UNITED STATES PATENT AND TRADEMARK OFFICE
`__________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________
`
`
`
`LAM RESEARCH CORP.,
`
`Petitioner
`
`v.
`
`DANIEL L. FLAMM,
`
`Patent Owner
`___________
`
`Case IPR2015-01767
`U.S. Patent No. 6,017,221
`
`Issued: January 5, 2000
`
`Named Inventor: Daniel L. Flamm
`
`Title: PROCESS DEPENDING ON PLASMA
`DISCHARGES SUSTAINED BY INDUCTIVE COUPLING
`___________
`
`DECLARATION OF JOSEPH L. CECCHI IN SUPPORT OF
`PETITIONER'S REPLY
`
`
`
`
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`9889037
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`LAM Ex 1022-p. 1
`LAM v FLAMM
`IPR2015-01767
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`__________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________
`
`
`
`LAM RESEARCH CORP.,
`
`Petitioner
`
`v.
`
`DANIEL L. FLAMM,
`
`Patent Owner
`___________
`
`Case IPR2015-01767
`U.S. Patent No. 6,017,221
`
`Issued: January 5, 2000
`
`Named Inventor: Daniel L. Flamm
`
`Title: PROCESS DEPENDING ON PLASMA
`DISCHARGES SUSTAINED BY INDUCTIVE COUPLING
`___________
`
`DECLARATION OF JOSEPH L. CECCHI IN SUPPORT OF
`PETITIONER'S REPLY
`
`
`
`
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`9889037
`
`
`
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`LAM Ex 1022-p. 1
`LAM v FLAMM
`IPR2015-01767
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`
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`IPR Case No. IPR2015-01767
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`
`I, Joseph L. Cecchi, declare as follows:
`
`
`
`
` U.S. Patent No. 6,017,221
` Declaration for Reply
`
`I.
`
`INTRODUCTION
`1.
`
`I am over 18 years of age and otherwise competent to make this
`
`Declaration.
`
`2.
`
`I have been asked to provide my views regarding technical issues in
`
`connection with the above-captioned inter partes review of U.S. Patent No.
`
`6,017,221 ("the '221 patent"). I opine only with respect to certain issues that are
`
`discussed in this declaration.
`
`3.
`
`I previously submitted a declaration in support of the petition for
`
`IPR2015-01767, which the Patent Trial and Appeal Board instituted. Ex. 1007. I
`
`now submit this declaration in support of Petitioner's Reply.
`
`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`4.
`I am currently Dean of the School of Engineering and Professor of
`
`Chemical and Biological Engineering at the University of New Mexico ("UNM").
`
`This is my second term as Dean, and the term began in February 2014. I have held
`
`my appointment as Professor since joining UNM in 1994.
`
`5.
`
`From 2011 to 2012, while on leave from UNM, I served as Provost
`
`and Professor of Engineering at the Masdar Institute of Science and Technology in
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`Abu Dhabi, United Arab Emirates.
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`IPR Case No. IPR2015-01767
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` U.S. Patent No. 6,017,221
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` Declaration for Reply
`
`
`6. My first appointment as Dean of the School of Engineering extended
`
`from 2000 to 2009. From 2004 to 2011, I was Chair of the Board of Directors of
`
`the Science and Technology Corp. at UNM, the university's technology transfer
`
`organization responsible for patenting and licensing UNM's intellectual property.
`
`7.
`
`From 1994 until 2000, I was Chair of the Department of Chemical and
`
`Nuclear Engineering at UNM. Previously, I was a Lecturer with the rank of
`
`Professor in the Department of Chemical Engineering at Princeton University,
`
`where I also directed the Graduate Program in Plasma Science and Technology. I
`
`was associated with the Plasma Physics Laboratory at Princeton University for
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`twenty-one years, as leader of the Plasma Processing Group (1987-1994); Principal
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`Research Physicist (1984-1994); leader of the Materials Physics Group (1979-
`
`1987); Research Physicist (1978-1984); and Staff Physicist (1972-1978).
`
`8.
`
`From 1991 to 1994, I was Director of the New Jersey SEMATECH
`
`Center of Excellence for Plasma Etching. This organization, which involved four
`
`universities and one industrial laboratory, was engaged in state-of-the-art research
`
`in plasma processing for semiconductor manufacturing.
`
`9.
`
`From 1992 to 2001, I worked on three committees established by the
`
`Semiconductor Industry Association ("SIA") to generate technology "roadmaps"
`
`for semiconductor manufacturing. Most recently, from 1998 to 2000, I was a
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`IPR Case No. IPR2015-01767
` Declaration for Reply
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`
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`member of the Interconnect Technical Working Group ("TWG") for the SIA
`
`International Technology Roadmap for Semiconductors ("ITRS").
`
`10.
`
`I obtained my Ph.D. in physics from Harvard University in 1972. I
`
`also received a Master's degree in physics from Harvard University in 1969, a
`
`Bachelor's degree in physics from Knox College in 1968, and a Master's of
`
`Business Administration (MBA) degree from the University of New Mexico in
`
`2011.
`
`11.
`
`I have had significant research experience in a number of areas
`
`pertaining to semiconductor devices and their manufacturing, including plasma
`
`physics, plasma chemistry, plasma etching, plasma enhanced chemical vapor
`
`deposition (PECVD), atomic layer deposition (ALD), which is a form of chemical
`
`vapor deposition, plasma-assisted ALD, and chemical-mechanical-polishing
`
`(CMP), sometimes called "chemical-mechanical-planarization".
`
`12.
`
`I have published over ninety papers in my fields of expertise. Among
`
`the eight United States patents on which I am an inventor, the following five
`
`patents are in the area of plasma technology for manufacturing semiconductors and
`
`other materials:
`
`
`
`"Method and Apparatus for Coupling a Microwave Source in an
`
`Electron Cyclotron Resonance System," U.S. Patent No. 5,111,111,
`
`Issued September 30, 1991.
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`IPR Case No. IPR2015-01767
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` U.S. Patent No. 6,017,221
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`
` Declaration for Reply
`
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`"Apparatus and Method for Uniform Microwave Plasma Processing
`
`
`
`
`
`
`
`Using TE11 and TM01 Modes," U.S. Patent No. 5,302,803, Issued
`
`April 12, 1994.
`
`"Apparatus and Process for Producing High Density Axially Extended
`
`Plasmas," U.S. Patent No. 5,587,038, Issued December 24, 1996.
`
`"Method of Making Dense, Conformal, Ultra-Thin Cap layers for
`
`Nanoporous Low-k ILD by Plasma Assisted Atomic Layer
`
`Deposition," U.S. Patent No. 7,947,579, Issued May 24, 2011.
`
`
`
`"Ultra-Thin Microporous/Hybrid Materials," U.S. Patent No.
`
`8,187,678, Issued May 29, 2012.
`
`13.
`
`I have been elected as a fellow in AVS, The Society for the Science
`
`and Technology of Materials, Interfaces, and Processing.
`
`14.
`
`I am aware of research and development activities ongoing in
`
`semiconductor manufacturing and devices since the 1980s time frame. As a result
`
`of my research experience in the plasma etching, deposition, and CMP areas, I am
`
`also familiar with other silicon semiconductor process technologies that directly
`
`impact these areas, including such things as lithography and cleaning techniques.
`
`15. As a professor, I have taught courses in silicon semiconductor devices
`
`and process technology at undergraduate and graduate levels. Many of the
`
`students I have taught have gone on to work for companies engaged in
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` U.S. Patent No. 6,017,221
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`IPR Case No. IPR2015-01767
` Declaration for Reply
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`semiconductor manufacturing. I have supervised the research of a number of
`
`students in semiconductor manufacturing as part of their work for their M.S. and
`
`Ph.D. degrees.
`
`16. My curriculum vitae (CV) (Exhibit 1011) includes additional details
`
`about my experience and professional background.
`
`17. The '221 patent generally relates to radio frequency (rf) powered
`
`inductively-coupled plasma source for semiconductor processing, including a
`
`method for minimizing undesirable capacitive coupling of the rf power to the
`
`plasma. In the method, undesirable capacitive coupling is reduced by adjusting
`
`phase and anti-phase portions of capacitively coupled currents. A so-called wave
`
`adjustment circuit is employed to selectively balance the phase and anti-phase
`
`portions. Ex. 1001.
`
`18. The specification of the '221 patent discloses that "[p]referably, the
`
`plasma discharge is derived from the inductively couple plasma source that is a de-
`
`coupled plasma source ('DPS') or a helical resonator, though other sources can be
`
`employed." Id. at 4:4-7. These types of plasma sources are among the so-called
`
`"high density plasma sources" that are particularly well suited for plasma etching
`
`and plasma assisted chemical vapor deposition of submicron features characteristic
`
`of semiconductor manufacturing in the 1994 time frame and beyond. See, e.g., Ex.
`
`1002 [Lieberman93] at pp. 10-11; Ex. 1012 [Lieberman94] at pp. 9-13 and Fig. 3.
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`IPR Case No. IPR2015-01767
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` U.S. Patent No. 6,017,221
`
`
` Declaration for Reply
`
`
`In my research, I have designed, constructed, and used de-coupled
`
`19.
`
`plasma sources, including inductively coupled plasma sources, helicon plasma
`
`sources, and electron cyclotron resonance (ECR) plasma sources. These sources
`
`are also high-density plasma sources. I have used these plasma sources for plasma
`
`etching and plasma assisted chemical vapor deposition. For example, publication
`
`74 in my CV (Ex. 1011 at 15), describes a plasma processing apparatus, including
`
`an electron cyclotron resonance (ECR) plasma source used for plasma etching of
`
`polysilicon, silicon dioxide and silicon. The plasma processing apparatus, shown
`
`in Figure 1 of this publication, includes an ECR source chamber and a downstream
`
`processing chamber.
`
`20. Publications 75 and 77 in my CV (Ex. 1011 at 15), describe improved
`
`operational characteristics of an ECR plasma etch reactor based on optimizing the
`
`coupling of the microwave power to the plasma. The optimized coupler included a
`
`dielectric window that functioned as a transmission line that adjusted the phase of
`
`the microwaves to match to the plasma. The optimized coupling reduced the
`
`reflected power to less than 5% of the incident power without external tuning,
`
`simplifying control of the plasma operation. This work underpins U.S. Patent,
`
`5,111,111, on which I am co-inventor.
`
`21. Publications 78 and 79 in my CV (Ex. 1011 at 15) describe a method
`
`for producing more uniform plasmas in ECR plasma etch reactors. The method
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`IPR2015-01767
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` U.S. Patent No. 6,017,221
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`IPR Case No. IPR2015-01767
` Declaration for Reply
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`involves increasing the magnetic field of the ECR reactor such that the microwave
`
`power is absorbed in the plasma further from the dielectric window. An important
`
`result of this work is that the etch rate uniformity across the surface of a wafer is
`
`correlated with the plasma uniformity, so that improving plasma uniformity
`
`resulted in a more uniform etch across the wafer being etched.
`
`22. Publications 79 in my CV (Ex. 1011 at 15) describes another method
`
`for producing more uniform plasmas in ECR plasma etch reactors, based on
`
`multiplexing two different microwave modes in the transmission waveguide used
`
`to introduce the microwave power into the ECR reactor. The result of mixing the
`
`two modes was a more uniform deposition of the microwave power across the
`
`reactor. This work is the basis for U.S. Patent, 5,302,803, on which I am co-
`
`inventor.
`
`23. Publications 81 in my CV (Ex. 1011 at 16) describes a method for
`
`providing an independent radio frequency (rf) wafer biasing on the wafer chuck in
`
`a manner that produces more uniform ion bombardment across substrates being
`
`processed. This work shows that using a lower rf frequency for wafer biasing
`
`results in a more uniform distribution of ion bombardment across the wafer.
`
`24. Publication 82 in my CV (Ex. 1011 at 16) discloses a new type of
`
`high-density decoupled plasma source in which a flat inductive coil in the presence
`
`of a low magnetic field launches a helicon wave that sustains a plasma that has
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` U.S. Patent No. 6,017,221
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`IPR Case No. IPR2015-01767
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`
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`greater axial extension compared to a conventional inductively couple plasma.
`
`This work is the basis for U.S. Patent 5,587,038 on which I am co-inventor.
`
`25. As further examples, publications 92, 93, and 94 in my CV (Ex. 1011
`
`at 17) relate to a process of plasma-assisted atomic layer deposition, which is a
`
`form of plasma-assisted chemical vapor deposition that provides layer-by-layer
`
`control of thin film deposition. An inductively coupled plasma source was used in
`
`this work. Publications 92 and 93 describe how plasma-assisted atomic layer
`
`deposition of silicon dioxide can be applied to producing a material that can be
`
`used for interlevel dielectrics between conductors in integrated circuits. These
`
`plasma processes are also the subject matter in U.S. Patent Nos. 7,947,579 and
`
`8,187,678, on which I am an inventor.
`
`26.
`
`I am being compensated for my time at my standard hourly rate of
`
`$450 in connection with this proceeding. My compensation is in no way
`
`contingent upon my performance or the outcome of this case.
`
`27.
`
`I have been asked my technical opinions regarding the understanding
`
`of a person of ordinary skill in the art (discussed below) as it relates to the '221
`
`patent and other reference documents.
`
`28.
`
`I have also been asked to provide my technical opinions on concepts
`
`discussed in the '221 patent and other reference documents, as well as my technical
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` U.S. Patent No. 6,017,221
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`IPR Case No. IPR2015-01767
` Declaration for Reply
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`opinions on how these concepts relate to several claim limitations of the '221
`
`patent in the context of the specification.
`
`29.
`
`In reaching the opinions stated herein, I have considered the '221
`
`patent, its prosecution history, the references listed in the table below, the Patent
`
`Owner's Preliminary Response (Paper 9), the Board's Institution Decision (Paper
`
`10), the Patent Owner Response (Paper 15), the Declaration of Daniel L. Flamm
`
`(Ex. 2001), and have also drawn as appropriate upon my own education, training,
`
`research, knowledge, and personal and professional experience.
`
`Description
`Exhibit
`1001 U.S. Patent No. 6,017,221 (the '221 patent)
`
`1002 Michael A. Lieberman and Richard A. Gottscho, Design of High Density Plasma
`Sources for Materials Processing, UNIVERSITY OF CALIFORNIA, BERKELEY
`TECHNICAL REPORT NO. UCB/ERL M93/3 (JANUARY 11, 1993) (on file with the
`University of California, Berkeley Library) (Lieberman93)
`
`1003 U.S. Patent No. 5,573,595 (Dible)
`
`1004 U.S. Patent No. 4,877,999 (Knapp)
`
`1005 U.S. Patent No. 5,065,118 (Collins)
`
`1006
`
`J. Hopwood, Review of Inductively Coupled Plasmas for Plasma Processing,
`Plasma Sources Sci. Technol. 1, 109-116 (1992) (Hopwood)
`
`1007 Declaration of Joseph L. Cecchi, Ph.D.
`
`1008 Merriam-Webster's Collegiate Dictionary, Eleventh Edition, 2012
`
`1009
`
`'221 Patent Prosecution History, 10/2/98 Office Action and 4/2/99 Response
`
`1010 Declaration of Miyoko Tsubamoto
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`IPR Case No. IPR2015-01767
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` U.S. Patent No. 6,017,221
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`
` Declaration for Reply
`
`
`1012 Michael A. Lieberman and Richard A. Gottscho, Design of High-Density Plasma
`Sources for Materials Processing, PLASMA SOURCES FOR THIN FILM DEPOSITION
`AND ETCHING (PHYSICS OF THIN FILMS VOLUME 18), August 1994 (Lieberman94)
`
`1013 Publisher's Webpage for PLASMA SOURCES FOR THIN FILM DEPOSITION AND
`ETCHING (1st Edition),
`http://store.elsevier.com/product.jsp?isbn=9780125330183&_requestid=1611063
`(last visited Aug. 13, 2015).
`
`1014 Declaration of Morgan Chu In Support of LAM's Unopposed Motion for Pro
`Hac Vice Admission
`
`1015 Declaration of Talin Gordnia In Support of LAM's Unopposed Motion for Pro
`Hac Vice Admission
`
`1016
`
`"Balun Transformers",
`https://www.minicircuits.com/pages/BalunApplicatioNote.htm (printed June 17,
`2016).
`
`1017 THE RADIO HANDBOOK, Ed. William I. Orr (16th edition) (1962).
`
`1018 U.S. Patent RE40,264 E
`
`1019 Figure 3(b)
`
`1020 Figures 3(a)
`
`1021 Deposition of Daniel L. Flamm, Sc. D., Oakland, California, Tuesday, July 26,
`2016
`
`1023 Rudolf F. Graf, MODERN DICTIONARY OF ELECTRONICS (6th edition) (1984)
`
`1024 Doug Jorgesen and Christopher Marki, "Balun Basics Primer, A Tutorial on
`Baluns, Balun Transformers, Magic-Ts, and 180o Hybrids," Marki Microwave
`(2014).
`
`III. PERSON HAVING ORDINARY SKILL IN THE ART
`30.
`I have approached my analysis of the '221 patent from the perspective
`
`of a person having ordinary skill in the art (a PHOSITA) at the time of the
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`IPR Case No. IPR2015-01767
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`
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`purported invention of the '221 patent, which I have been informed is December 4,
`
`1995, the earliest priority date recited by the '221 patent.
`
`31.
`
`I have been informed by counsel that a person having ordinary skill in
`
`the art is a hypothetical person who is presumed to have known all of the relevant
`
`art at the time of the invention. Factors that may be considered in determining the
`
`level of ordinary skill in the art may include: (1) type of problems encountered in
`
`the art; (2) prior art solutions to those problems; (3) rapidity with which
`
`innovations are made; (4) sophistication of the technology; and (5) educational
`
`level of active workers in the field. I have been informed by counsel that it is from
`
`the viewpoint of a person of ordinary skill in the art that determined patentability.
`
`32. Based on these factors, in my opinion, a person having ordinary skill
`
`in the art of the '221 patent would generally have had either (i) a Bachelor's degree
`
`in engineering, physics, chemistry, materials science, or a similar field, and three
`
`or four years of work experience in semiconductor manufacturing or related fields,
`
`or (ii) a Master's degree in engineering, physics, chemistry, materials science, or a
`
`similar field and two or three years of work experience in semiconductor
`
`manufacturing or related fields.
`
`33. Based on this understanding of a PHOSITA for the '221 patent, I
`
`believe that I am at least a person having ordinary skill in the art for purposes of
`
`the '221 patent. For example, my qualifications and experiences discussed in
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`IPR Case No. IPR2015-01767
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`Section II above, and in my CV (Ex. 1011), demonstrate my familiarity with and
`
`knowledge of the art of the '221 patent. I therefore believe that I am qualified to
`
`offer this declaration as to how such a person would have interpreted the '221
`
`patent and the prior art on or about December 4, 1995. Unless otherwise stated,
`
`my statements below refer to the knowledge, beliefs and abilities of a person
`
`having ordinary skill in the art of the '221 patent at the time of the purported
`
`invention of the '221 patent.
`
`IV. RELEVANT LEGAL STANDARDS
`34. My opinions are informed by my understanding of the relevant law. I
`
`understand that the patentability analysis is conducted on a claim-by-claim basis.
`
`35.
`
`I understand that in proceedings before the USPTO, the claims of an
`
`unexpired patent are to be given their broadest reasonable interpretation in view of
`
`the specification from the perspective of a person having ordinary skill in the art. I
`
`understand that the '221 patent has not expired.
`
`36.
`
`I understand that a single piece of prior art "anticipates" a claim if
`
`each and every element of the claim is disclosed in that prior art. I further
`
`understand that, where a claim element is not explicitly disclosed in a prior art
`
`reference, the reference may nonetheless anticipate a claim if the missing claim
`
`element is necessarily present in the apparatus or a natural result of the method
`
`disclosed—i.e., if the missing element is "inherent."
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`IPR Case No. IPR2015-01767
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` U.S. Patent No. 6,017,221
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` Declaration for Reply
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`I understand that the prior art may render a patent claim "obvious." I
`
`37.
`
`understand that two or more pieces of prior art that each disclose fewer than all
`
`elements of a patent claim may nevertheless be combined to render a patent claim
`
`obvious if the combination of the prior art collectively discloses all elements of the
`
`claim and a person having ordinary skill in the art at the time would have had
`
`reason to combine the prior art. I understand that this reason to combine need not
`
`be explicit in any of the prior art, but may be inferred from the knowledge of a
`
`person having ordinary skill in the art at the time the patent application was filed. I
`
`also understand that a person having ordinary skill in the art is not an automaton,
`
`but is a person having ordinary creativity. I further understand that one or more
`
`pieces of prior art that disclose fewer than all of the elements of a patent claim may
`
`render a patent claim obvious if including the missing element would have been
`
`obvious to a person having ordinary skill in the art (e.g., the missing element
`
`represents only an insubstantial difference over the prior art or a reconfiguration of
`
`a known system).
`
`38.
`
`I understand that a patent claim is obvious if the differences between
`
`the subject matter claimed and the prior art are such that the subject matter as a
`
`whole would have been obvious at the time the alleged invention was made. I
`
`understand that the obviousness analysis must focus on the knowledge available to
`
`one of skill in the art at the time of the alleged invention in order to avoid
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`IPR Case No. IPR2015-01767
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`impermissible hindsight. I further understand that the obviousness inquiry assumes
`
`that the person having ordinary skill in the art would have knowledge of all
`
`relevant references available at the time of the alleged invention.
`
`39.
`
`I also understand that the USPTO has identified exemplary rationales
`
`that may support a conclusion of obviousness, and I have considered those
`
`rationales in my analysis. The rationales include:
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`
`
`
`
`
`
`
`
`
`
`Combining prior art elements according to known methods to yield
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`predictable results;
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`Simple substitution of one known element for another to obtain
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`predictable results;
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`Use of known technique to improve similar devices (methods or
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`products) in the same way;
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`Applying a known technique to a known device (methods or products)
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`ready for improvement to yield predictable results;
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`Choosing from a finite number of identified, predictable solutions,
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`with a reasonable expectation of success, such that the effort was
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`"obvious to try";
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`
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`Known work in one field of endeavor that may prompt variations on
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`the work for use in either the same field or a different one based on
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`9889037
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`- 14 -
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`
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`LAM Ex 1022-p. 15
`LAM v FLAMM
`IPR2015-01767
`
`
`
`IPR Case No. IPR2015-01767
`
`
` U.S. Patent No. 6,017,221
`
`
` Declaration for Reply
`
`
`design incentives or other market forces if the variations are
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`predictable to a person having ordinary skill in the art;
`
`
`
`Some teaching, suggestion, or motivation in the prior art that would
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`have led a person having ordinary skill in the art to modify the prior
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`art reference or to combine prior art reference teachings to arrive at
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`the claimed invention.
`
`40.
`
`I appreciate that secondary considerations may be considered, if
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`present, as part of the overall obviousness analysis. Such considerations do not
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`appear to be present here:
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`
`
`
`
`
`
`I have never heard anyone offer praise for the '221 patent, nor am I
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`aware of any commercial success attributable to the '221 patent.
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`I am also unaware of any copying of the alleged invention of the '221
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`patent.
`
`I am unaware of any use to which the owner of the '221 patent has put
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`the patent except to assert it in litigation.
`
`V. THE '221 PATENT
`41.
`I understand Lam is challenging claims 1-7 ("challenged claims") of
`
`the '221 patent.
`
`42.
`
`In my opinion, the challenged claims are all directed to a method for
`
`minimizing undesirable capacitive coupling of an inductively-coupled plasma
`
`9889037
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`- 15 -
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`
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`LAM Ex 1022-p. 16
`LAM v FLAMM
`IPR2015-01767
`
`
`
` U.S. Patent No. 6,017,221
`
`
`IPR Case No. IPR2015-01767
` Declaration for Reply
`
`
`
`source for semiconductor processing. In the method, undesirable capacitive
`
`coupling is reduced by adjusting phase and anti-phase portions of capacitively
`
`coupled currents. A so-called wave adjustment circuit is employed to selectively
`
`balance the phase and anti-phase portions.
`
`43.
`
`I understand that the '221 patent is a continuation-in-part of a U.S.
`
`patent application filed on October 23, 1996 (now abandoned) which, in turn,
`
`claims priority to another application filed on December 4, 1995 (also abandoned).
`
`Ex. 1001-1. I understand that no matter which of these dates Flamm may rely on
`
`as the priority date of the '221 patent, the references relied upon in this Petition are
`
`prior art to the '221 patent because they all predate Dec. 4, 1995, the earliest
`
`possible priority date recited by the '221 patent.
`
`A. Representative Claim 1
`44. The crux of the alleged invention of the '221 patent is the
`
`straightforward and well-known process of minimizing undesirable capacitive
`
`coupling of an inductively-coupled plasma source for semiconductor processing.
`
`For example, claim 1 recites a process comprising (a) "subjecting a substrate to
`
`entities, at least one of said entities emanating from a gaseous discharge excited by
`
`a high frequency field from an inductive coupling structure," (b) "in which a phase
`
`portion and an anti-phase portion of capacitive currents coupled from the inductive
`
`coupling structure are selectively balanced;" and (c) "wherein said inductive
`
`9889037
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`- 16 -
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`
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`LAM Ex 1022-p. 17
`LAM v FLAMM
`IPR2015-01767
`
`
`
` U.S. Patent No. 6,017,221
`
`
`IPR Case No. IPR2015-01767
` Declaration for Reply
`
`
`
`coupling structure is adjusted using a wave adjustment circuit, said wave
`
`adjustment circuit adjusting the phase portion and the anti-phase portion of the
`
`capacitively coupled currents." Ex. 1001 at 22:58-23:2.
`
`B.
`
`The '221 Patent Disclosure
`1.
`Inductively-Coupled Plasma Source
`45. The '221 patent discusses "plasma processing of devices using an
`
`inductive discharge," such processing including, for example, "plasma etching and
`
`resist stripping of semiconductor devices. . . . [and] chemical vapor deposition
`
`(CVD) of semiconductor devices." Ex. 1001 ['221 patent] at 1:16-21. "These
`
`plasma processing techniques often rely upon radio frequency power (rf) supplied
`
`to an inductive coil for providing power to gas phase species in forming a plasma."
`
`Id. at 1:33-36.
`
`9889037
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`- 17 -
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`
`
`LAM Ex 1022-p. 18
`LAM v FLAMM
`IPR2015-01767
`
`
`
`IPR Case No. IPR2015-01767
`
`
` U.S. Patent No. 6,017,221
`
`
` Declaration for Reply
`
`
`Capacitively Coupled Currents
`
`2.
`
`
`
`46. The '221 patent describes how, in an inductively-coupled plasma
`
`source configuration, "capacitive coupling between high voltage selections of the
`
`coil and the plasma discharge often cause high and uncontrollable plasma
`
`potentials relative to ground," which, in turn, "can cause damaging high energy ion
`
`bombardment of articles being processed by the plasma." Id. at 2:66-3:5.
`
`"Consequently, uncontrolled potential differences, such as that caused by 'stray'
`
`capacitive coupling from the coil of an inductive plasma source to the plasma, are
`
`undesirable." Id. at 4:37-39.
`
`9889037
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`- 18 -
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`
`
`LAM Ex 1022-p. 19
`LAM v FLAMM
`IPR2015-01767
`
`
`
`IPR Case No. IPR2015-01767
`
`
` U.S. Patent No. 6,017,221
`
`
` Declaration for Reply
`
`
`Phase and Anti-Phase Portions of the Capacitively Coupled
`Currents
`47. The '221 patent discusses reducing undesirable capacitively coupled
`
`3.
`
`currents by selectively adjusting phase and anti-phase portions of an excitation
`
`signal. It states, "[s]ince the capacitive current increases monotonically with the
`
`magnitude of the difference of peak phase and anti-phase voltages, which occur at
`
`points A and C in FIG. 2A, this coupling can be lessened by reducing this voltage
`
`difference." Ex. 1001 ['221 patent] at 10:31-35. Referring to Fig. 2A of the '221
`
`patent, reproduced above, the phase and anti-phase components of the voltage are
`
`represented, respectively, at reference numerals 70 and 71. Capacitive coupling is
`
`reduced by setting "substantially zero AC voltage at one point on the inductive coil
`
`(refer to point 00 in FIG. 2A)," corresponding to "substantially equal phase 70 and
`
`anti-phase voltage distributions in directions about this point (refer to 00-A and 00-
`
`C in FIG. 2A) and provides substantially equal capacitance coupling to the plasma
`
`from physical inductor elements (00-C) and (00-A), carrying the phase and anti-
`
`phase potentials." Id. at 10:14-22.
`
`4. Wave Adjustment Circuit
`48. The '221 patent discusses adjusting phase and anti-phase portions of
`
`capacitively coupled currents using wave adjustment circuits. Referring back to
`
`Fig. 2A of the '221 patent, an "upper wave adjustment circuit 57" and a "lower
`
`wave adjustment circuit 59" are shown connected to the "inductive applicator 55."
`
`9889037
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`- 19 -
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`LAM Ex 1022-p. 20
`LAM v FLAMM
`IPR2015-01767
`
`
`
` U.S. Patent No. 6,017,221
`
`
`IPR Case No. IPR2015-01767
` Declaration for Reply
`
`
`
`Ex. 1001 ['221 patent] at 10:4-6. They are used to achieve the reduction of
`
`undesirable capacitively coupled currents, as "the wave adjustment circuits are
`
`adjusted to provide substantially zero AC voltage at one point on the inductive coil
`
`(refer to point 00 in FIG. 2A)." Id. at 10:14-16. The '221 patent describes several
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`possibilities for the wave adjustment circuit, but chiefly defines it by the role it
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`plays: "A wave adjustment circuit (e.g., RLC circuit, coil, transmission line, etc.) is
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`operably coupled to the plasma applicator. The wave adjustment circuit can
`
`selectively adjust phase and anti-phase potentials of the plasma from an rf power
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`supply." Id. at 7:29-34. As a further disclosed aspect of the '221 patent, the wave
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`adjustment circuit receives an input waveform from the power supply and produces
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`an output waveform, destined for the inductive plasma applicator, which has
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`changed phase and anti-phase portions. Figure 4 of the '221 patent shows a wave
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`adjustment circuit 400 that has an input that is connected to the output of rf power
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`source 122 and has output connected to inductive plasma coil 132. Id. at 16:1-6
`
`and Fig. 4. As a specific embodiment, the specification of the '221 patent describes
`
`a "toroidal transformer . . . coupled between the rf power source 122 and the coil
`
`132," whereby the "(balanced-unbalanced) toroidal transformer (i.e., broadband
`
`transmission transformer, broadband transformer, etc.) 401 can be used to provide
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`balanced matching." Ex. 1001 ['221 patent] at 16:28-30.
`
`9889037
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`- 20 -
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`
`
`LAM Ex 1022-p. 21
`LAM v FLAMM
`IPR2015-01767
`
`
`
` U.S. Patent No. 6,017,221
`
`
`IPR Case No. IPR2015-01767
` Declaration for Reply
`
`
`
`VI. OPINIONS RELATING TO PETITIONER'S REPLY
`49. As I explain in detail below, it is my opinion that claims 1 and 4-7 of
`
`the '221 patent are unpatentable on the following grounds.
`
`50. Lieberman93 (Ex. 1002) and Lieberman 94 (Ex. 1012) (hereinafter
`
`referred to collectively as "Lieberman") teach that driving the inductive coil "push-
`
`pull using a balanced transformer . . . places a virtual ground in the middle of the
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`coil . . . . [which] reduces the undesired capacitively coupled rf currents flowing
`
`from coil to plasma by a factor of two." Ex. 1002 at 23; Ex. 1012 at 53. In my
`
`opinion, a PHOSITA would recognize that Lieberman's push-pull configuration
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`"plac[ing] a virtual ground in the middle of the coil" would correspond to an AC
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`voltage waveform on the coil that is symmetric around the center with respect to
`
`positive and negative voltage distributions about the virtual ground. This, in turn,
`
`provides substantially equal phase portion and anti-phase portion of the
`
`capacitively coupled currents. As a result, the phasor vector sum of the phase
`
`portion (a phasor at zero radians) and the
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