber is coupled to the metastable atom
`source?
`
`… T
`
`HE WITNESS: Yes, at this point I do not feel comfortable doing this
`(Kortshagen Deposition (1.16.15), p. 174, l. 24 – p. 175, l. 7).
`
`30
`
`
`
`OBVIOUSNESS
`Claims 1-29, and 45 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
` Iwamura, Angelbeck and Pinsley would not have taught:
`“the plasma chamber confining a volume of excited
`atoms generated by the excited atom source” As Recited
`In Independent Claim 1 and As Similarly Recited In
`Independent Claims 18 and 45
` Petitioners argued that Iwamura’s plasma confines the
`volume of excited atoms generated upstream at the
`preexcitation unit and the first plasma generation unit
`(Petition pp. 55-56).
` But plasma, not the excited or metastable atoms enter
`the plasma chamber of Iwamura (Dr. Hartsough’s
`Declaration, ¶¶ 64-65.)
`
`31
`
`
`
`OBVIOUSNESS
`Claims 1-29 And 45 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
` Iwamura, Angelbeck and Pinsley would not have taught:
`“an energy source that is coupled to the volume of
`excited atoms confined by the plasma chamber” As
`Recited In Independent Claim 1 and As Similarly Recited
`In Independent Claims 18 and 45
` Petitioners argued that the second pair of electrodes in
`the chamber 10 is the claimed energy source (Petition
`pp. 56-57).
` But “the first pair of electrodes 26 generates a plasma
`and that plasma and not the excited or metastable atoms
`enters the chamber 10” (Dr. Hartsough’s Declaration, ¶
`70.)
`
`32
`
`
`
`OBVIOUSNESS
`Claims 1-29 And 45 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
` Iwamura, Angelbeck and Pinsley would not have taught:
`“the energy source raising an energy of excited atoms in the
`volume of excited atoms so that at least a portion of the exited
`atoms in the volume of excited atoms is ionized” As Recited In
`Independent Claim 1 and As Similarly Recited In Independent
`Claims 18 and 45
` Petitioners argued that a power supply coupled to the
`electrodes of Iwamura’s plasma chamber provides energy to the
`excited or metastable atoms within the chamber (Petition, pp.
`56-57).
` But “the atoms entering Iwamura’s chamber are not excited or
`metastable, but rather activated (i.e., ionized to a plasma)… the
`electrodes in Iwamura’s plasma chamber cannot possibly be
`considered to ionized excited or metastable atoms because the
`atoms are already ionized before they enter the chamber” (Dr.
`Hartsough’s Declaration, ¶ 72.)
`
`33
`
`
`
`OBVIOUSNESS
`Claims 16, 28 and 42 Are Not Obvious Over Iwamura,
`Angelbeck, and Pinsley
`Iwamura, Angelbeck and Pinsley would not have
`taught:
`“an electron/ion absorber that receives the
`excited atoms from the excited atom source, the
`electron/ion absorber trapping electrons and
`ions,” As Recited In Claim 16, And As Similarly
`Recited In Claims 28, 42 and 45
`Petitioners argued that Iwamura’s electrode 80
`teaches this claim limitation (Petition, pp. 58-59).
`But Iwamura teaches ion capture only from the
`plasma and not from the excited or metastable
`atoms (Dr. Hartsough’s Declaration, ¶ 153.)
`
`34
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2014-00828, 829, 1073, 917, and 1076
`Patent 6,805,779
`
`END
`
`35
`
`
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