FUJITSU
SEMICONDUCTOR
LIMITED,
FUJITSU
SEMICONDUCTOR
AMERICA,
INC.,
`THE GILLETTE COMPANY, RENESAS ELECTRONICS
`CORPORATION, RENESAS ELECTRONICS AMERICA, INC., ADVANCED MICRO DEVICES, INC.,
`GLOBALFOUNDRIES U.S., INC., GLOBALFOUNDRIES DRESDEN MODULE ONE LLC & CO. KG,
`GLOBALFOUNDRIES DRESDEN MODULE TWO LLC & CO. KG, TOSHIBA AMERICA ELECTRONIC
`COMPONENTS, INC., TOSHIBA AMERICA INC., TOSHIBA AMERICA INFORMATION SYSTEMS, INC.,
`and TOSHIBA CORPORATION,
`Petitioner,
`v.
`ZOND, LLC,
`Patent Owner.
`
`IPR2014-‐00861
`IPR2014-‐01088
`IPR2014-‐01089
`Patent 6,086,652
`
`Patent Owner’s Demonstrative Exhibits
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`1
`
`
`THE GILLETTE COMPANY, RENESAS ELECTRONICS
`CORPORATION, RENESAS ELECTRONICS AMERICA, INC., ADVANCED MICRO DEVICES, INC.,
`GLOBALFOUNDRIES U.S., INC., GLOBALFOUNDRIES DRESDEN MODULE ONE LLC & CO. KG,
`GLOBALFOUNDRIES DRESDEN MODULE TWO LLC & CO. KG, TOSHIBA AMERICA ELECTRONIC
`COMPONENTS, INC., TOSHIBA AMERICA INC., TOSHIBA AMERICA INFORMATION SYSTEMS, INC.,
`and TOSHIBA CORPORATION,
`Petitioner,
`v.
`ZOND, LLC,
`Patent Owner.
`
`IPR2014-‐00861
`IPR2014-‐01088
`IPR2014-‐01089
`Patent 6,086,652
`
`Patent Owner’s Demonstrative Exhibits
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`1
`
`
`
`‘652 Patent – A System and Technique for
`Generating a Super-‐Ionized Plasma Having a
`High Density of Ions.
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`2
`
`
`
`‘652 Patent
`
`In prior systems, such as that shown in Fig. 1 of
`the ‘652 patent, neutral gas in the region 105
`between electrodes 114 and 124 is ionized by
`applying a voltage across the electrodes 114,
`124 to create a plasma. In such systems, ions
`tend to concentrate in certain portions of region
`105.
`
`If the ion concentration is relatively high, it can
`cause corresponding erosion non-uniformities
`in the target.
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`3
`
`
`
`‘652 Patent
`
`• The uniformity of the plasma can be improved by
`increasing the power applied to the plasma via the
`voltage across the electrodes, to thereby increase
`the ion density and disperse the charged particles.
`
`• However, increasing plasma density and uniformity
`in this manner can significantly increase the risk of
`an undesirable electrical breakdown and arcing
`condition.
`
`‘652 Patent at 4:31-‐37
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`4
`
`
`
`‘652 Patent
`
`• The ‘652 patent
`generates a super-‐
`ionized, uniformly
`distributed plasma (one
`with a relatively uniform
`density of charged
`particles), which reduces
`the risk of arcing at high
`charge densities.
`• Region 214 is designed
`to promote excitation of
`neutral atoms from a
`feed gas for transport
`into region 252, where
`the excited atoms are
`then ionized by the high
`power pulses applied to
`electrodes 202a, 226.
`
`‘652 Patent at 4:31-‐37; 13:42-‐47.
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`5
`
`
`
`‘652 Patent
`
`• Region 214 is
`shaped to act as a
`conduit so that the
`newly formed ions
`are transported into
`adjacent region 252
`where a second
`power supply
`applies high power
`pulses to electrode
`202a to thereby
`launch additional
`power into the
`transported mixture
`in the region to
`super-‐ionize it.
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`‘652 Patent at 6:50-‐52;
`10:10-‐12; 11:54-‐57;
`14:37-‐65; 16:24-‐30.
`
`6
`
`
`
`‘652 Patent
`
`• All claims of the ‘652
`patent require super-‐
`ionizing the initial plasma
`so as to generate a high-‐
`density plasma.
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`7
`
`
`
`Petitioner Fails to Address the Claimed
`“Super-‐Ionization” as Construed by the
`Board.
`
`Super-‐ionizing an initial
`plasma so as to generate a
`high-‐density plasma means,
`“converting at least 75% of the
`neutral atoms in the initial
`plasma into ions.”
`
`Decision at pp. 10-‐11.
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`8
`
`
`
`Petitioner Fails to Prove that Mozgrin Teaches
`the Claimed “Super-‐Ionization” As Construed
`by the Board
`
`A person of ordinary skill in the art would have
`understood that if Mozgrin’s neutral gas
`density were about 2.0 x 1015 atoms cm-‐3 or
`smaller, then at least 75% of the neutral argon
`gas would have been ionized, i.e., the degree
`of ionization is 75%, which in Mozgrin’s case is
`1.5x1015 ions cm-‐3 divided by 2.0x1015 atoms
`cm-‐3.
`
`Kortshagen Declaration
`Ex. 1002 at ¶ 72.
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`9
`
`
`
`‘652 Patent
`
`Claims 18 – 35 of the ‘652
`patent require transporting an
`initial plasma to a location
`proximate a cathode assembly
`where the initial plasma is
`super-‐ionized.
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`10
`
`
`
`Mozgrin:
`
`The Parties Agree that Mozgrin Does Not Teach or Suggest
`the Claimed Transportation Technique
`
`• Mozgrin (the alleged structure for super-‐ionization) “does not suggest
`any external source of an initial plasma.” (Hartsough Declaration, par.
`91)
`
`•
`
`•
`
`“Instead, the pre-‐ionized gas created by Mozgrin’s DC voltage
`apparently remains in the same location when Mozgrin’s High-‐Voltage
`component superimposes the voltage pulse across the electrodes to
`thereby grow the density of the pre-‐ionized gas.” (Hartsough
`Declaration, par. 91)
`
`The Petitioners cite to Iwamura and Fahey for the claimed
`transportation, but neither reference teaches or suggests combining an
`external plasma source to Mozgrin for transporting an initial plasma to
`Mozgrin for super-‐ionization (see slides that follow)
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`11
`
`
`
`Iwamura:
`
`Teaches Reducing Ion Density
`-‐ Not Super-‐Ionization
`
`Iwamura proposes a two-‐stage approach for
`the purpose of generating a desired “neutral
`activated gas species” while reducing the
`density and energy level of incidental ions so
`as not to damage the substrate.
`
`Iwamura therefore contains no suggestion to
`combine his two-‐stage approach with Mozgrin
`for the claimed purpose of Super-‐Ionizing an
`initial plasma. (see representative supporting evidence
`in the following slides)
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`Iwamura at 4:50-‐53
`
`12
`
`
`
`Iwamura:
`
`Iwamura’s Goal Is To Generate Neutral
`Activated Species
`
`•
`
`“The object to be treated is treated by the activated gas species.”
`(Iwamura, Abstract).
`
`• The desired “activated species” are electrically neutral. (Kortshagen
`Deposition, at Ex. 2004, 60:4-‐16, Hartsough Declaration, Ex. 2002, Par. 70
`– 72).
`
`• A plasma (which contains ions) was used to generate the desired neutral
`activated species, but Iwamura tries to reduce the density and energy
`level of these incidental ions (see next slide)
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`13
`
`
`
`Iwamura:
`
`Iwamura Wants To Reduce Density and
`Energy Level of the Transported Ions
`
`Iwamura proposes removing ions so that “only neutral activated gas species” are
`directed toward the object to be treated.
`“Thus, the charged particles captured by the grounded electrode, and only
`neutral activated gas species are directed toward the object to be treated. This
`prevents charging and damage to the object to be treated caused by exposure
`to ions.” (Iwamura, col. 4, lines 48 – 54).
`
`Iwamura also proposes reducing the power applied in the second stage where the
`object is treated.
`
`See Hartsough Declaration, Par. 79 – 81 regarding power reduction.
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`14
`
`
`
`Fahey:
`
`Fahey is Not In The Field of Plasma Sources
`
`• A device for generating a beam of
`“metastable atoms” (i.e., neutral atoms)
`(Fahey at 381)
`.
`
`•
`
`•
`
`“It is correct that Fahey is a reference that
`is not geared towards super-‐ionization . . .
`.” (Kortshagen Deposition, Ex. 2003 at
`86:13 – 18 (emphasis added))
`
`“Fahey is not in the field of high-‐density
`plasma sources.” (Hartsough Declaration,
`Ex. 2002 at ¶ 67)
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`
`
`Fahey:
`
`Incidental Ions Should be Removed
`From the Atom Beam
`
`As in Iwamura, any incidental ions in
`Fahey’s beam were undesirable and
`therefore Fahey removed them when
`measuring the atom beam:
`
`.
`
`“For all diagnostic measurements, the
`beam was kept free of charged species
`by maintaining an adequate voltage on
`a set of parallel sweep plates.” (Fahey
`at 382).
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`16
`
`
`
`Claim 5 – An RF Power Supply to
`Super-‐Ionize the Initial Plasma
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`17
`
`
`
`Claim 5 – An RF Power Supply to
`Super-‐Ionize the Initial Plasma
`
`Petition at 38.
`
`GlobalFoundries et al. v. Zond
`IPR2014-‐00861, IPR2014-‐01088
`& IPR2014-‐01089
`Zond Ex. 2005
`
`18
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