UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2014-00781,782,1083,1086, and 1087
`Patent 7,147,759
`
`PATENT OWNER ZOND LLC’S
`DEMONSTRATIVE EXHIBIT
`
`1
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2014-00781,782,1083,1086, and 1087
`Patent 7,147,759
`
`PATENT OWNER ZOND LLC’S
`DEMONSTRATIVE EXHIBIT
`
`1
`
`
`
`OBVIOUSNESS
`Claims 1-50 Are Not Obvious Over Wang and
`Kudryavtsev
` Wang and Kudryavtsev would not have taught:
`1. “an amplitude and 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,” As Recited In Claim 20 And
`Similarly in Claim 40
`
`2. “a 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,” As
`Recited In Claim 20 And Similarly In Claim 40
`
`2
`
`
`
`OBVIOUSNESS
`Claims 1-50 Are Not Obvious Over Wang and
`Kudryavtsev
` Wang instead teaches controlling a power pulse:
`the target 14 is powered by narrow pulses of negative DC
`power supplied from a pulsed DC power supply 80, as
`illustrated in FIG. 1. The pulse form is generically represented
`in the timing diagram of FIG. 4 and includes a periodic
`sequence of power pulses. (col. 5, ll. 23-27).
`
`Figures 4, 5, and 6 in Wang shows the amplitude or rise time of
`power, not voltage.
`
`“the power pulse width is preferably specified rather than the
`voltage pulse width.” (col. 5, ll. 52-54)
`
` Neither Wang nor Kudryavtsev teach an increase in the
`excitation rate of the ground state atoms
`
`3
`
`
`
`OBVIOUSNESS
`Claims 1-50 Are Not Obvious Over Wang and
`Kudryavtsev
`Kudryavtsev fails to teach that the
`amplitude and rise time of the voltage
`pulse are chosen to increase an
`excitation rate of ground state atoms:
`FIG. 2 shows no change in the current
`(a) on the rising edge of the voltage
`pulse (b).
`
`4
`
`
`
`OBVIOUSNESS
`Claims 1-50 Are Not Obvious Over Wang and
`Kudryavtsev
`
`5
`
`
`
`OBVIOUSNESS
`Claims 1-50 Are Not Obvious Over Wang and
`Kudryavtsev
`Wang discloses that arcing occurs:
`“[p]lasma ignition … has a tendency
`to generate particles during the initial
`arcing, which may dislodge large
`particles from the target or
`chamber.” (col. 7, ll. 3-6).
`“particulates produced by arcing are
`much reduced.” (col. 7, ll. 47-49).
`
`6
`
`
`
`OBVIOUSNESS
`Claim 38 Is Not Obvious Over Wang, Kudryavtsev, and
`Yamaguchi
`Yamaguchi would not have taught:
`1. The Claim Limitations In Independent
`Claim 20 That Have Been Shown To Be
`Missing From Wang and Kudryavtsev
`
`2. That “ionizing the feed gas comprises
`exposing the feed gas to an electrode
`that is adapted to emit electrons”
`
`7
`
`
`
`OBVIOUSNESS
`Claim 38 Is Not Obvious Over Wang, Kudryavtsev, and
`Yamaguchi
` Yamaguchi instead teaches:
`exposing the particles that are ejected from the target
`to an electron emitting electrode (Exhibit 2005, Dr.
`Hartsough’s Declaration, ¶¶ 128-136).
`
`“[p]articles evaporated from a target 2 are ionized using
`an ionizing mechanism 6, and the ionized sputtering
`particles … are incident on a substrate 7” (¶ [0039]).
`
`“[t]he embodiment uses a mechanism which hits
`thermoelectrons against evaporated particles and
`discharge gas particles to ionize the evaporated
`particles.” (¶ [0042]).
`
`8
`
`
`
`OBVIOUSNESS
`Claim 38 Is Not Obvious Over Wang, Kudryavtsev, and
`Yamaguchi
`FIG. 11 of the ’759 patent,
`reproduced on the next slide,
`shows the feed gas exposed to the
`electrode 452 in the area 245:
`
`9
`
`
`
`OBVIOUSNESS
`Claim 38 Is Not Obvious Over Wang, Kudryavtsev, and
`Yamaguchi
`
`10
`
`
`
`OBVIOUSNESS
`Claim 38 Is Not Obvious Over Wang, Kudryavtsev, and
`Yamaguchi
`FIG. 1 of Yamaguchi shows
`electrodes (6) in the path of the
`evaporated particles (area 606)
`from sputtering target (2) to
`substrate (7):
`
`11
`
`
`
`OBVIOUSNESS
`Claim 38 Is Not Obvious Over Wang, Kudryavtsev, and
`Yamaguchi
`
`12
`
`
`
`OBVIOUSNESS
`Claim 22 Is Not Obvious Over Wang, and Kudryavtsev
`
` Wang and Kudryavtsev would not have taught “applying a
`substantially uniform electric field”
`
`The Petitioners admitted that “the electric field [in Wang]
`between the cathode/target 14 and the anode 24 is not
`constant or substantially uniform” (Petition, p. 47)
`
`It would not have been obvious to modify Wang to include a
`parallel plate capacitor because it is incompatible with Wang’s
`floating shield (Dr. Hartsough’s declaration, ¶¶ 152-152).
`
`“the floating shield 64 accumulates some electron charge and
`builds up a negative potential. Thereby, it repels further
`electron loss to the floating shield 64 and thus confines the
`plasma nearer the target 56.” (Chiang, col. 11, ll. 8-11).
`
`13
`
`
`
`OBVIOUSNESS
`Claims 17 and 39 Are Not Obvious Over Wang,
`Kudryavtsev, Kobayashi, and Muller-Horsche
`Kobayashi and Muller-Horsche would not
`have taught:
`1. The Claim Limitations In Independent
`Claims 1 and 20 That Have Been Shown To
`Be Missing From Wang and Kudryavtsev
`
`2. That “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”
`
`14
`
`
`
`OBVIOUSNESS
`Claims 17 and 39 Are Not Obvious Over Wang,
`Kudryavtsev, Kobayashi, and Muller-Horsche
` Wang teaches away from the use of Muller-Horsche’s
`pulsed UV source for pre-ionizing a feed gas:
`Plasma ignition, particularly in plasma sputter reactors,
`has a tendency to generate particles during the initial
`arcing, which may dislodge large particles from the
`target chamber. … Each of the previously described
`short pulses need to ignite the plasma since the target is
`unpowered between the pulses. Accordingly, it is
`advantageous to use a target power waveform
`illustrated in Fig. 6 in which the target is maintained at a
`background power level PB between pulses 96 rising to
`a peak level PP corresponding to that contemplated in
`Fig. 4. (col. 7, ll. 3-17)
`
`15
`
`
`
`OBVIOUSNESS
`Claims 17 and 39 Are Not Obvious Over Wang,
`Kudryavtsev, Kobayashi, and Muller-Horsche
`Muller-Horsche teaches the very same type of
`pulsed power source for pre-ionization that was
`disparaged in Wang:
`“Thus, in the circuits according to the invention for
`preionization of a pulsed gas laser as well for the
`preionization the same energy source is used
`which also serves for the main discharge… The
`essential matter is the provision of an inductance
`(coil) 30 in the preionization and main discharge
`circuit and the arrangement of the line 32 with
`which the preionization electrodes 12, 12’ are put
`under voltage.” (col. 4, l. 65 – col. 5, l. 6)
`
`16
`
`
`
`OBVIOUSNESS
`Claims 17 and 39 Are Not Obvious Over Wang,
`Kudryavtsev, Kobayashi, and Muller-Horsche
`Muller-Horsche teaches avoiding sputtering, which
`is the very purpose of Wang’s apparatus:
`“Muller-Horsche teaches that a key advantage of
`his invention is reduced electrode erosion or
`sputtering” (Dr. Hartsough’s Declaration, ¶ 142).
`
`“sparks are effectively suppressed and thus also
`the disadvantages caused by sparks, in particular
`erosion processes at the electrodes and gas
`impurities” (col. 2, ll. 21-23).
`
`17
`
`
`
`OBVIOUSNESS
`Claim 11 Is Not Obvious Over Wang, Kudryavtsev, and Li
`
`Li does not teach:
`The claim limitations from
`independent claim 1 that have been
`shown to be missing from Wang and
`Kudryavtsev
`
`“a temperature controller that
`controls the temperature of the
`substrate support”
`
`18
`
`
`
`OBVIOUSNESS
`Claim 11 Is Not Obvious Over Wang, Kudryavtsev, and Li
`
`Li instead teaches that “[s]ubstrate
`temperatures were maintained at or
`below 300〫C” (Abstract)
`“Li makes no mention of controlling
`the temperature of a substrate
`support, as required by claim 11” (Dr.
`Hartsough’s Declaration, ¶ 156.)
`
`19
`
`
`
`OBVIOUSNESS
`Claim 30 Is Not Obvious Over Wang and Kudryavtsev
`
`Neither Wang nor Kudryavtsev teaches :
`“the ions in the strongly-ionized plasma impact
`the surface of the sputtering target in a
`substantially uniform manner”
`
`Indeed, Wang explicitly states that the ions in its
`device do not impact the sputtering target in a
`uniform manner:
`“the sputtering is concentrated [in] the area of the
`target below the magnetron“(col. 5, ll. 33-34).
`
`20
`
`
`
`OBVIOUSNESS
`Claim 30 Is Not Obvious Over Wang, and Kudryavtsev
`
`21
`
`
`
`OBVIOUSNESS
`Claims 9, 26 and 31 Are Not Obvious Over Wang, and
`Kudryavtsev
`Neither Wang nor Kudryavtsev teaches :
`“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”
`
`“As shown by [FIG. 1] … the area of high density
`plasma is limited to the area under the magnetron
`(42) and not the area proximate to the sputtering
`target 14 as required by the claims 26 and 31.” (Dr.
`Hartsough’s Declaration, ¶ 148).
`
`22
`
`
`
`OBVIOUSNESS
`Claim 3 Is Not Obvious Over Wang and Kudryavtsev
`
` Neither Wang nor Kudryavtsev teaches :
`a “power supply that generates a constant voltage”
` Wang instead teaches controlling a power pulse:
`“The target 14 is powered by narrow pulses of
`negative DC power supplied from a pulsed DC power
`supply 80, as illustrated in FIG. 1. The pulse form is
`generically represented in the timing diagram of FIG. 4
`and includes a periodic sequence of power pulses”
`(col. 5, ll. 18-22)
` Wang instead teaches allowing the voltage to vary:
`“[The pulse’s] exact shape depends on the design of
`the pulsed DC power supply 80, and significant rise
`times and fall times are expected” (col. 5, ll. 23-27)
`
`23
`
`
`
`OBVIOUSNESS
`Claim 6 Is Not Obvious Over Wang and Kudryavtsev
`
` Neither Wang nor Kudryavtsev teaches that:
`“the rise time of the voltage pulse is chosen to increase the ionization
`rate of the excited atoms in the weakly-ionized plasma”
` Wang instead teaches only that:
`“[t]he illustrated pulse form is idealized. Its exact shape depends on the
`design of the pulsed DC power supply 80, and significant rise times and
`fall times are expected” (col. 5, ll. 23-36)
`
`“Wang’s statement is merely a comment of fact that rise times and fall
`times are features of the pulse to distinguish from the idealized (perfect
`rectangular pulse shape) pulse forms of Figs. 4 and 6” (Dr. Hartsough’s
`Declaration, With respect to FIG. 4, that “[t]he illustrated rectangular
`pulse widths” (Dr. Hartsough’s Declaration ¶ 181)
`
`24
`
`
`
`OBVIOUSNESS
`Claim 13 Is Not Obvious Over Wang and Kudryavtsev
`
`Neither Wang nor Kudryavtsev teaches that:
`The “volume between the anode and the cathode
`assembly is chosen to increase the ionization rate
`of the excited atoms in the weakly-ionized plasma
`the strongly-ionized plasma is substantially
`uniform proximate to the sputtering target”
`
`“there is no indication in either Wang or
`Kudryavtsev of choosing a volume between the
`anode and the cathode to increase the ionization
`rate of the excited atoms” (Dr. Hartsough’s
`Declaration ¶ 189)
`
`25
`
`
`
`OBVIOUSNESS
`Claim 2 Is Not Obvious Over Wang and Kudryavtsev
`
`Neither Wang nor Kudryavtsev teaches :
`“a power supply that generates constant
`power”
`Wang instead teaches:
`With respect to FIG. 6, that “the actual
`waveforms will differ from the idealized
`illustrated ones” (col. 7, ll. 41-42)
`
`With respect to FIG. 4, that “[t]he illustrated
`rectangular pulse widths” (col. 7, ll. 50-52)
`
`26
`
`
`
`OBVIOUSNESS
`Claims 1-50 Are Not Obvious Over Wang and
`Kudryavtsev
`The Petitioners failed to provide any
`objective evidence that combining the
`teachings of Kudryavtsev and Wang would
`have led to a predictable result and achieved
`the claimed invention of the ‘759 patent with
`a reasonable expectation of success:
`Kudryavtsev teaches pulsed gas cylindrical
`discharge device with no magnet and no
`sputtering (p. 34, right col.).
`Wang teaches a sputtering magnetron
`device (col. 3, ll. 69-72).
`
`27
`
`
`
`OBVIOUSNESS
`Claims 1-50 Are Not Obvious Over Wang and
`Kudryavtsev
`Kudryavtsev teaches a nearly stationary
`excited atom density: “For nearly
`stationary n2 [excited atom density
`values] … there is an explosive increase in
`ne [electron or ion density].” (p. 31, right
`col, ¶ 6).
`The ‘759 patent discloses and claims an
`increase in the rate at which excited
`atoms are generated (Dr. Hartsough’s
`declaration, ¶ 99).
`
`28
`
`
`
`OBVIOUSNESS
`Claims 1-50 Are Not Obvious Over Wang and
`Kudryavtsev
`Kudryavtsev teaches pressures of 3.7 and 11.4
`torr (FIG. 3 caption)
`Wang teaches that “[t]he SIP reactor is
`advantageous for a low-power, low-pressure
`background” (col. 7, ll. 32-34)
`Kudryavtsev states that “the distance between
`the electrodes was L = 52cm” (p. 32, right col,
`¶ 6).
`The ‘759 patent discloses a “gap 244 is
`between approximately 0.3 cm and 10 cm”
`(col. 5, ll. 44-45)
`
`29
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2014-00781,782,1083,1086, and 1087
`Patent 7,147,759
`
`END
`
`30
`
`
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