UNITED STATES PATENT AND TRADEMARK OFFICE
`__________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________
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`
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`LAM RESEARCH CORP.,
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`Petitioner
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`v.
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`DANIEL L. FLAMM,
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`Patent Owner
`___________
`
`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 PETITION
`FOR INTER PARTES REVIEW OF U.S. PATENT NO. 6,017,221 UNDER 37
`C.F.R. § 1.68
`
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`
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`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`3475040
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`LAM Exh 1007-pg 1
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`__________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________
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`
`
`LAM RESEARCH CORP.,
`
`Petitioner
`
`v.
`
`DANIEL L. FLAMM,
`
`Patent Owner
`___________
`
`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 PETITION
`FOR INTER PARTES REVIEW OF U.S. PATENT NO. 6,017,221 UNDER 37
`C.F.R. § 1.68
`
`
`
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`3475040
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`LAM Exh 1007-pg 1
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`IPR Case No. Unassigned
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`I, Joseph L. Cecchi, declare as follows:
`
`
`
`
` U.S. Patent No. 6,017,221
` Declaration for Petition
`
`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.
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`6,017,221 (“the ‘221 patent”). I opine only with respect to certain issues that are
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`discussed in this declaration.
`
`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`3.
`I am currently Dean of the School of Engineering and Professor of
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`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.
`
`4.
`
`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.
`
`5. 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
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`the Science and Technology Corp. at UNM, the university’s technology transfer
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`organization responsible for patenting and licensing UNM’s intellectual property.
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` Declaration for Petition
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`From 1994 until 2000, I was Chair of the Department of Chemical and
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`6.
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`Nuclear Engineering at UNM. Previously, I was a Lecturer with the rank of
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`Professor in the Department of Chemical Engineering at Princeton University,
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`where I also directed the Graduate Program in Plasma Science and Technology. I
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`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-
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`1987); Research Physicist (1978-1984); and Staff Physicist (1972-1978).
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`7.
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`From 1991 to 1994, I was Director of the New Jersey SEMATECH
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`Center of Excellence for Plasma Etching. This organization, which involved four
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`universities and one industrial laboratory, was engaged in state-of-the-art research
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`in plasma processing for semiconductor manufacturing.
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`8.
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`From 1992 to 2001, I worked on three committees established by the
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`Semiconductor Industry Association (“SIA”) to generate technology “roadmaps”
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`for semiconductor manufacturing. Most recently, from 1998 to 2000, I was a
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`member of the Interconnect Technical Working Group (“TWG”) for the SIA
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`International Technology Roadmap for Semiconductors (“ITRS”).
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`9.
`
`I obtained my Ph.D. in physics from Harvard University in 1972. I
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`also received a Master's degree in physics from Harvard University in 1969, a
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`Bachelor's degree in physics from Knox College in 1968, and a Master's of
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`IPR Case No. Unassigned
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`Business Administration (MBA) degree from the University of New Mexico in
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`2011.
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`10.
`
`I have had significant research experience in a number of areas
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`pertaining to semiconductor devices and their manufacturing, including plasma
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`physics, plasma chemistry, plasma etching, plasma enhanced chemical vapor
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`deposition (PECVD), atomic layer deposition (ALD), which is a form of chemical
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`vapor deposition, plasma-assisted ALD, and chemical-mechanical-polishing
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`(CMP), sometimes called “chemical-mechanical-planarization”.
`
`11.
`
`I have published over ninety papers in my fields of expertise. Among
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`the eight United States patents on which I am an inventor, the following five
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`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.
`
`
`
`“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
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`Plasmas,” U.S. Patent No. 5,587,038, Issued December 24, 1996.
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`IPR Case No. Unassigned
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` Declaration for Petition
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`“Method of Making Dense, Conformal, Ultra-Thin Cap layers for
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`
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`Nanoporous Low-k ILD by Plasma Assisted Atomic Layer
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`Deposition,” U.S. Patent No. 7,947,579, Issued May 24, 2011.
`
`
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`“Ultra-Thin Microporous/Hybrid Materials,” U.S. Patent No.
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`8,187,678, Issued May 29, 2012.
`
`12.
`
`I have been elected as a fellow in AVS, The Society for the Science
`
`and Technology of Materials, Interfaces, and Processing.
`
`13.
`
`I am aware of research and development activities ongoing in
`
`semiconductor manufacturing and devices since the 1980s time frame. As a result
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`of my research experience in the plasma etching, deposition, and CMP areas, I am
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`also familiar with other silicon semiconductor process technologies that directly
`
`impact these areas, including such things as lithography and cleaning techniques.
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`14. 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
`
`semiconductor manufacturing. I have supervised the research of a number of
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`students in semiconductor manufacturing as part of their work for their M.S. and
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`Ph.D. degrees.
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`15. My curriculum vitae (CV) (Exhibit 1011) includes additional details
`
`about my experience and professional background.
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`IPR Case No. Unassigned
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` U.S. Patent No. 6,017,221
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` Declaration for Petition
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`16. 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
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`plasma. In the method, undesirable capacitive coupling is reduced by adjusting
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`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.
`
`17. 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-
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`coupled plasma source (‘DPS’) or a helical resonator, though other sources can be
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`employed.” Id. at 4:4-7. These types of plasma sources are among the so-called
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`“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.
`
`18.
`
`In my research, I have designed, constructed, and used de-coupled
`
`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
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`etching and plasma assisted chemical vapor deposition. For example, publication
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`IPR Case No. Unassigned
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`74 in my CV (Ex. 1011 at 15), describes a plasma processing apparatus, including
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`an electron cyclotron resonance (ECR) plasma source used for plasma etching of
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`polysilicon, silicon dioxide and silicon. The plasma processing apparatus, shown
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`in Figure 1 of this publication, includes an ECR source chamber and a downstream
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`processing chamber.
`
`19. Publications 75 and 77 in my CV (Ex. 1011 at 15), describe improved
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`operational characteristics of an ECR plasma etch reactor based on optimizing the
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`coupling of the microwave power to the plasma. The optimized coupler included a
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`dielectric window that functioned as a transmission line that adjusted the phase of
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`the microwaves to match to the plasma. The optimized coupling reduced the
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`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.
`
`20. 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
`
`involves increasing the magnetic field of the ECR reactor such that the microwave
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`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
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`correlated with the plasma uniformity, so that improving plasma uniformity
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`resulted in a more uniform etch across the wafer being etched.
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`IPR Case No. Unassigned
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` Declaration for Petition
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`21. Publications 79 in my CV (Ex. 1011 at 15) describes another method
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`for producing more uniform plasmas in ECR plasma etch reactors, based on
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`multiplexing two different microwave modes in the transmission waveguide used
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`to introduce the microwave power into the ECR reactor. The result of mixing the
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`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.
`
`22. 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
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`a manner that produces more uniform ion bombardment across substrates being
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`processed. This work shows that using a lower rf frequency for wafer biasing
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`results in a more uniform distribution of ion bombardment across the wafer.
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`23. Publication 82 in my CV (Ex. 1011 at 16) discloses a new type of
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`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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`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.
`
`24. 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
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`form of plasma-assisted chemical vapor deposition that provides layer-by-layer
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`IPR Case No. Unassigned
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`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
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`deposition of silicon dioxide can be applied to producing a material that can be
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`used for interlevel dielectrics between conductors in integrated circuits. These
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`plasma processes are also the subject matter in U.S. Patent Nos. 7,947,579 and
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`8,187,678, on which I am an inventor.
`
`25.
`
`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.
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`26.
`
`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
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`patent and other reference documents.
`
`27.
`
`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
`
`opinions on how these concepts relate to several claim limitations of the '221
`
`patent in the context of the specification.
`
`28.
`
`In reaching the opinions stated herein, I have considered the '221
`
`patent, its prosecution history, and the references listed in the table below, and
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`have also drawn as appropriate upon my own education, training, research,
`
`knowledge, and personal and professional experience.
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`IPR Case No. Unassigned
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`Exhibi
`t
`1001 U.S. Patent No. 6,017,221 (the '221 patent)
`
`
`
`
` U.S. Patent No. 6,017,221
`
` Declaration for Petition
`
`Description
`
`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)
`
`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
`
`1011 Curriculum Vitae of Joseph L. Cecchi, Ph.D.
`
`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=1
`611063 (last visited Aug. 13, 2015).
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`IPR Case No. Unassigned
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`III. PERSON HAVING ORDINARY SKILL IN THE ART
`29.
`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
`
`purported invention of the '221 patent, which I have been informed is December 4,
`
`1995, the earliest priority date recited by the '221 patent.
`
`30.
`
`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.
`
`31. 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
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`similar field and two or three years of work experience in semiconductor
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`manufacturing or related fields.
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` Declaration for Petition
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`32. 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
`
`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
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`offer this declaration as to how such a person would have interpreted the '221
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`patent and the prior art on or about December 4, 1995. Unless otherwise stated,
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`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.
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`IV. RELEVANT LEGAL STANDARDS
`33. 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.
`
`34.
`
`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.
`
`35.
`
`I understand that a single piece of prior art "anticipates" a claim if
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`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
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`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."
`
`36.
`
`I understand that the prior art may render a patent claim "obvious." I
`
`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).
`
`37.
`
`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
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`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
`
`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.
`
`38.
`
`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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`
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`Combining prior art elements according to known methods to yield
`
`predictable results;
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`Simple substitution of one known element for another to obtain
`
`predictable results;
`
`Use of known technique to improve similar devices (methods or
`
`products) in the same way;
`
`Applying a known technique to a known device (methods or products)
`
`ready for improvement to yield predictable results;
`
`Choosing from a finite number of identified, predictable solutions,
`
`with a reasonable expectation of success, such that the effort was
`
`"obvious to try";
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`Known work in one field of endeavor that may prompt variations on
`
`
`
`the work for use in either the same field or a different one based on
`
`design incentives or other market forces if the variations are
`
`predictable to a person having ordinary skill in the art;
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`
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`Some teaching, suggestion, or motivation in the prior art that would
`
`have led a person having ordinary skill in the art to modify the prior
`
`art reference or to combine prior art reference teachings to arrive at
`
`the claimed invention.
`
`39.
`
`I appreciate that secondary considerations may be considered, if
`
`present, as part of the overall obviousness analysis. Such considerations do not
`
`appear to be present here:
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`
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`I have never heard anyone offer praise for the '221 patent, nor am I
`
`aware of any commercial success attributable to the '221 patent.
`
`I am also unaware of any copying of the alleged invention of the '221
`
`patent.
`
`I am unaware of any use to which the owner of the '221 patent has put
`
`the patent except to assert it in litigation.
`
`V. THE '221 PATENT
`40.
`I understand Lam is challenging claims 1-7 ("challenged claims") of
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`the '221 patent.
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`3475040
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`LAM Exh 1007-pg 15
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`IPR Case No. Unassigned
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` U.S. Patent No. 6,017,221
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` Declaration for Petition
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`In my opinion, the challenged claims are all directed to a method for
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`41.
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`minimizing undesirable capacitive coupling of an inductively-coupled plasma
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`source for semiconductor processing. In the method, undesirable capacitive
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`coupling is reduced by adjusting phase and anti-phase portions of capacitively
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`coupled currents. A so-called wave adjustment circuit is employed to selectively
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`balance the phase and anti-phase portions.
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`42.
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`I understand that the '221 patent is a continuation-in-part of a U.S.
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`patent application filed on October 23, 1996 (now abandoned) which, in turn,
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`claims priority to another application filed on December 4, 1995 (also abandoned).
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`Ex. 1001-1. I understand that no matter which of these dates Flamm may rely on
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`as the priority date of the '221 patent, the references relied upon in this Petition are
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`prior art to the '221 patent because they all predate Dec. 4, 1995, the earliest
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`possible priority date recited by the '221 patent.
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`A. Representative Claim 1
`43. The crux of the alleged invention of the '221 patent is the
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`straightforward and well-known process of minimizing undesirable capacitive
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`coupling of an inductively-coupled plasma source for semiconductor processing.
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`For example, claim 1 recites a process comprising (a) "subjecting a substrate to
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`entities, at least one of said entities emanating from a gaseous discharge excited by
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`a high frequency field from an inductive coupling structure," (b) "in which a phase
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`3475040
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`LAM Exh 1007-pg 16
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` U.S. Patent No. 6,017,221
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`IPR Case No. Unassigned
` Declaration for Petition
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`
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`portion and an anti-phase portion of capacitive currents coupled from the inductive
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`coupling structure are selectively balanced;" and (c) "wherein said inductive
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`coupling structure is adjusted using a wave adjustment circuit, said wave
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`adjustment circuit adjusting the phase portion and the anti-phase portion of the
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`capacitively coupled currents." Ex. 1001 at 22:58-23:2.
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`B.
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`The '221 Patent Disclosure
`1.
`Inductively-Coupled Plasma Source
`44. The '221 patent discusses "plasma processing of devices using an
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`inductive discharge," such processing including, for example, "plasma etching and
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`resist stripping of semiconductor devices. . . . [and] chemical vapor deposition
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`(CVD) of semiconductor devices." Ex. 1001 ['221 patent] at 1:16-21. "These
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`plasma processing techniques often rely upon radio frequency power (rf) supplied
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`to an inductive coil for providing power to gas phase species in forming a plasma."
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`Id. at 1:33-36.
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`LAM Exh 1007-pg 17
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`IPR Case No. Unassigned
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` U.S. Patent No. 6,017,221
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`
` Declaration for Petition
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`Capacitively Coupled Currents
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`2.
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`
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`45. The '221 patent describes how, in an inductively-coupled plasma
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`source configuration, "capacitive coupling between high voltage selections of the
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`coil and the plasma discharge often cause high and uncontrollable plasma
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`potentials relative to ground," which, in turn, "can cause damaging high energy ion
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`bombardment of articles being processed by the plasma." Id. at 2:66-3:5.
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`"Consequently, uncontrolled potential differences, such as that caused by 'stray'
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`capacitive coupling from the coil of an inductive plasma source to the plasma, are
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`undesirable." Id. at 4:37-39.
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`3475040
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`LAM Exh 1007-pg 18
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`IPR Case No. Unassigned
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` U.S. Patent No. 6,017,221
`
`
` Declaration for Petition
`
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`Phase and Anti-Phase Portions of the Capacitively Coupled
`Currents
`46. The '221 patent discusses reducing undesirable capacitively coupled
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`3.
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`currents by selectively adjusting phase and anti-phase portions of an excitation
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`signal. It states, "[s]ince the capacitive current increases monotonically with the
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`magnitude of the difference of peak phase and anti-phase voltages, which occur at
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`points A and C in FIG. 2A, this coupling can be lessened by reducing this voltage
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`difference." Ex. 1001 ['221 patent] at 10:31-35. Referring to Fig. 2A of the '221
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`patent, reproduced above, the phase and anti-phase components of the voltage are
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`represented, respectively, at reference numerals 70 and 71. Capacitive coupling is
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`reduced by setting "substantially zero AC voltage at one point on the inductive coil
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`(refer to point 00 in FIG. 2A)," corresponding to "substantially equal phase 70 and
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`anti-phase voltage distributions in directions about this point (refer to 00-A and 00-
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`C in FIG. 2A) and provides substantially equal capacitance coupling to the plasma
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`from physical inductor elements (00-C) and (00-A), carrying the phase and anti-
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`phase potentials." Id. at 10:14-22.
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`4. Wave Adjustment Circuit
`47. The '221 patent discusses adjusting phase and anti-phase portions of
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`capacitively coupled currents using wave adjustment circuits. Referring back to
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`Fig. 2A of the '221 patent, an "upper wave adjustment circuit 57" and a "lower
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`wave adjustment circuit 59" are shown connected to the "inductive applicator 55."
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`3475040
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`LAM Exh 1007-pg 19
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` U.S. Patent No. 6,017,221
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`IPR Case No. Unassigned
` Declaration for Petition
`
`
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`Ex. 1001 ['221 patent] at 10:4-6. They are used to achieve the reduction of
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`undesirable capacitively coupled currents, as "the wave adjustment circuits are
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`adjusted to provide substantially zero AC voltage at one point on the inductive coil
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`(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
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`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
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`and Fig. 4. As a specific embodiment, the specification of the '221 patent describes
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`a "toroidal transformer . . . coupled between the rf power source 122 and the coil
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`132," whereby the "(balanced-unbalanced) toroidal transformer (i.e., broadband
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`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.
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`LAM Exh 1007-pg 20
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`IPR Case No. Unassigned
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`VI. TECHNICAL BACKGROUND
`48.
`In my opinion, patents and printed publications predating the
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` U.S. Patent No. 6,017,221
` Declaration for Petition
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`
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`purported invention of the '221 patent disclosed the limitations of the challenged
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`claims. For example, the references discussed herein disclose minimizing
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`undesirable capacitive coupling of an inductively-coupled plasma source for
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`semiconductor processing by adjusting the phase and anti-phase components of
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`capacitively coupled currents.
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`49. The prior art article by Lieberman and Gottscho, Design of High
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`Density Plasma Sources For Materials Processing, was published as a University
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`of California, Berkeley technical report bearing catalog no. UCB/ERL M93/3 on
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`January 11, 1993 (Ex. 1002; see also Ex. 1010 [Declaration of Miyoko
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`Tsubamoto]) and also in the compendium Plasma Sources For Thin Film
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`Deposition and Etching (Physics of Thin Films Volume 18) on August 18, 1994
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`(Ex. 1012; see also Ex. 1013 [publisher's webpage]). These two versions are
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`essentially identical in content and, where referred to generally and not
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`distinguished as Lieberman93 and Lieberman94, they will be referred to
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`collectively and/or interchangeably as "Lieberman." Lieberman teaches a process
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`for fabricating a product using a plasma source. See, e.g., Ex. 1002 [Lieberman93]
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`at p. 1; Ex. 1012 [Lieberman94] at p. 2-3. Lieberman further teaches subjecting a
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`substrate to entities, at least one of said entities emanating from a gaseous
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`3475040
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`LAM Exh 1007-pg 21
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` U.S. Patent No. 6,017,221
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`IPR Case No. Unassigned
` Declaration for Petition
`
`
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`discharge excited by a high frequency field from an inductive coupling structure.
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`See, e.g., Ex. 1002 [Lieberman93] at p. 23, Fig. 25; Ex. 1012 [Lieberman94] at p.
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`53, Fig. 25. Lieberman discloses a phase portion and an anti-phase portion of
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`capacitive currents coupled from an inductive coupling structure are selectively
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`balanced, wherein said inductive coupling structure is adjusted using a wave
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`adjustment circuit, said wave adjustment circuit adjusting the phase portion and
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`anti-phase portion of the capacitively coupled currents. See, e.g., Ex. 1002
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`[Lieberman93] at p. 23; Ex. 1012 [Lieberman94]. I discuss the Lieberman
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`reference in more detail below in Section VIII.A where I explain my opinions that
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`claims 1-7 of the '221 patent are unpatentable based on the grounds discussed in
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`that section.
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`50. The Dible reference, U.S. Pat. No. 5,573,595, (Ex. 1003) was issued
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`on Nov. 12, 1996 and filed on September 29, 1995. Dible discloses a process for
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`fabricating a product using a plasma source. See, e.g., Ex. 1003 at 1:7-9. Dible
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`further teaches subjecting a substrate to entities, at least one of said entities
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`emanating from a gaseous discharge excited from an inductive coupling structure.
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`See, e.g., id. at 1:41-46, 2:42-56, 4:3-10. Dible discloses a phase portion and
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