UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`GLOBAL FOUNDRIES U.S., INC., GLOBALFOUNDRIES DRESDEN
`MODULE ONE LLC & CO. KG, GLOBALFOUNDRIES DRESDEN MODULE
`TWO LLC & CO. KG, and THE GILLETTE COMPANY,
`
`Petitioners
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`v.
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`ZOND, LLC
`Patent Owner
`
`
`Case No. IPR2014-010891
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`Patent 6,806,652 B2
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`DECLARATION OF LARRY D. HARTSOUGH, PH.D.
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`1  Case  IPR  2014-­‐01004  has  been  joined  with  the  instant  proceeding.  
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`                                                                                                                          
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`Gillette et al. v. Zond
`IPR2014-01089 Zond Ex. 2002
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`Table of Contents
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`I.    Education  and  Professional  Background  .............................................................................  1  
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`II.    Summary  ...........................................................................................................................  5  
`III.    Legal  Standards  ................................................................................................................  7  
`A.  
`Level  of  Ordinary  Skill  in  the  Art.  ..............................................................................................  8  
`B.   Claim  Interpretation.  ................................................................................................................  9  
`C.  
`Legal  Standards  for  Obviousness.  .............................................................................................  11  
`IV.    Background  TOPICS  .........................................................................................................  13  
`A.   Voltage,  current,  impedance  and  power.  .................................................................................  15  
`B.   Plasmas.  ..................................................................................................................................  17  
`C.   Plasma  ignition.  .......................................................................................................................  20  
`D.   The  ‘652  Patent  –  Super-­‐Ionizing  an  Initial  Plasma  to  Generate  a  High-­‐Density  Plasma.  ...........  21  
`V.    Scope  and  content  of  The  prior  art.  ..................................................................................  27  
`A.   Overview  of  Mozgrin.  ..............................................................................................................  27  
`B.   Overview  of  Kudryavtsev.  ........................................................................................................  30  
`C.   Overview  of  Fahey.  ..................................................................................................................  34  
`D.   Overview  of  Iwamura  ..............................................................................................................  36  
`VI.    Claim  Analysis  vis-­‐à-­‐vis  the  Cited  References  ...................................................................  44  
`A.   Petitioners  have  not  shown  that  any  combination  of  the  cited  references  suggest  “super-­‐
`ionizing”  an  initial  plasma  and  excited  atoms  to  generate  a  high-­‐density  plasma.  ...........................  44  
`B.   The  Petition  fails  to  establish  that  the  cited  references  suggest  “wherein  the  power  supply  
`comprises  a  RF  power  supply  that  generates  an  alternating  electric  field.”  .....................................  47  
`C.   The  Petition  fails  to  establish  that  the  cited  references  suggest  transporting  the  initial  plasma  
`and  excited  atoms  proximate  to  a  cathode  assembly  and  super-­‐ionizing  the  initial  plasma  proximate  
`to  the  cathode  assembly.  ................................................................................................................  50  
`VII.    DECLARATION  ................................................................................................................  55  
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`I, Larry D. Hartsough, do hereby declare:
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`I am making this declaration at the request of patent owner Zond, LLC, in
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`connection with the Inter Partes Reviews (IPRs) of U.S. Patent No. 6,806,652 (the
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`“‘652 patent”), set forth in the above caption.
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`1.
`2.
`3.
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`I am being compensated for my work in this matter at the rate of $300 per
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`hour. I have no interest in the ‘652 patent and my compensation in no way
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`depends on the outcome of this proceeding.
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`In forming the opinions set forth in this declaration I reviewed a number of
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`materials, including the ‘652 patent, the file history of the ‘652 patent, the Petitions
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`for Inter Partes Review and the cited references discussed below, the Patent Trial
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`and Appeal Board’s (PTAB’s) Institution Decisions in these IPR proceedings, the
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`transcript of the deposition of Dr. Uwe Kortshagen concerning the ‘652 patent, and
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`the additional materials discussed herein.
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`
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`4. My formal education is as follows. I received a Bachelors of Science degree
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`I. EDUCATION AND PROFESSIONAL BACKGROUND
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`in 1965, Master of Science degree in 1967, and Ph.D. in 1971, all in Materials
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`Science/Engineering from the University of California, Berkeley.
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`1
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`5.
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`I have worked in the semiconductor industry for approximately 30 years. My
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`experience includes thin film deposition, vacuum system design, and plasma
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`processing of materials. I made significant contributions to the development of
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`magnetron sputtering hardware and processes for the metallization of silicon
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`integrated circuits. Since the late 1980s, I have also been instrumental in the
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`development of standards for semiconductor fabrication equipment published by
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`the Semiconductor Equipment and Materials International (“SEMI”) trade
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`6.
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`organization.
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`From 1971-1974, I was a research metallurgist in the thin film development
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`lab of Optical Coating Laboratory, Inc. In 1975 and 1976, I developed and
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`demonstrated thin film applications and hardware for an in-line system at Airco
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`Temescal. During my tenure (1977-1981) at Perkin Elmer, Plasma Products
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`Division, I served in a number of capacities from Senior Staff Scientist, to
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`Manager of the Advanced Development activity, to Manager of the Applications
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`Laboratory. In 1981, I co-founded a semiconductor equipment company, Gryphon
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`Products, and was VP of Engineering during development of the product. From
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`1984-1988, I was the Advanced Development Manager for Gryphon, developing
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`new hardware and process capabilities. During 1988-1990, I was Project Manager
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`at General Signal Thinfilm on a project to develop and prototype an advanced
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`cluster tool for making thin films. From 1991-2002, I was Manager of PVD
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`2
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`(physical vapor deposition) Source Engineering for Varian Associates, Thin Film
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`Systems, and then for Novellus Systems, after they purchased TFS. Since then, I
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`have been consulting full time doing business as UA Associates, where my
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`consulting work includes product development projects, film failure analysis,
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`project management, technical presentations and litigation support.
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`Throughout my career, I have developed and/or demonstrated processes and
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`7.
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`equipment for making thin films, including Al, Ti-W, Ta, and Cu metallization of
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`silicon wafers, RF sputtering and etching, and both RF and DC magnetron reactive
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`sputtering, for example SiO2, Al2O3, ITO (Indium-Tin Oxide), TiN, and TaN. I
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`have been in charge of the development of two sputter deposition systems from
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`conception to prototype and release to manufacturing. I have also specialized in the
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`development and improvement of magnetically enhanced sputter cathodes. I have
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`experience with related technology areas, such as wafer heating, power supply
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`evaluation, wafer cooling, ion beam sources, wafer handling by electrostatics,
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`process pressure control, in-situ wafer/process monitoring, cryogenic pumping,
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`getter pumping, sputter target development, and physical, electrical and optical
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`properties of thin films.
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`I am a member of a number of professional organizations including the
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`American Vacuum Society, Sigma Xi (the Scientific Research Society), and as a
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`3
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`8.
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`referee for the Journal of Vacuum Science & Technology. I have been a leader in
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`the development of SEMI Standards for cluster tools and 300mm equipment,
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`including holding various co-chair positions on various standards task forces. I
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`have previously served as a member of the US Department of Commerce’s
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`Semiconductor Technical Advisory Committee.
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`9.
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`I have co-authored many papers, reports, and presentations relating to
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`semiconductor processing, equipment, and materials, including the following:
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`a. P. S. McLeod and L. D. Hartsough, "High-Rate Sputtering of
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`Aluminum for Metalization of Integrated Circuits", J. Vac. Sci.
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`Technol., 14 263 (1977).
`
`b. D. R. Denison and L. D. Hartsough, "Copper Distribution in
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`Sputtered Al/Cu Films", J. Vac. Sci. Technol., 17 1326 (1980).
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`c. D. R. Denison and L. D. Hartsough, "Step Coverage in Multiple
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`Pass Sputter Deposition" J. Vac. Sci. Technol., A3 686 (1985).
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`d. G. C. D’Couto, G. Tkach, K. A. Ashtiani, L. Hartsough, E.
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`Kim, R. Mulpuri, D. B. Lee, K. Levy, and M. Fissel; S. Choi,
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`S.-M. Choi, H.-D. Lee, and H. –K. Kang, “In situ physical
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`vapor deposition of ionized Ti and TiN thin films using hollow
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`4
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`cathode magnetron plasma source” J. Vac. Sci. Technol. B
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`19(1) 244 (2001).
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`10. My areas of expertise include sputter deposition hardware and processes,
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`thin film deposition system design and thin film properties. I am a named inventor
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`on twelve United States patents covering apparatus, methods or processes in the
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`fields of thin film deposition and etching. A copy of my CV is attached as
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`Attachment A.
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`
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`11. My opinions in this matter are set forth in detail below. Briefly, it is my
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`II. SUMMARY
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`opinion that:
`
`a. Petitioners have not demonstrated that any of the combined teachings
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`of (a) Mozgrin, Kudryavtsev, Fahey, and Iwamura; (b) Mozgrin and
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`Iwamura; or (c) Mozgrin, Iwamura, and Fahey suggest “super-
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`ionizing an initial plasma so as to generate a high density plasma;
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`b. the apparatus recited in claim 5 would not have been obvious to a
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`person of ordinary skill in the art at the time of the invention in view
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`of the combined teachings of Mozgrin, Kudryavtsev, Fahey, Vratny,
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`5
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`and Iwamura; and
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`c. none of the combined teachings of (a) Mozgrin, Kudryavtsev, Fahey,
`
`and Iwamura; (b) Mozgrin and Iwamura; or (c) Mozgrin, Iwamura,
`
`and Fahey suggest transporting an initial plasma proximate to a
`
`cathode assembly and then super-ionizing the initial plasma proximate
`
`to the cathode assembly.
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`I note that in instituting these proceedings, the Board determined that the
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`12.
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`claimed limitation of super-ionizing an initial plasma so as to generate a high-
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`density plasma requires, “converting at least 75% of the neutral atoms in the initial
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`plasma into ions.”1 In contrast, Dr. Kortshagen attempts to demonstrate that
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`Mozgrin teaches converting at least 75% of the neutral atoms in the high-density
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`plasma into ions. These requirements are not synonymous.
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`13. Dr. Kortshagen states that, “if Mozgrin’s neutral gas density were about 2.0
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`x 1015 atoms cm-3, then at least 75% of the neutral argon gas would have been
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`ionized . . . .”2 He then attempts to demonstrate that Mozgrin describes pressure
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`                                                                                                                          
`1 See, e.g., Globalfoundries U.S., Inc. et al. v. Zond, LLC, IPR2014-01088, Paper
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`16, p. 11 (P.T.A.B. Jan. 6, 2015).
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`2 IPR2014-01089 Ex. 1202 at ¶ 88.
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`6
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`and temperature conditions that would support such rarified atom density in
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`Mozgrin’s highest reported ion density plasma.3 However, Mozgrin does not
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`control pressure of his fill gas, so as temperature rises, pressure will rise. Dr.
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`Kortshagen does not account for this fact and instead assumes that the initial gas
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`pressure of 0.2 Torr is held constant and calculates a gas temperature that would
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`result in this pressure for his goal of 2.0 x 1015 atoms cm-3.
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`14. Even assuming Dr. Kortshagen’s computations to be correct in this regard,
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`all that this would demonstrate is that for the highest ion density described by
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`Mozgrin, the degree of ionization was at least 75%. In contrast, the claims of the
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`‘652 patent require super-ionizing the initial plasma so as to generate a high-
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`density plasma.4 The initial plasma is not the high-density plasma, thus Dr.
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`Kortshagen’s computations fail to address the requirement specified in the claim.
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`15.
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`III. LEGAL STANDARDS
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`In this section I describe my understanding of certain legal standards. I have
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`                                                                                                                          
`3 Id. at ¶¶ 73-77.
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`4 See, e.g., Ex. 1001 at 33:61-64 (claim 1); 34:51-53 (claim 18); 36:20-22 (claim
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`36) (emphasis added).
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`been informed of these legal standards by Zond’s attorneys. I am not an attorney
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`and I am relying only on instructions from Zond’s attorneys for these legal
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`standards.
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`16.
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`A. Level of Ordinary Skill in the Art.
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`I understand that a person of ordinary skill in the art provides a reference
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`point from which the prior art and claimed invention should be viewed. This
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`reference point prevents one from using his or her own insight or hindsight in
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`deciding whether a claim is obvious.
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`17.
`
`In my opinion, given the disclosure of the ‘652 patent and the disclosure of
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`the prior art references considered here, I consider a person of ordinary skill in the
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`art at the time of filing of the ‘652 patent to be someone who holds at least a
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`bachelor of science degree in physics, material science, or electrical/computer
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`engineering with at least two years of work experience or equivalent in the field of
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`development of plasma-based processing equipment. I met or exceeded the
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`requirements for one of ordinary skill in the art at the time of the invention and
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`continue to meet and/or exceed those requirements.
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`B. Claim Interpretation.
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`18.
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`I understand that the Board has construed the term “super-ionizing the initial
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`plasma so as to generate a high-density plasma” requires, “converting at least 75%
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`of the neutral atoms in the initial plasma into ions.” In rendering the opinions set
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`19.
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`forth herein I have applied this construction.5
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`I also understand that a means plus function claim limitation must be
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`construed to cover the corresponding structure, material, or acts described in the
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`specification and equivalents thereof. To that end, I understand the Board has
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`adopted the following constructions of means plus function terms in the claims of
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`the ‘652 patent.6
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`Term
`means for generating an initial plasma
`and excited atoms from a volume of feed
`gas
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`Construction
`Structures, as shown in Figure 2 and
`described in the Specification of the
`’652 patent, including gap 212 or region
`214 defined by an outer cathode section
`and an anode spaced apart from the
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`                                                                                                                          
`5  Global Foundries U.S. Inc. et al. v. Zond, LLC, IPR2014-01089, Paper 13 at 17
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`(P.T.A.B. Jan. 6, 2015).  
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`6 Id. at 11-18.
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`cathode sufficient to allow current to
`flow through region 214, and first power
`supply 206, which is separate from a
`second power supply used to super-
`ionize the plasma; and structures, as
`shown in Figure 12 and described in the
`Specification of the ’652 patent,
`including an excited atom source 732b
`(cathode assembly) that has tube 733,
`which is surrounded by enclosure 735,
`that defines electrode chamber 739, in
`which is positioned electrode 741
`connected to first power supply 731.
`The cathode assembly in the “means for
`transporting” element is distinct from
`the cathode assembly corresponding
`structure for the “means for generating”
`element. The corresponding structure
`for the transporting function is gas
`exchange system 238, 242 that flows
`gas through the outer cathode sections
`202b/656b/702b/722b/732b (shown,
`e.g., in Figures 2, 3, 5, 6, and 12),
`through gap 214, toward inner cathode
`assembly 202a/732a.
`The recited function is construed as
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`means for transporting the initial
`plasma and excited atoms proximate to
`a cathode assembly
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`means for super-ionizing the initial
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`10
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`plasma proximate to the cathode
`assembly
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`“converting at least 75% of the neutral
`atoms in the initial plasma into ions near
`the cathode assembly.” The
`corresponding structure for the super-
`ionizing function is second power
`supply 222 that generates an electric
`field across inner cathode 202a (e.g.,
`Fig. 2A, 2B, 3, 5, and 6) or inner
`cathode 732a (Fig. 12); and inner anode
`226 or 658 (e.g., Fig. 2A, 2B, 3, 5 and
`6) or inner anode 703 (Fig. 12).
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`In rendering the opinions set forth herein I have applied the above constructions.
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`
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`20.
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`C. Legal Standards for Obviousness.
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`I understand that a patent claim may be invalid if the differences between the
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`claimed subject matter and the prior art are such that the subject matter as a whole
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`would have been obvious at the time the invention was made to a person of
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`ordinary skill in the pertinent art.
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`21.
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`I understand that obviousness must be analyzed from the perspective of a
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`person of ordinary skill in the relevant art at the time the invention was made. In
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`analyzing obviousness, I understand that it is important to understand the scope of
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`11
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`the claims, the level of skill in the relevant art, the scope and content of the prior
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`art, the differences between the prior art and the claims, and any secondary
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`considerations of non-obviousness. I have not been asked to study or analyze any
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`secondary considerations of non-obviousness.
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`I also understand that a party seeking to invalidate a patent as obvious must
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`22.
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`demonstrate that a person of ordinary skill in the art would have been motivated to
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`combine the teachings of the prior art references to achieve the claimed invention,
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`that the person of ordinary skill in the art would have had a reasonable expectation
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`of success in doing so, and that such determinations are evaluated as of the time
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`the invention was made. I understand that this temporal requirement prevents the
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`forbidden use of hindsight. I also understand that rejections for obviousness cannot
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`be sustained by mere conclusory statements and that Petitioners must show some
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`reason why a person of ordinary skill in the art would have thought to combine
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`particular available elements of knowledge, as evidenced by the prior art, to reach
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`the claimed invention. I also understand that the motivation to combine inquiry
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`focuses heavily on the scope and content of the prior art and the level of ordinary
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`skill in the pertinent art.
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`In arriving at the opinions set forth herein, I have considered questions of
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`obviousness from the perspective of a person of ordinary skill in the relevant art at
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`12
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`23.
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`the time the invention was made and have given consideration to (1) the scope and
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`content of the prior art; (2) the differences between the prior art and the asserted
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`claims; and (3) the level of ordinary skill in the pertinent art. I have been informed
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`and understand that the obviousness analysis requires a comparison of the properly
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`construed claim language to the prior art on a limitation-by-limitation basis.
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`
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`24. The ‘652 patent is generally directed to a system and technique for
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`IV. BACKGROUND TOPICS
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`generating a super-ionized plasma having a high density of ions.7 I understand that
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`IPR2014-01088 was instituted to consider (1) whether claims 1-14, 16 and 17 are
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`obvious in view of the combined teachings of Mozgrin et al., High-Current Low-
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`Pressure Quasi- Stationary Discharge in a Magnetic Field: Experimental
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`Research, Plasma Physics Reports, Vol. 21, No. 5, 1995 (IPR2014-01088 Ex.
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`1003) (“Mozgrin”), Kudryavtsev, et al., Ionization relaxation in a plasma
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`produced by a pulsed inert-gas discharge, Sov. Phys. Tech. Phys. 28(1), January
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`1983 (IPR2014-01088 Ex. 1006) (“Kudryavtsev”), D. W. Fahey, et al., High flux
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`beam source of thermal rare gas metastable atoms, J. Phys. E; Sci. Insrum., Vol.
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`13, 1980 (IPR2014-01088 Ex. 1005) (“Fahey”), and Iwamura, U.S. Pat. No.
`                                                                                                                          
`7 Ex. 1001 at Abstract.
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`13
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`5,753,886 (IPR2014-01088 Ex. 1007) (“Iwamura”); (2) whether claim 5 is obvious
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`in view of the combined teachings of Mozgrin, Kudryavtsev, Fahey, Vratny, U.S.
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`Pat No. 3,461,054 (IPR2014-01088 Ex. 1008) (“Vratny”), and Iwamura; (3)
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`whether claims 8-10 are obvious in view of the combined teachings of Mozgrin,
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`Kudryavtsev, Fahey, Lantsman, U.S. Patent 6,190,512 (IPR2014-01088 Ex. 1013)
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`(“Lantsman”), and Iwamura; and (4) whether claim 15 is obvious in view of the
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`combined teachings of Mozgrin, Kudryavtsev, Fahey, Wang, U.S. Pat No.
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`6,413,382 (IPR2014-01088 Ex. 1004) (“Wang”), and Iwamura.
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`I also understand that IPR2014-00861 was instituted to consider the
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`25.
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`obviousness of (1) claims 18-30, 33 and 34 in view of the combined teachings of
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`Mozgrin, Kudryavtsev, Fahey, and Iwamura; (2) claims 31 and 32 in view of the
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`combined teachings of Mozgrin, Kudryavtsev, Fahey, Campbell, U.S. Patent
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`5,429,070 (IPR2014-00861 Ex. 1114) (“Campbell”), and Iwamura; (3) claims 18-
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`30 in view of the combined teachings of Mozgrin and Iwamura; (4) claims 31 and
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`32 in view of the combined teachings of Mozgrin, Iwamura, and Campbell; and (5)
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`claims 33 and 34 in view of the combined teachings of Mozgrin, Iwamura, and
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`Fahey.
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`I further understand that IPR2014-01089 was instituted to consider the
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`obviousness of claim 35 in view of the combined teachings of (1) Mozgrin,
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`14
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`26.
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`

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`27.
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`Kudryavtsev, Fahey, and Iwamura; and (2) Mozgrin, Iwamura, and Fahey.
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`In this section I provide some background information useful to
`
`understanding these cited references and the subject matter claimed in the ‘652
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`patent.
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`
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`28. As is commonly known, when a voltage “V” is applied across an impedance
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`A. Voltage, current, impedance and power.
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`“I,” an electric field is generated that forces a current I to flow through the
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`impedance. For purely resistive impedance, the relation between the voltage and
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`the resultant current is given by: V = I * R.
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`29. A common analogy is that voltage is like a pressure that causes charged
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`particles like electrons and ions to flow (i.e., current), and the amount of current
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`depends on the magnitude of the pressure (voltage) and the amount of resistance or
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`impedance that inhibits the flow. The ‘652 patent and the cited references
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`considered here involve the flow of current through an assembly having a pair of
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`electrodes with a plasma in the region between them. The effective impedance of
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`such an assembly varies greatly with the density of charged particles in the region
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`between the electrodes. Although such an impedance is more complex than the
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`simple resistive impendence of the above equation, the general relation is similar: a
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`15
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`voltage between the electrode assembly forces a current to flow through the
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`plasma, such that the amount of current is determined by the amplitude of the
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`voltage and the impedance of the plasma. Thus, the current through the electrode
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`assembly increases with the electrode voltage and, for a given electrode voltage,
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`the current will increase with a drop in the impedance of the plasma.
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`30. The impedance varies with the charge density of the plasma: With a high
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`density of charged particle the impedance is relatively small, and with a low
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`density of charged particles the impedance is relatively large. Simply, the more
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`ions and electrons to carry the charge, the less resistance. However, the charges
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`31.
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`and fields react with each other in a very complicated manner.
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`In response to the electric field in the region between the electrodes (i.e., the
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`voltage across the electrodes), all charged particles in the region (the electrons and
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`positive ions) feel a force that propels them to flow. This flow is an electric current
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`“I.” The amount of current depends upon the number of charged particles. When
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`there are no charged particles (i.e., no plasma), there is no current flow in response
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`to the electric field. In this condition, the impendence of the assembly is extremely
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`high, like that of an open circuit. But when there is a dense plasma between the
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`electrodes (with many charged particles), a substantial current will flow in
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`response to the electric field. In this condition, the impendence of the electrode
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`16
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`assembly is very low. Thus, in general, the impedance of an electrode assembly
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`varies greatly with the charge density of the plasma: The impedance is effectively
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`infinite (an open circuit) when there is no plasma, and is very low when the charge
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`density of the plasma is very high.
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`32.
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`It is also well known that electric power (P) is the product of voltage (V) and
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`current (I): P = V * I. Thus, for a given voltage across an electrode assembly, the
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`amount of power will depend on the amount of corresponding current flowing
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`through the electrode assembly. If there is no current flow (such as when there is
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`no plasma between the electrodes), the power is zero, even if the voltage across the
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`electrodes is very large. Similarly, at very low electrode voltages, the power can
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`still be quite high if the current is large.
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`33. The claims of the ‘652 patent refer to a high-density plasma that is created
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`by application of an electric field across an initial plasma. 8
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`34. Plasma is a distinct state of matter characterized by a significant number of
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`B.
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`Plasmas.
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`                                                                                                                          
`8 Id. at 33:61-64 (claim 1); 34:51-53 (claim 18); 36:20-22 (claim 35) (emphasis
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`added).
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`17
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`electrically charged particles.9 In an ordinary gas, each atom or molecule contains
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`an equal number of positive and negative charges, so that each is electrically
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`“neutral.” When those atoms or molecules are subjected to heat or other energy,
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`they begin to lose electrons and are left with a positive charge. This process is
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`called ionization. When enough gas atoms or molecules have been ionized such
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`that the ions, together with the free electrons, significantly affect the electrical
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`characteristics of the substance it is said to be plasma. Although made up of
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`charged particles the plasma remains electrically neutral overall.10
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`35. Common examples of the use of plasmas include applications in neon signs
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`and fluorescent lights. Plasmas are also used in a number of industrial processes,
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`including the manufacture of semiconductor devices. To that end, consider an
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`object (hereinafter referred to as a “target”) in or near a plasma. If the target (or an
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`object in its vicinity) is made electrically negative compared to the plasma,
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`positively charged ions in the plasma will be accelerated towards the target. At the
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`surface of the target, a number of different interactions can occur (see Figure 1,
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`below).
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`                                                                                                                          
`9 Id. at 1:13-15.
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`10 Id. at 1:15.
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`18
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`(A)
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`(B)
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`(C)
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`(D)
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`Plasma
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`Surface
`of
`Target
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`FIG. 1
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`
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`Figure 1: Interactions at a target’s surface
`
`In Figure 1, an arriving ion is “adsorbed” onto the surface of the target at
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`36.
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`(A). Adsorption is an adhesion of ions (or other particles) to a surface and is
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`typically a low energy process, which is dominant around a few tens of eV, or less.
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`At (B), the incoming ion transfers some of its momentum to one of the target’s
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`surface atoms and causes it to move. This is called displacement. If the energy of
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`the incoming ion is sufficiently high, say on the order of 100 eV or more, surface
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`atoms of the target may be removed in a process referred to as sputtering (shown in
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`(C)). If the ion energy is even greater, say above 1 keV, then it may be implanted
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`into the target (at (D)). These various processes form the bases of a number of
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`plasma-assisted semiconductor manufacturing techniques.
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`19
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`37. To ignite a plasma, a gas is introduced in a space between two electrodes,
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`C.
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`Plasma ignition.
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`for example in a tube or other container, and an electric field is applied between
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`the electrodes. A simplified example of such an arrangement is shown in Figure 2.
`
`Anode
`
`Tube
`
`Gas
`
`Electric Field
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`+
`
`_
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`Voltage
`Source
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`Cathode
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`
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`Figure 2: Simplified plasma system
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`Even at room temperature, the gas will contain a small number of ions and free
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`electrons. These ions and electrons are accelerated towards the electrically negative
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`electrode (the “cathode”) and the electrically positive electrode (the “anode”),
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`respectively. As electrons collide with gas atoms, they produce new ions.
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`38. When the ions are in close proximity to the cathode (e.g., on the order of a
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`20
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`few Angstroms), electrons can tunnel from the cathode, and the ions are
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`neutralized. When an ion is neutralized, some amount of energy (corresponding to
`
`the ionization energy of the ion) is released. If this energy is transferred to a
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`surface electron at the cathode (via an Auger process) and it is greater than the
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`electron work function, new electrons (so-called “secondary electrons”) are
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`emitted into the gas from the cathode. These secondary electrons are accelerated
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`towards the anode, and when they collide with gas atoms they generate new ions
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`and free electrons. By the addition and acceleration of new electrons, the process
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`of ionization proceeds; and, if the applied power is sufficiently high, a plasma is
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`created. The ‘652 patent is particularly concerned with high-density plasmas, for
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`example, plasmas having a density greater than 1012 cm-3.11
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`
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`D. The ‘652 Patent – Super-Ionizing an Initial Plasma to Generate a High-
`Density Plasma.
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`39. The ‘652 patent explains that for certain applications, such as plasma etching
`
`or plasma sputtering, it is undesirable for the plasma’s ion concentration to vary
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`significantly from one location to another. For example if the ion concentration is
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`relatively high in one region, it can cause corresponding erosion non-uniformities
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`