UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2014-00818,819,821,827, and 1098
`Patent 6,853,142
`
`PATENT OWNER ZOND LLC’S
`DEMONSTRATIVE EXHIBIT
`
`1
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2014-00818,819,821,827, and 1098
`Patent 6,853,142
`
`PATENT OWNER ZOND LLC’S
`DEMONSTRATIVE EXHIBIT
`
`1
`
`
`
`OBVIOUSNESS
`Claims 1-20, 40 And 42 Are Not Obvious Over Wang
`and Lantsman
`Wang and Lantsman would not have
`taught:
`“a gas line that supplies feed gas to the
`strongly-ionized plasma, the feed gas
`diffusing the strongly-ionized plasma,
`thereby allowing additional power from
`the pulsed power supply to be absorbed
`by the strongly ionized plasma,” As
`Recited In Claim 1 And Similarly in
`Claims 10 and 40
`
`2
`
`
`
`OBVIOUSNESS
`Claims 1-20 And 42 Are Not Obvious Over Wang and
`Lantsman
`Lantsman makes no mention of generating a
`strongly ionized plasma and therefore, cannot
`possibly teach supplying feed gas to strongly-
`ionized plasma (Dr. Hartsough’s Declaration, Exhibit
`2005, ¶ 94).
`
`“Wang’s chamber is a significantly different design
`than the ‘142 patent in that the feed gas in Wang
`enters by the wafer/pedestal electrode, far from
`the high density plasma region 42” (Dr. Hartsough’s
`Declaration, Exhibit 2005, ¶ 94).
`
`3
`
`
`
`OBVIOUSNESS
`Claims 1-20 And 42 Are Not Obvious Over Wang and
`Lantsman
`
`4
`
`
`
`OBVIOUSNESS
`Claims 1-20 And 42 Are Not Obvious Over Wang and
`Lantsman
` Wang, instead of teaching that the feed gas allows
`additional power from the pulsed power supply to be
`absorbed by the strongly ionized plasma as required by
`claims 1 and 10, discloses:
`
`“a sputter working gas such as argon is supplied from a
`gas source 32 through a mass flow controller 34 to a
`region in back of the grounded shield 24. The gas flows
`into the processing region 22 through a gap formed
`between the pedestal 18, the grounded shield 24, and
`10 a clamp ring or plasma focus ring 36 surrounding the
`periphery of the wafer 20” (col. 4, ll. 5-11)
`
`5
`
`
`
`OBVIOUSNESS
`Claims 1-20 And 42 Are Not Obvious Over Wang and
`Lantsman
`FIG. 2C of the ‘142 patent “shows the
`feed gas entering the chamber at 226
`and 220 in the vicinity of the strongly
`ionized plasma so that it can diffuse the
`plasma, thereby allowing additional
`power from the pulsed power supply to
`be absorbed by the strongly ionized
`plasma” (Dr. Hartsough’s Declaration,
`Exhibit 2005, ¶¶ 94 - 101).
`
`6
`
`
`
`OBVIOUSNESS
`Claims 1-20 And 42 Are Not Obvious Over Wang and
`Lantsman
`
`7
`
`
`
`OBVIOUSNESS
`Claim 15 Is Not Obvious Over Wang and Lantsman
`
` Wang and Lantsman would not have taught:
`
`“selecting at least one of a pulse amplitude and a pulse
`width of the electrical pulse in order to cause the
`strongly-ionized plasma to be substantially uniform” As
`Recited In Claim 15
`
` Wang instead teaches:
`
`“that the uniformity of its plasma is limited to the area
`beneath the rotating magnet and is caused by the
`rotating magnet” (Dr. Hartsough’s Declaration, Exhibit
`2005, ¶ 105).
`
`8
`
`
`
`OBVIOUSNESS
`Claim 15 Is Not Obvious Over Wang and Lantsman
`
`9
`
`
`
`OBVIOUSNESS
`Claims 3 and 12 Are Not Obvious Over Wang and
`Lantsman
`Wang and Lantsman would not have taught:
`
`“the gas line supplies additional feed gas that
`exchanges the weakly-ionized plasma while
`applying the electrical pulse across” As Recited In
`Claim 3 And As Similarly Recited In Claim 12
`
`Lantsman does not even teach a pulse and instead
`teaches:
`
`two DC power supplies
`
`10
`
`
`
`OBVIOUSNESS
`Claims 3 and 12 Are Not Obvious Over Wang and
`Lantsman
`
` With respect to Wang:
`
`“even if a skilled artisan would have added feed gas during application of
`Wang’s background power, PB, as alleged by the Petitioner, Wang would still
`not have taught the claim limitation at issue because the claim limitation
`requires adding feed gas while applying an electrical pulse and the
`background power PB is not a pulse.” (Dr. Hartsough’s Declaration, Exhibit
`2005, ¶¶ 107-109).
`
`“Wang’s chamber design does not provide the necessary feed gas flow
`dynamics to exchange the weakly ionized plasma while applying the electrical
`pulse across” (Dr. Hartsough’s Declaration, Exhibit 2005, ¶109).
`
`Wang’s chamber design is shown in FIG. 1 reproduced in slide 9 above
`
`11
`
`
`
`OBVIOUSNESS
`Claims 4 and 22 Are Not Obvious Over Wang and
`Lantsman Or Kudryavtsev
` Neither Wang nor Lantsman teaches:
`“a power supply that supplies power to the weakly-ionized plasma
`through an electrical pulse applied across the weakly-ionized plasma,”
`And “the power supply generates a constant power”
` Wang instead teaches that:
`“FIG 6 is idealized and that the actual shape of the power pulse is most
`accurately described as rounded (Gaussian, hyperbolic secant, or the
`like)” (Dr. Hartsough’s Declaration, Exhibit 2005, ¶ 111)
`
`“the actual waveforms [of FIG. 6] will differ from the idealized ones”
`(Wang, col. 7, ll. 41-42)
`
`“[t]he illustrated pulse form [of FIG. 4] is idealized… significant rise times
`and fall times are expected” (Wang, col. 7, ll. 23-27)
` Lantsman does not disclose a power supply that generates an electrical
`pulse, let alone a pulse that has a constant power (Dr. Hartsough
`Declaration, ¶ 112)
`
`12
`
`
`
`OBVIOUSNESS
`Claim 33 Is Not Obvious Over Wang and Kudryavtsev
`
` Neither Wang nor Kudryavtsev teaches:
`“applying the electric field at a constant power”
` Wang instead teaches that:
`“FIG 6 is idealized and that the actual shape of the power pulse is most
`accurately described as rounded (Gaussian, hyperbolic secant, or the
`like)” (Dr. Hartsough’s Declaration, Exhibit 2005, ¶ 111)
`
`“the actual waveforms [of FIG. 6] will differ from the idealized ones”
`(Wang, col. 7, ll. 41-42)
`
`“[t]he illustrated pulse form [of FIG. 4] is idealized… significant rise times
`and fall times are expected” (Wang, col. 7, ll. 23-27)
` Petitioners provided just ½ page of argument in their Petitioner for claim
`33 and “did not present any explanation as to how a pulsed DC power
`supply would necessarily apply an electric field at constant power” (Dr.
`Hartsough Declaration, ¶ 142)
`
`13
`
`
`
`OBVIOUSNESS
`Claim 25 Is Not Obvious Over Wang and Kudryavtsev
`
`Neither Wang nor Kudryavtsev teaches:
`“a pulsed electric field”
`Petitioners did not demonstrate that this limitation
`is obvious over Wang and Kudryavtsev:
`Provided only an unsupported assertion
`neglecting to consider the factors that effect an
`electric field (Petition, pp. 33-34, and 52)
`
`Unsupported assertions are given little or no
`weight by the Board (Synopsys Inc. v. Mentor
`Graphics Corp., IPR2012-00042, Paper 60, Final
`Decision (P.T.A.B. February 19, 2014), pp. 31-32.
`
`14
`
`
`
`OBVIOUSNESS
`Claims 5, 23, and 34 Are Not Obvious Over Wang and
`Lantsman or Kudryavtsev
` Neither Wang nor Lantsman teaches:
`“the power supply 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. 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)
`
` “Lantsman does not make any mention of a power supply that generates an electrical
`pulse, let alone one that does so with a constant voltage” (Dr. Hartsough Declaration, ¶
`118)
`
`15
`
`
`
`OBVIOUSNESS
`Claims 21-39 And 43 Are Not Obvious Over Wang and
`Kudryavtsev
`Wang and Kudryavtsev would not have
`taught:
`“a cathode that is positioned adjacent to
`the anode and forming a gap there
`between,” As Recited In Claim 21
`Petitioners admitted that “[i]n Wang, the
`cathode 14 and anode 24 are not
`positioned so as to form a gap, as shown
`in the ‘142 patent” (Petition, p. 40)
`
`16
`
`
`
`OBVIOUSNESS
`Claims 21-39 And 43 Are Not Obvious Over Wang and
`Kudryavtsev
`Wang instead teaches a floating shield, located
`between the anode and cathode that directs the
`sputtered ions toward the wafer:
`“a grounded shield 24 protects the chamber walls
`from sputter deposition and also acts as a
`grounded anode for the cathode of the negatively
`biased target 14. A floating shield 26 supported
`on a second dielectric isolator 28 becomes
`negatively charged in the presence of a high-
`density plasma and acts to focus sputtered metal
`ions towards the wafer 20.” (col. 3, l. 64 – col. 4, l.
`5)
`
`17
`
`
`
`OBVIOUSNESS
`Claims 21-39 And 43 Are Not Obvious Over Wang and
`Kudryavtsev
`
`18
`
`
`
`OBVIOUSNESS
`Claims 21-39 And 43 Are Not Obvious Over Wang and
`Kudryavtsev
`Petitioners’ argument that it would have been
`obvious to modify Wang’s device is wrong for two
`reasons:
`It constitutes improper hindsight because it uses
`the ‘142 patent as a blueprint for modifying Wang
`
`The Petitioners failed to demonstrate that such
`modifications to Wang’s device would not have
`rendered Wang’s floating shield unsuitable for its
`intended purpose of focusing the sputtered metal
`ions toward the wafer
`
`19
`
`
`
`OBVIOUSNESS
`Claim 29 Is Not Obvious Over Wang and Kudryavtsev
`
` Neither Wang nor Kudryavtsev teaches that:
`“the ionization source is chosen from the group comprising an electrode coupled to a
`DC power supply” as required by claim 29
`
` Petitioners alleged that:
`
`Wang teaches this claim limitation because “the cathode 14 shown in Wang’s Fig. 1
`satisfies the ‘electrode’ limitation” (Petition, p. 53).
`
` But Wang’s cathode cannot be the claimed “electrode” of claim 29 because claim 21,
`from which claim 29 depends, recites an anode and a cathode and therefore, the
`electrode recited in claim 29 must be something other than the anode or the cathode
`
`FIG. 6a of the ‘142 patent an electrode 452 that is separate and distinct from the
`anode 216 or cathode and is a filament (e.g., a narrow cynlindrical wire like the
`filament in a typical light bulb)
`
`20
`
`
`
`OBVIOUSNESS
`Claim 29 Is Not Obvious Over Wang and Kudryavtsev
`
`21
`
`
`
`OBVIOUSNESS
`Claims 13, 24 and 32 Are Not Obvious Over Wang and
`Kudryavtsev
` Wang and Kudryavtsev do not teach:
`That an electric field across the gap is “a quasi-static electric
`field”
`
`The ‘142 patent defines a quasi-static electric field as “an
`electric field that has characteristic time of electric field
`variation that is much greater than the collision time for
`electrons with neutral gas particles” (‘142 patent, col. 7, ll. 16-
`19)
`
`“Petitioners did not even make any comparison between the
`characteristic time of electric field variation and collision time”
`(Dr. Hartsough’s Declaration, Exhibit 2005, ¶ 130)
`
`22
`
`
`
`OBVIOUSNESS
`Claims 14, 26 and 36 Are Not Obvious Over Wang and
`Kudryavtsev
` Wang and Kudryavtsev do not teach that “selecting at least one of a pulse amplitude and a
`pulse width of the electrical pulse in order to increase an ionization rate of the strongly
`ionized plasma” of claims 14 or 36, or “a rise time of the electric field is chosen to increase an
`ionization rate of the excited atoms in the weakly-ionized plasma” of claim 26:
`
`Petitioners provided less than ½ page of argument in the Petition for the proposed ground
`against claim 26 (Petition, p. 53)
`
`The pulse referenced in Wang by the Petitioners is a power pulse having an unspecified rise
`time: “[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” (Wang, col. 5, ll. 23-26)
`
`“claim 26 recites that a rise time of an electric field is chosen while Wang discloses that a
`rise time power pulse varies with the design of the power supply.” (Dr. Hartsough’s
`Declaration, Exhibit 2005, ¶ 133)
`
` Neither Wang nor Kudryavtsev teach an increase in the ionization rate of the excited atoms
`
`Petitioners argument that “[w]hile Wang’s density is increasing, its ionization rate is
`increasing too” conflates an increase an density with an increased ionization rate
`
`23
`
`
`
`OBVIOUSNESS
`Claims 27, 37, and 38 Are Not Obvious Over Wang and
`Kudryavtsev
` Wang and Kudryavtsev do not teach:
`“the strongly ionized plasma is substantially uniform
`proximate to the cathode,” as recited in claims 27 and
`38
`
`“selecting at least one of a pulse amplitude and a pulse
`width of the electrical pulse in order to cause the
`strongly-ionized plasma to be substantially uniform in an
`area adjacent to a surface of the cathode,” as required
`by dependent claim 37
`
` Wang instead teaches in FIG. 1 that the high density
`plasma (HDP) region only appears below the magnetron
`
`24
`
`
`
`OBVIOUSNESS
`Claims 27, 37, and 38 Are Not Obvious Over Wang, and
`Kudryavtsev
`
`25
`
`
`
`OBVIOUSNESS
`Claims 27, 37, and 38 Are Not Obvious Over Wang and
`Kudryavtsev
` Wang not only fails to teach selection of a pulse
`amplitude or width of an electrical pulse to cause the
`strongly-ionized plasma to be uniform but discloses an
`approach using a magnetron that was distinguished by
`the ‘142 patent:
`
`“Magnetron sputtering systems having homogeneous
`diffusion accelerate ions in the strongly-ionized plasma
`238 towards the surface of the sputtering target in a
`more uniform manner than with conventional
`magnetron puttering. Consequently, the target material
`is deposited more uniformly on a substrate without the
`necessity of rotating th substrate and/or the
`magnetron” (‘142 patent, col. 7, ll. 46-52)
`
`26
`
`
`
`OBVIOUSNESS
`Claim 28 Is Not Obvious Over Wang and Kudryavtsev
`
`Wang and Kudryavtsev would not have taught that:
`“a dimension of the gap between the anode and the
`cathode is chosen to increase an ionization rate of
`the excited atoms in the weakly-ionized plasma,”
`Neither Wang nor Kudryavtsev teach an increase in
`the ionization rate of the excited atoms, let alone
`that the dimension of the gap was chosen to increase
`the ionization rate
`Because Kudryavtsev teaches a distance between the
`electrodes of 52cm, “combining Kudryavtsev with
`Wang would have led one of ordinary skill in the art
`further from the claimed invention of the ‘142
`patent” (Dr. Hartsough’s Declaration, ¶ 138)
`
`27
`
`
`
`OBVIOUSNESS
`Claims 21-39, 41 and 43 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 ‘142 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).
`
`28
`
`
`
`OBVIOUSNESS
`Claims 21-39, 41 and 43 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 ‘142 patent discloses and claims
`an increase in the rate at which
`excited atoms are generated
`
`29
`
`
`
`OBVIOUSNESS
`Claims 21-39, 41 and 43 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 ‘142 patent discloses a “gap 244 is
`between approximately 0.3 cm and 10 cm”
`(col. 5, ll. 44-45)
`
`30
`
`
`
`OBVIOUSNESS
`Claims 1-20, 40 and 42 Are Not Obvious Over Wang and
`Lantsman
`The Petitioners failed to provide any
`objective evidence that combining the
`teachings of Wang and Lantsman would have
`led to a predictable result and achieved the
`claimed invention of the ‘142 patent with a
`reasonable expectation of success:
`Wang discloses that a “target 14 is powered
`by narrow pulses of negative DC power
`supplied from a pulsed DC power supply 80,
`as illustrated in FIG. 1” (col. 5, ll. 18-22)
`Lantsman discloses two DC power supplies.
`
`31
`
`
`
`OBVIOUSNESS
`Claims 1-20, 40 and 42 Are Not Obvious Over Wang and
`Lantsman
`Wang does not mention diffusing
`strongly ionized plasma with feed gas
`(Dr. Hartsough’s Declaration ¶¶ 80-
`84).
`Lantsman does not generate strongly
`ionized plasma; it does not discloses
`the ion density of the plasma (Dr.
`Hartsough’s Declaration ¶¶ 80-84).
`
`32
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2014-00818, 819, 821,827, and 1098
`Patent 6,853,142
`
`END
`
`33
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