UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________________________
`
`GLOBALFOUNDRIES U.S., INC., GLOBALFOUNDRIES DRESDEN
`MODULE ONE LLC & CO. KG, GLOBALFOUNDRIES DRESDEN
`MODULE TWO LLC & CO. KG, and
`THE GILLETTE COMPANY,
`Petitioners,
`
`
`
`v.
`
`Zond, LLC.
`U.S. Patent No. 7,147,7591
`IPR Case No. IPR2014-01086
`
`
`
`PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION FOR
`OBSERVATION ON CROSS-EXAMINATION OF
`PETITIONER’S REPLY WITNESS
`
`
`1 Case No. IPR2014-00981 has been joined with this proceeding.
`
`
`
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________________________
`
`GLOBALFOUNDRIES U.S., INC., GLOBALFOUNDRIES DRESDEN
`MODULE ONE LLC & CO. KG, GLOBALFOUNDRIES DRESDEN
`MODULE TWO LLC & CO. KG, and
`THE GILLETTE COMPANY,
`Petitioners,
`
`
`
`v.
`
`Zond, LLC.
`U.S. Patent No. 7,147,7591
`IPR Case No. IPR2014-01086
`
`
`
`PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION FOR
`OBSERVATION ON CROSS-EXAMINATION OF
`PETITIONER’S REPLY WITNESS
`
`
`1 Case No. IPR2014-00981 has been joined with this proceeding.
`
`
`
`
`I.
`
`II.
`
`
`
`
`
`
`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
`
`
`
`TABLE OF CONTENTS
`
`
`INTRODUCTION ........................................................................................... 1
`
`RESPONSES TO OBSERVATIONS ON DR. OVERZET’S
`TESTIMONY .................................................................................................. 1
`
`A.
`
`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`G.
`
`H.
`
`I.
`
`Response to Observation 1 .................................................................... 1
`
`Response to Observation 2 .................................................................... 3
`
`Response to Observation 3 .................................................................... 4
`
`Response to Observation 4 .................................................................... 5
`
`Response to Observation 5 .................................................................... 6
`
`Response to Observation 6 .................................................................... 9
`
`Response to Observation 7 .................................................................. 10
`
`Response to Observation 8 .................................................................. 11
`
`Response to Observation 9 .................................................................. 13
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`
`
`i
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
`
`
`INTRODUCTION
`
`I.
`
`Petitioner submits this response to Patent Owner Zond’s Observations on
`
`Cross-Examination of Dr. Overzet, Paper No. 30 (“Observation”). Patent Owner
`
`presents nine observations on Dr. Overzet’s testimony. While Petitioner believes
`
`that the testimony will be appropriately viewed and weighed by the Board, the
`
`specific observations presented by Patent Owner are irrelevant and mischaracterize
`
`the testimony of Dr. Overzet, as specified below, and therefore are not probative of
`
`any material issue before the Board.
`
`II. RESPONSES TO OBSERVATIONS ON DR. OVERZET’S
`TESTIMONY
`A. Response to Observation 1
`Patent Owner contends that Dr. Overzet’s testimony indicates that his field
`
`of expertise is inadequate to support Petitioner’s positions with respect to “gas
`
`laser references” such as Müller-Horsche. Observation at 2. Patent Owner
`
`misdirects the proper inquiry. Dr. Overzet’s testimony demonstrates his expertise
`
`in the relevant field of plasma generation.
`
`The testimony cited by Patent Owner merely indicates that Dr. Overzet is
`
`not an expert in all aspects of “gas laser design.” On the other hand, Dr. Overzet
`
`testified that “I am an expert in the generation of plasma; furthermore all of the
`
`articles that we've gone through with respect to the '759 patent involve the
`
`generation of plasma.” Overzet Dep. at 109:14-18 (Ex. 2012). In other words, Dr.
`1
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
`
`
`Overzet is an expert in the relevant field for the patent at issue and he applies his
`
`expert opinion when concluding that it would be obvious to substitute a well-
`
`known UV radiation source – such as that disclosed in Müller-Horsche – for the
`
`electrodes of Wang to perform Wang’s preionization step. See Overzet Dec. at ¶¶
`
`104-105 (Ex. 1036).
`
`Dr. Overzet testified that aspects of Müller-Horsche that do not relate to
`
`preionization are irrelevant to his opinion regarding the combination of Müller-
`
`Horsche’s UV source with Wang’s system:
`
`A. In a pulsed -- in a gas laser, in a pulsed gas laser, Müller-
`
`Horsche -- actually I believe this is also covered in my declaration. In
`
`paragraph 106, page 63 where I write, "To be clear, I have referred to
`
`Müller-Horsche with respect to preionization. Whether the main
`
`electrode at Müller-Horsche (which is not used for preionization) has
`
`advantages directed to erosion does not change the fact that it would
`
`be obvious to use a UV source for preionization."
`
`
`Overzet Dep. at 106:11-21. (Ex. 2012); Overzet Dec. at ¶106 (Ex. 1036).
`
`Dr. Overzet relies on aspects of Müller-Horsche that are directly in his field of
`
`expertise. As a result, it is irrelevant whether Dr. Overzet considers himself to be
`
`an expert in “gas laser design.”
`
`2
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`B. Response to Observation 2
`Patent Owner contends that Dr. Overzet’s testimony related to Kudryavtsev
`
`establishes that he does not understand Kudryavtsev because “Dr. Overzet stated
`
`that Kudryatsev did not disclose a gas laser even though Kudryavsev explicitly
`
`does so.” Observation at 2. Patent Owner mischaracterizes Dr. Overzet’s
`
`testimony, which demonstrates the opposite.
`
`In fact, Dr. Overzet specifically testified that Kudryavtsev mentions gas
`
`lasers, gas breakdown and laser sparks. Dr. Overzet further testified that
`
`Kudryavtsev’s model can be used to study emission mechanisms in those devices.
`
`Dr. Overzet never testified that Kudryavtsev fails to disclose gas lasers. Instead,
`
`he testified that Kudryavtsev does not expressly disclose the mechanisms of
`
`emission in those devices.
`
`Q. Earlier you answered a question in the negative, and I'll read
`
`you the question: "Is it your opinion that Kudryavtsev discloses
`
`emission mechanisms in pulsed gas lasers, gas breakdown and laser
`
`sparks." Do you recall answering that question?
`
`A. I do.
`
`Q. Can you explain your answer to that question, please?
`
`3
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`A. Kudryavtsev explains that his model can be used for
`
`studying emission mechanisms in those environments, but he does not
`
`disclose the various mechanisms of emission, save at most one.
`
`Overzet Dep. at 107:16 – 108:5 (Ex. 2012). As a result, Zond’s observation
`
`mischaracterizes Dr. Overzet’s testimony and is irrelevant to the instituted grounds
`
`for which Dr. Overzet has offered his expert opinion.
`
`C. Response to Observation 3
`Observation 3 merely repeats Observation 1 and reiterates Patent Owner’s
`
`contention the Dr. Overzet’s testimony cannot support Petitioner’s position with
`
`respect to Müller-Horsche.
`
`Again, Dr. Overzet explained that Müller-Horsche discloses a gas laser and
`
`clarified that his opinions rely on the plasma generation in Müller-Horsche, which
`
`“is very similar to Wang in that it teaches a two-step ionization process, and those
`
`two stages are determined by two sets -- two sets of electrodes.” Overzet Dep. at
`
`103:25 – 104:4 (Ex. 2012); Overzet Dec. at ¶¶ 104-105 (Ex. 1036). Thus, Dr.
`
`Overzet relies on aspects of Müller-Horsche that are directly in his field of
`
`expertise – plasma generation. As a result, the fact that Müller-Horsche discloses
`
`plasma generation in the context of a gas laser is irrelevant to the instant
`
`proceedings.
`
`4
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`D. Response to Observation 4
`Patent Owner claims that Dr. Overzet testified that Fig. 5 of Kudryavtsev
`
`only applies to devices having a radius which precludes predictable results when
`
`combined with Wang whose system does not have a radius. Observation at 4. Dr.
`
`Overzet’s testimony demonstrates that Patent Owner’s argument based on an
`
`isolated quotation is simply wrong.
`
` Right after the testimony that Patent Owner quotes in its observation, Dr.
`
`Overzet testified that Fig. 5 of Kudryavtsev applies to devices having a
`
`“normalized” radius. Overzet Dep. at 29:7-11 (Ex. 2012). Dr. Overzet then
`
`further explained that Kudryavtsev’s model has wide applicability to systems other
`
`than Kudryavtsev’s particular cylindrical apparatus, including those that do not
`
`have a radius:
`
`A. Since Kudryavtsev has a model that is widely applicable, he
`
`could, and one of ordinary skill in the art -- let me rephrase that. He
`
`could choose to apply his model in various volumes. His model would
`
`not simply be limited to things having a simple radius, cylindrical or
`
`spherical.
`
`Q. But my question was with respect to Figure 5.
`
`A. Figure 5 discloses one kind of an environment that has a
`
`radius.
`
`5
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`Q. So Figure 5 would be limited to only those types of shapes
`
`that have a radius; is that correct?
`
`MR. TENNANT: Objection, form. Asked and answered.
`
`A. My understanding is that Figure 5 would be most readily
`
`applied to that kind of a system, but still could have application
`
`outside.
`
`Overzet Dep. at 29:19 – 30:15 (Ex. 2012) (emphasis added).
`
`A. Figure 5 is a single example of utilizing Kudryavtsev and
`
`Skrebov's widely applicable model to understand a single
`
`circumstance and set of parameters.
`
`Overzet Dep. at 37:7 – 10 (Ex. 2012) (emphasis added). When Dr.
`
`Overzet’s testimony is considered in its full context, Patent Owner’s
`
`observation is incorrect and ultimately irrelevant to Dr. Overzet’s opinion –
`
`both expressed in his declaration and confirmed in his deposition – that a
`
`person of ordinary skill in the art would be motivated to combine
`
`Kudryavtsev’s teaching with Wang’s system.
`
`E. Response to Observation 5
`Observation 5 cites to selected portions of Dr. Overzet’s testimony relating
`
`to differences between Wang and Kudryavtsev. Based on that testimony, Patent
`
`Owner contends that “there is no objective evidence tending to establish that the
`
`6
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`teachings of the very different devices of Wang and Kudryavtsev would have led
`
`to predictable results.” Observation at 5. Patent Owner’s argument is misplaced
`
`because it mischaracterizes Dr. Overzet’s testimony about combining Wang and
`
`Kudryavtsev and is irrelevant to the grounds instituted in this proceeding.
`
`First, the testimony cited by Patent Owner refers only to isolated questions
`
`regarding the physical apparatus used by Kudryavtsev and Wang and ignores the
`
`fact that Dr. Overzet’s answers were not in the context of combining the two
`
`references. In fact, during his deposition, Dr. Overzet explained in detail how his
`
`declaration shows that a person of ordinary skill in the art would be motivated to
`
`apply the teachings of Kudryavtsev to the system of Wang:
`
`In short, Kudryavtsev is useful for describing how a voltage
`
`pulse such as Wang's voltage pulse operates and how to adjust
`
`voltage amplitude and duration in order to increase the ionization rate
`
`so that a rapid increase in electron density and the formation of a
`
`strongly-ionized plasma occurs for the benefit of improved sputtering
`
`and manufacturing processing capabilities.
`
`Beginning, again, in paragraph 57, bottom of page 29:
`
`"Moreover, a person of ordinary skill in the art would understand that
`
`Kudryavtsev intended that its derived model can be applied over a
`
`range of pressures as evidenced by Figure 3 of Kudryavtsev, which
`
`7
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
`
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`accurately models the duration of the slow growth stage tau sub s for
`
`argon discharges."
`
`Overzet Dep. at 39:4-21 (Ex. 2012). Patent Owner’s observation attempts to twist
`
`Dr. Overzet’s testimony regarding the physical apparatuses of Wang and
`
`Kudryavtsev by unilaterally concluding that a person of ordinary skill in the art
`
`would not combine the references despite the fact that Dr. Overzet never testified
`
`as such.
`
`
`
`Secondly, Patent Owner’s reliance on the physical differences between
`
`Wang and Kudryavtsev is irrelevant as the Board considered this argument when
`
`Patent Owner initially made it in its Preliminary Response and instituted inter
`
`partes review because “a determination of obviousness based on teachings from
`
`multiple references does not require an actual, physical substitution of elements.”
`
`IPR2014-01086 Institution Decision at 19 (Paper No. 11); see also IPR2014-01086
`
`Patent Owner Preliminary Response at 34-40 (Paper No. 8). Because of this, the
`
`instant proceeding is instituted on the ground that a person of ordinary skill in the
`
`art would combine the teaching of Kudryavtsev to Wang irrespective of any
`
`physical differences between the apparatuses disclosed in the references. Thus,
`
`Patent Owner’s observation regarding physical differences between the
`
`apparatuses of Wang and Kudryavtsev are irrelevant to the instant proceeding.
`
`8
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
`
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`F. Response to Observation 6
`The Patent Owner contends that Dr. Overzet’s testimony demonstrates that
`
`the requirement for a plasma density to be “substantially uniform” in claims 9, 26
`
`and 31 of the ’759 Patent would not have been obvious in view of Kudryavtsev.
`
`Observation at 8. Patent Owner incorrectly reads the claims of the ’759 Patent and
`
`attempts to shoehorn portions of Dr. Overzet’s testimony in order to support its
`
`erroneous construction.
`
`The testimony cited by Patent Owner merely indicates that the plasma
`
`density in Figure 5 of Kudryavtsev is larger in the center than at some value away
`
`from the center. Observation at 8-11. Patent Owner fails to consider the claim
`
`language calling for the plasma to be “substantially uniform.” ’759 Patent at 22:1-
`
`3, 23:13-17, 23:30-32 (Ex. 1001) (emphasis added). Indeed, right after the
`
`testimony cited by Patent Owner, Dr. Overzet testified that Kudryavtsev meets the
`
`“substantially uniform” limitation:
`
`Q. Figure 5 shows that the plasma density is not uniform;
`
`correct?
`
`MR. TENNANT: Objection, form, relevance.
`
`A. One of ordinary skill in the art would always understand that
`
`plasmas, when incoming close to any kind of a surface, will decrease
`
`in plasma density. So the uniformity would never be considered from
`
`9
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
`
`
`0 to 1 in that fashion, as the question has examined it. Therefore, one
`
`of ordinary skill in the art would understand this plasma to be
`
`relatively uniform.
`
`Overzet Dep. at 35:23 – 36:7 (Ex. 2012). When Dr. Overzet’s testimony is
`
`considered in its full context, Patent Owner’s observation is incorrect and
`
`ultimately irrelevant to Dr. Overzet’s opinion – both expressed in his declaration
`
`and confirmed in his deposition – that a person of ordinary skill in the art would
`
`understand that Kudryavtsev discloses a substantially uniform plasma.
`
`G. Response to Observation 7
`Patent Owner contends that Dr. Overzet’s testimony that Figures 4 and 6 of
`
`Wang disclose idealized power pulses undermines Petitioner’s position that Wang
`
`teaches choosing an amplitude and rise time of a voltage pulse to increase an
`
`excitation rate as claimed in the ‘759 patent. This is an incorrect characterization
`
`of Dr. Overzet’s opinion.
`
`Petitioner’s unfounded conclusion is based solely on Dr. Overzet’s
`
`confirmation that Figures 4 and 6 of Wang disclose idealized pulses. Dr. Overzet’s
`
`opinion – expressed in his declaration and confirmed at his deposition – recognizes
`
`that the pulses are idealized and relies on various passages from Wang when
`
`concluding that “Wang describes controlling both the magnitude and rise time of
`
`the voltage pulse at the power supply such that electrical pulse is sufficient to
`
`10
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
`
`
`increase the density of the weakly ionized plasma to generate strongly-ionized
`
`plasma”2. Overzet Dec. at ¶ 66 (Ex. 1036). After confirming with Dr. Overzet that
`
`Figures 4 and 6 of Wang are idealized, Patent Owner consciously chose not to
`
`question Dr. Overzet about his opinion regarding Wang’s disclosure of the claimed
`
`pulse amplitude and rise time. As a result, Zond’s observation does nothing more
`
`than repeat a small portion of Dr. Overzet’s opinion and tack on a baseless
`
`conclusion that Wang does not disclose the claim limitation. Unfounded
`
`conclusions provide no insight regarding the prior art’s disclosure and are
`
`irrelevant to these proceedings.
`
`H. Response to Observation 8
`Patent Owner contends that Dr. Overzet’s testimony shows that Wang’s
`
`Figure 6 does not teach applying a voltage pulse to ionize excited atoms without
`
`forming an arc discharge. Observation at 12. Patent Owner’s contention is
`
`premised on an incorrect reading of Dr. Overzet’s deposition testimony which
`
`clearly indicates that Wang’s Figure 6 reduces the particulates produced by arcing
`
`
`2 See Wang at 9:30-40 (calling for an adjustable DC power supply delivering a
`negative voltage and a pulsed power supply delivering pulses of negative voltage);
`7:19-22 (calling for a background power level chosen to exceed the minimum
`power necessary to support a plasma and a peak power at least 100 times the
`background power); 7:65-8:1 (calling for the time constant of the high-pass filter to
`fall between the pulse width and the pulse repetition period of the negative voltage
`pulses) and Fig. 7 (Ex. 1005)
`
`11
`
`
`
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
`
`
`during ignition and that there is no arcing during subsequent applications of high
`
`power pulses.
`
` In its observation, Patent Owner points to an excerpt from Dr. Overzet’s
`
`testimony as support for its conclusion that Figure 6 of Wang only discloses that
`
`particulates from arcing are reduced and that Figure 6 does not teach applying a
`
`pulse “without forming an arc discharge.” Observation at 12. However, Patent
`
`Owner wholly misreads the cited testimony. When asked whether Wang’s Figure
`
`6 reduces particulates produced by arcing, Dr. Overzet confirmed that it does and
`
`further stated that the chamber impedance changes relatively little between the two
`
`power levels, which is indicative that no arc is occurring:3
`
`Q. My question is whether Wang states that particulates
`
`produced by arcing are much reduced in the embodiment of Figure 6.
`
`MR. TENNANT: Objection to form.
`
`A. The statement -- direct statement in Wang's column 7 is that
`
`the initial plasma ignition needs to be performed only once and at
`
`much lower power levels so that particulates produced by arcing are
`
`
`3 Dr. Overzet testified that “Further, the chamber impedance changes relatively
`little between the two power levels P sub v [sic] and P sub p since a plasma always
`exists in the chamber.” Overzet Dep. at 102:19-22 (Ex. 2012). This relatively
`small change in impedance between PB and PP indicates that there is no arcing
`because an arc would cause the chamber impedance to vary drastically. See
`Overzet Declaration at ¶ 75 (Ex. 1036).
`
`12
`
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
`
`
`much reduced. Further, the chamber impedence [sic] changes
`
`relatively little between the two power levels P sub v and P sub p
`
`since a plasma always exists in the chamber.
`
`Q. Does the passage that you just read from, Wang, pertain to
`
`the embodiments of Figure 6?
`
`A. That is my -- that is my understanding that it pertains to
`
`Figure 6.
`
`Overzet Dep. at p. 102, l. 11 – p. 103, l. 3 (Exhibit 2012) (emphasis added).
`
`Thus, Dr. Overzet’s testimony supports his opinion that Wang’s Figure 6
`
`discloses application of a pulse “without forming an arc discharge.”
`
`Response to Observation 9
`
`I.
`Observation 9 is repetitious of Observations 1, 3, and 5. Patent Owner
`
`contends that Dr. Overzet’s testimony demonstrates that because the devices of
`
`Müller-Horsche and Wang are different, there is no objective evidence tending to
`
`establish that their teachings would lead to predictable results. Observation at 13.
`
`Patent Owner’s argument is misplaced because it mischaracterizes Dr. Overzet’s
`
`opinion about combining Wang and Müller-Horsche and is irrelevant to the
`
`grounds instituted in this proceeding.
`
`Consistent with his expertise in the field of plasma generation, Dr. Overzet
`
`testified that Müller-Horsche and Wang are very similar regarding their process for
`
`13
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`generating a plasma. Overzet Dec. at ¶ 105 (Ex. 1036). It is Dr. Overzet’s opinion
`
`that, since Wang is also directed to preionization to avoid arcing, it would be
`
`obvious to use a well-known UV radiation source such as taught by Müller-
`
`Horsche to preionize the gas of Wang. Overzet Dec. at ¶ 105 (Ex. 1036). Similar
`
`to Observation 5, Patent Owner’s reliance on the physical differences between
`
`Wang and Müller-Horsche is irrelevant as the Board has already rejected such an
`
`argument when instituting inter partes review. IPR2014-01086 Institution
`
`Decision at 19 (Paper No. 11). Because of this, the instant proceeding is instituted
`
`on the ground that a person of ordinary skill in the art would combine the teaching
`
`of Müller-Horsche to Wang irrespective of any physical differences between the
`
`overall apparatuses disclosed in the references. Thus, Patent Owner’s observation
`
`regarding physical differences between the apparatuses of Wang and Müller-
`
`Horsche are irrelevant to the instant proceeding.
`
`Respectfully Submitted,
`
`/s/ David. M. Tennant
`David M. Tennant
`Lead Counsel for Petitioner
`GlobalFoundries
`Registration No. 48,362
`
`
`Dated: May 26, 2015
`
`
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`14
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`Trial No. IPR2014-01086
`Petitioner’s Response to Patent Owner’s Motion for Observation
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`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 RESPONSE TO
`
`PATENT OWNER’S MOTION FOR OBSERVATION ON CROSS-
`
`EXAMINATION OF PETITIONER’S REPLY WITNESS” as detailed below:
`
`
`
`
`
`Date of service May 26, 2015
`
`Manner of service Email: bbarker@chsblaw.com;
`gonsalves@gonsalveslawfirm.com; kurt@rauschenbach.com
`
`Documents served PETITIONER’S RESPONSE TO PATENT OWNER’S
`MOTION FOR OBSERVATION ON CROSS-
`EXAMINATION OF PETITIONER’S REPLY WITNESS
`
`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
`
`15
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`
`
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