LAM RESEARCH CORP.,
`Petitioner
`
`Demonstrative Exhibits
`
`Inter Partes Review Case No. IPR2015‐01767
`
`U.S. Patent No. 6,017,221
`
`October 11, 2016
`Michael Fleming
`Samuel Lu
`
`1
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`LAM Ex 1028-p. 1
`LAM v FLAMM
`IPR2015-01767
`
`
`Petitioner
`
`Demonstrative Exhibits
`
`Inter Partes Review Case No. IPR2015‐01767
`
`U.S. Patent No. 6,017,221
`
`October 11, 2016
`Michael Fleming
`Samuel Lu
`
`1
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`LAM Ex 1028-p. 1
`LAM v FLAMM
`IPR2015-01767
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`
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`Grounds For Institution (1‐4)
`
`On February 24, 2016, the Board instituted this IPR on the
`following grounds:
`
`(1) Whether claims 1 and 5‐7 are unpatentable under§102(b) as
`anticipated by Lieberman93;
`
`(2) Whether claims 1 and 5‐7 are unpatentable under§102(b) as
`anticipated by Lieberman94;
`
`(3) Whether claims 1 and 5‐7 are unpatentable under§103(a) as
`obvious over the combination of Lieberman93 and Dible;
`
`(4) Whether claims 1 and 5‐7 are unpatentable under§103(a) as
`obvious over the combination of Lieberman94 and Dible;
`
`Decision to Institute IPR2015‐01767 at 24
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`2
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`Grounds For Institution (5‐8)
`
`On February 24, 2016, the Board instituted this IPR on grounds:
`
`(5) Whether claim 4 is unpatentable under§103(a) as obvious
`over the combination of Lieberman93 and Collins
`
`(6) Whether claim 4 is unpatentable under§103(a) as obvious
`over the combination of Lieberman93, Dible and Collins;
`
`(7) Whether claim 4 is unpatentable under§103(a) as obvious
`over the combination of Lieberman94 and Collins; and
`
`(8) Whether claim 4 is unpatentable under§103(a) as obvious
`over the combination of Lieberman94, Dible and Collins.
`
`Decision to Institute IPR2015‐01767 at 24
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`3
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`Road Map
`
`1. The Purported Invention
`
`2. The Claim Language
`
`3. The Prior Art Anticipates Claims 1, 5‐7
`
`4. The Prior Art Renders Obvious Claims 1, 4‐7
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`4
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`The Purported Invention
`
`The technology at issue relates to plasma processing
`using an inductive discharge
`
`• This type of
`processing was
`well known in
`the prior art
`
`See, e.g., ’221 Patent 1:15‐36
`
`Lieberman, Ex 1012, Fig. 25
`
`5
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`The Purported Problem: Unbalanced
`Capacitive Currents Create Non‐Uniformity
`
`’221 Patent 2:64‐66
`
`The ’221 Patent addresses non‐
`uniformity purportedly arising
`from capacitive currents:
`
`’221 Patent 2:66‐3:2
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`6
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`The Purported Solution: Selectively Balancing
`Phase And Anti‐Phase Portions Of Capacitive Currents
`
`Patent Owner Response at 2
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`The Purported Solution: Selectively Balancing
`Phase And Anti‐Phase Portions Of Capacitive Currents
`
`Wave
`adjustment
`circuits
`(57,59)
`
`In this embodiment, 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). This embodiment
`also provides substantially equal
`phase 70 and anti‐phase 71
`voltage distributions in directions
`about this point (refer to OO‐A
`and OO‐C in FIG. 2A) and
`provides substantially equal
`capacitance coupling to the
`plasma from physical inductor
`elements (OO‐C) and (OO‐A),
`carrying the phase and anti‐
`phase potentials.
`
`’221 Patent 10:13‐22
`
`’221 Patent Fig. 2A
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`8
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`The Purported Solution: Selectively Balancing
`Phase And Anti‐Phase Portions Of Capacitive Currents
`
`Wave
`adjustment
`circuits
`(57,59)
`
`In this embodiment, 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). This embodiment
`also provides substantially equal
`phase 70 and anti‐phase 71
`voltage distributions in directions
`about this point (refer to OO‐A
`and OO‐C in FIG. 2A) and
`provides substantially equal
`capacitance coupling to the
`plasma from physical inductor
`elements (OO‐C) and (OO‐A),
`carrying the phase and anti‐
`phase potentials.
`
`’221 Patent 10:13‐22
`
`’221 Patent Fig. 2A
`
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`The Purported Result:
`Reduce the Vector Sum of Capacitive Coupled Currents
`
`’221 Patent 6:31‐41 (cited in Institution Decision at 3)
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`‘221 Discloses Various Ways to Create Wave
`Adjustment Circuits Including Push‐Pull Arrangement
`
`’221 Patent 12:24‐26
`
`’221 Patent 16:17‐20
`
`’221 Patent 16:43‐45
`
`’221 Patent 16:26‐29
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`11
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`Road Map
`
`1. The Purported Invention
`
`2. The Claim Language
`
`3. The Prior Art Anticipates Claims 1, 5‐7
`
`4. The Prior Art Renders Obvious Claims 1, 4‐7
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`12
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`Independent Claim 1
`
`1. A process for fabricating a product using a plasma source,
`said process comprising the steps of
`1a. subjecting a substrate to entities, at least one of said
`entities emanating from a gaseous discharge
`1b. excited by a high frequency field
`1c. from an inductive coupling structure
`1d. in which a phase portion and an anti ‐phase portion of
`capacitive currents coupled from the inductive coupling
`structure are selectively balanced;
`1e. wherein said inductive coupling structure is adjusted using a
`wave adjustment circuit,
`1f. said wave adjustment circuit adjusting the phase portion and
`the anti‐phase portion of the capacitively coupled currents.
`
`13
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`Dr. Flamm Does Not Dispute That Elements
`1, 1(a), 1(b) and 1(c) Are Disclosed In The Prior Art
`
`1. A process for fabricating a product using a plasma source,
`said process comprising the steps of
`1a. subjecting a substrate to entities, at least one of said
`entities emanating from a gaseous discharge
`1b. excited by a high frequency field
`1c. from an inductive coupling structure
`1d. in which a phase portion and an anti ‐phase portion of
`capacitive currents coupled from the inductive coupling
`structure are selectively balanced;
`1e. wherein said inductive coupling structure is adjusted using a
`wave adjustment circuit,
`1f. said wave adjustment circuit adjusting the phase portion and
`the anti‐phase portion of the capacitively coupled currents.
`
`14
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`Dr. Flamm Focuses Instead
`On Elements 1(d)‐1(f)
`
`1. A process for fabricating a product using a plasma source, said
`process comprising the steps of
`1a. subjecting a substrate to entities, at least one of said entities
`emanating from a gaseous discharge
`1b. excited by a high frequency field
`1c. from an inductive coupling structure
`1d. in which a phase portion and an anti ‐phase portion of
`capacitive currents coupled from the inductive coupling
`structure are selectively balanced;
`1e. wherein said inductive coupling structure is adjusted using a
`wave adjustment circuit,
`1f. said wave adjustment circuit adjusting the phase portion and
`the anti‐phase portion of the capacitively coupled currents.
`
`15
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`Key Claim Limitation At Issue
`
`“Selectively balanc[ing]”
`the phase portion and
`the anti‐phase portion
`
`’221 Patent, Claim 1
`
`16
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`Selectively Balancing Covers A
`Wide Range Of Adjustments
`
`Patent owner response and testimony:
`Selectively balancing covers between
`a 10% and a 100% adjustment in sum
`of phase and anti‐phase portions of
`capacitive currents
`
`Patent Owner Response at 4; Ex. 1021 at 197:4‐8
`
`17
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`Patent Owner Response:
`Selectively Balanced Covers A Range
`
`Dr. Flamm’s Response:
`
`Patent Owner Response at 4
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`18
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`Inventor (And Patent Owner):
`Selectively Balanced Includes A 10% Balance
`
`Dr. Flamm’s Testimony:
`
`Ex. 1021, 197:4‐8
`
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`Road Map
`
`1. The Purported Invention
`
`2. The Claim Language
`
`3. The Prior Art Anticipates Claims 1, 5‐7
`
`4. The Prior Art Renders Obvious Claims 1, 4‐7
`
`20
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`Claims 1, 5‐7 Are Anticipated By
`Either Lieberman 93 Or Lieberman 94
`
`Ex. 1002
`
`Ex. 1012
`
`21
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`Lieberman Teaches
`All Of The Elements Of Claim 1
`
`1. A process for fabricating a product using a plasma source,
`said process comprising the steps of
`1a. subjecting a substrate to entities, at least one of said
`entities emanating from a gaseous discharge
`1b. excited by a high frequency field
`1c. from an inductive coupling structure
`1d. in which a phase portion and an anti ‐phase portion of
`capacitive currents coupled from the inductive coupling
`structure are selectively balanced;
`1e. wherein said inductive coupling structure is adjusted using a
`wave adjustment circuit,
`1f. said wave adjustment circuit adjusting the phase portion and
`the anti –phase portion of the capacitively coupled currents.
`
`22
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`Lieberman Uses a Plasma Source
`
`
`1. A process for fabricating a product using a plasma source, said 1. A process for fabricating a product using a plasma source, said
`
`process comprising the steps ofprocess comprising the steps of
`
`Lieberman discloses the use of …
`
`Ex. 1012 at 2
`
`23
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`Lieberman Subjects The Substrate
`To A Plasma Source
`
`
`1a. subjecting a substrate to entities, at least one of said entities 1a. subjecting a substrate to entities, at least one of said entities
`
`emanating from a gaseous dischargeemanating from a gaseous discharge
`
`Lieberman discloses that:
`
`Ex. 1012 at 54
`
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`Lieberman Excites Plasma
`Using A High Frequency Field
`
`
`
`1b. excited by a high frequency field1b. excited by a high frequency field
`
`Lieberman discloses using a 13.56MHz
`field to excite the plasma:
`
`Ex. 1012 at 52‐53
`
`25
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`Lieberman Uses An
`Inductive Coupling Structure
`
`
`
`1c. from an inductive coupling structure1c. from an inductive coupling structure
`
`Inductive
`coupling
`structures
`
`Ex. 1012 at Fig. 25
`
`26
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`Lieberman Selectively Balances By Placing
`A Virtual Ground In the Middle of the Coil
`
`
`1d. in which a phase portion and an anti‐phase portion of 1d. in which a phase portion and an anti‐phase portion of
`
`capacitive currents coupled from the inductive coupling capacitive currents coupled from the inductive coupling
`
`structure are selectively balanced;structure are selectively balanced;
`
`Lieberman discloses that:
`
`Ex. 1012 at 53
`
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`’221 Selectively Balances In The Same Way
`By Placing The Virtual Ground in Middle of the Coil
`
`Lieberman: “Place[] a virtual
`ground in the middle of the
`coil”
`
`’221: “[T]he 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).”
`
`’221 patent, Ex. 1001, Fig. 2A and 10:14‐16; Ex. 1012 at 53
`
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`’221 Shows Virtual Ground in the Middle Results
`In Equal Voltage Distribution
`
`’221 patent, Ex. 1001, Fig. 2A, 10:17‐22
`
`29
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`’221 Shows Placing Virtual Ground In The Middle
`Results In Reduced Sum of Capacitive Current
`
`’221 patent, Ex. 1001, Fig. 2A, 10:17‐22
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`30
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`Lieberman And ‘221 Accomplish The Same Thing:
`Reducing The Sum Of Capacitive Currents
`
`Lieberman discloses that:
`
`’221 Patent:
`
`Ex. 1012 at 53
`
`Ex. 1001 at 10:28‐30
`
`31
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`100% Balanced Phase Portion And Anti‐Phase Portion
`
`Phase Portion
`
`Anti‐Phase Portion
`
`Sum of Phase Portion and Anti‐Phase Portion = Zero
`
`’221 Patent Fig. 2A, 13:26‐28; Ex. 1021 at 193:10‐198:22
`
`32
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`0% Balanced (Unbalanced) Phase Portion
`And Anti‐Phase Portion
`
`Phase Portion
`
`Sum of Phase Portion and Anti‐Phase Portion = Maximum Value
`
`’221 Patent Fig. 2A, 13:26‐28; Ex. 1021 at 193:10‐198:22
`
`33
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`10% Balanced (Unbalanced) Phase Portion
`And Anti‐Phase Portion
`
`Phase Portion
`
`Anti‐Phase Portion
`
`Sum of Phase Portion and Anti‐Phase Portion =
`A Value less than Maximum and More than Zero
`
`’221 Patent Fig. 2A, 13:26‐28; Ex. 1021 at 193:10‐198:22
`
`34
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`Lieberman Shows Placing Virtual Ground In Middle
`Results In Reduced Sum of Capacitive Current
`
`
`1d. in which a phase portion and an anti‐phase portion of 1d. in which a phase portion and an anti‐phase portion of
`
`capacitive currents coupled from the inductive coupling capacitive currents coupled from the inductive coupling
`
`structure are selectively balanced;structure are selectively balanced;
`
`Lieberman discloses that:
`
`Ex. 1012 at 53
`
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`Lieberman Is Not Limited
`To Controlling Only Magnitude
`
`Dr. Cecchi opines that, in Lieberman:
`• “[T]he phasor vector sum of the phase portion … and
`the anti‐phase portion … of the capacitively coupled
`current is substantially reduced to zero.”
`
`Ex. 1022 ¶¶50‐51
`
`• A POSITA would understand the discussion of driving
`the inductive coil "push‐pull" in Lieberman to
`correspond to the claimed "phase and an anti‐phase
`portion of capacitive currents coupled from an
`inductive coupling structure" recited by claim 1.
`
`Ex. 1007, ¶ 71
`
`36
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`Lieberman Uses A Balanced Transformer
`As A Wave Adjustment Circuit
`
`
`1e. wherein said inductive coupling structure is adjusted using a 1e. wherein said inductive coupling structure is adjusted using a
`
`wave adjustment circuit,wave adjustment circuit,
`
`Lieberman discloses a
`wave adjustment circuit:
`
`Ex. 1012 at 53
`
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`’221 Patent Confirms A Transformer Like The One In
`Lieberman Can Be Used AS A Wave Adjustment Circuit
`
`’221 Patent Fig 4
`
`’221 Patent 16:17‐20
`
`’221 Patent 16:26‐29
`
`38
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`The Board Agreed Lieberman Uses A Balanced Transformer
`To Selectively Balance The Phase And Anti‐Phase Portions
`
`Board’s Decision to Institute
`
`Institution Decision at 9
`
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`Dr. Cecchi Agrees With The Board
`
`• Lieberman: Driving the coil “push‐pull using a
`balancing transformer, … places a virtual ground in
`the middle of the coil.”
`
`Ex. 1002, 23; Ex. 1012, 53
`
`• Dr. Cecchi: “A POSITA would have understood that
`this ‘virtual ground’ would ‘provide substantially
`zero AC voltage at one point in the inductive coil,’
`Ex. 1001 [’221 patent] at 10:15‐16 thus
`accomplishing the same goal as in the ’221 patent
`of ‘reduc[ing] the undesired capacitively coupled rf
`current flowing from coil to plasma.’”
`
`Ex. 1007, ¶72 (citations in original)
`
`40
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`Dr. Flamm’s Declaration Seeks
`To Distinguish Lieberman
`
`But Dr. Flamm’s Assertions Are Contradicted By:
`
`• Dr. Flamm’s own deposition testimony
`
`• Dr. Cecchi’s declaration
`
`41
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`Dr. Flamm Flip Flop #1:
`Lieberman Does Not Teach A Balun Transformer
`
`Dr. Flamm Declaration:
`
`“Lieberman teaches a
`conventional balanced
`magnetic transformer,
`which is not a balun.”
`
`Ex. 2001, ¶ 9 (emphasis added)
`
`42
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`Dr. Flamm Then Says:
`Lieberman Teaches A Balun Transformer
`
`Dr. Flamm Deposition:
`Q. Do you agree that
`Figure 1A and Figure
`1C then show a
`balun transformer?
`A. I think I can agree
`with that.
`
`Ex. 1021, 159:24‐160:1
`
`43
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`Dr. Cecchi Agrees:
`Lieberman Teaches A Balun Transformer
`
`• Dr. Cecchi opines that the Lieberman balanced
`transformer operates in the push‐pull arrangement
`just as the '221 patent transformer 401 (which is a
`balun transformer).
`
`Ex. 1007 at ¶ 71
`
`44
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`Dr. Flamm Flip Flop #2: A POSITA Would
`Not Know To Ground The Balanced Transformer
`
`Dr. Flamm Declaration:
`
`Ex. 2001 at ¶17
`
`45
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`Dr. Flamm Then Says: A POSITA Would Have
`Known To Ground The Balanced Transformer
`
`Dr. Flamm Deposition:
`• Dr. Flamm admits that the ’221 patent transformer
`401 also does not show a ground.
`
`Ex. 1021, 67: 6‐7
`
`• But, Dr. Flamm asserts that a POSITA would have
`known that the ’221 patent transformer 401 should
`be grounded.
`
`Id. at 67:10‐13
`
`46
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`Dr. Flamm Then Says: A POSITA Would Have
`Known To Ground The Balanced Transformer
`
`Dr. Flamm Deposition:
`• Dr. Flamm admits that such balun transformers are
`well known prior art ("To construct the actual
`equipment, the person of ordinary skill in the art would
`know … baluns, I myself did when I was as young as
`maybe 16 years old, because I was a radio ham.")
`
`Ex. 1021, 51:4‐52:3
`
`• Balun transformers are commonly made by grounding
`the center tap of the secondary windings of a flux
`coupled transformer.
`
`Ex. 1016, 1 and Fig. 1c; Ex. 1024, 6 and Fig. 4
`See Ex. 1021, 156:24‐25, 159:7‐23, 97:6 ,97:21‐98:2 and 100:6‐18
`
`47
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`Dr. Cecchi Agrees: POSITA Would Have Known
`To Ground The Balanced Transformer
`
`Ex. 1022 at ¶53
`
`48
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`Dr. Flamm Flip Flop #3: A POSITA Would Not Know
`How To Construct An RF High Power Flux Coupled Balun
`
`Dr. Flamm asserts that the use of an iron or ferrite
`core would not work:
`
`• Dr. Flamm states that a flux coupled balun
`transformer that operates in the practical
`frequency range of 20 hertz to 1 gigahertz is
`not operable for high‐power applications
`assuming that the transformer has a ferrite or
`iron rod core.
`
`See e.g., Ex. 1021, 110:9‐112:7
`
`49
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`But Dr. Flamm Then Says: A POSITA Would Know
`How To Construct An RF High Power Flux Coupled Balun
`
`Dr. Flamm Deposition:
`• Dr. Flamm testifies that a POSITA would understand
`that the core of the balun transformer, element 40,
`of the ’221 patent is a ferrite material such as
`powdered iron.
`
`See e.g., Ex. 1021, 80:19‐21
`
`50
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`Indeed, Dr. Flamm Admits That A POSITA Would
`Know How To Do This For Lieberman
`
`In deposition, Dr. Flamm was presented with the table on p. 9
`of Ex. 1024 that discloses that flux coupled balun transformers
`have a practical frequency range of 20 hertz to 1 gigahertz.
`
`Q. Is there any reason to believe that you couldn't construct
`the flux coupled balun transformer as shown in Figure 4
`to be in the practical range of 20 hertz to 1 gigahertz as
`shown in the table on page 9?
`A. Yes, I think you could construct a device such as is
`shown in the figure.
`
`Ex. 1021, 108:1‐12
`
`51
`
`LAM Ex 1028-p. 51
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Dr. Cecchi Agrees: A POSITA Would Know How To
`Construct An RF High Power Flux Coupled Balanced Transformer
`
`• Dr. Cecchi: “In my opinion, a POSITA would know
`that the balanced transformer in Lieberman's
`setup would have a core made of suitable material,
`such as a ferrite or powdered iron core, for the RF
`power application at least for the 13.56 MHz
`frequency stated in Lieberman.”
`
`Ex. 1007, ¶72 (citations in original)
`
`52
`
`LAM Ex 1028-p. 52
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Dr. Flamm And Dr. Cecchi Agree That The ’221
`Transformer Operates In A Push‐Pull Arrangement
`
`• When confronted with the ’221 patent specification,
`Dr. Flamm admits that the ’221 transformer is a
`push‐pull arrangement.
`
`Ex. 1021, 48:10‐49:25
`
`• Dr. Cecchi agrees that the transformer, element 401,
`shown in Figure 4 of the '221 patent operates as a
`push‐pull arrangement.
`
`Ex. 1007, ¶ 71
`
`53
`
`LAM Ex 1028-p. 53
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Lieberman Teaches that Its Transformer
`Also Operates In A Push‐Pull Arrangement
`
`Just Like The ’221 Patent
`
`Ex. 1012 at 53
`
`54
`
`LAM Ex 1028-p. 54
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Dr. Cecchi’s Testimony Should Be Credited
`Over Flamm’s Argument
`
`• Dr. Cecchi opines that the Lieberman balanced
`transformer accomplishes selectively balancing the
`phase and the anti‐phase portions of the capacitively
`coupled currents and thereby, teaches "the wave
`adjustment circuit."
`
`Ex. 1007, ¶¶ 72 and 73 and Ex. 1022, ¶¶ 50‐51
`
`• Dr. Cecchi provides an opinion that is underpinned
`with objective evidence and scientific explanations.
`
`• In contrast, Dr. Flamm provides only bald statements
`without any such underpinning.
`
`Reply 17‐18
`
`55
`
`LAM Ex 1028-p. 55
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Lam Relies On Expert Testimony
`Of A Disinterested Witness
`
`Dr. Joseph Cecchi
`University of New Mexico
`
`56
`
`LAM Ex 1028-p. 56
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Patent Owner Dr. Flamm Relies Upon
`His Own Biased Testimony
`
`• Dr. Flamm is asserting the
`’221 patent against the entire
`semiconductor industry
`
`• Dr. Flamm is in litigation against
`Intel, Samsung, GlobalFoundries,
`Micron and Maxim
`
`Daniel L. Flamm
`
`See, e.g., Petitioner’s Reply at 4 (listing lawsuits brought by Dr. Flamm)
`
`57
`
`LAM Ex 1028-p. 57
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Elements 1(d)‐1(f) Are Disclosed In Lieberman
`
`1. A process for fabricating a product using a plasma source, said
`process comprising the steps of
`1a. subjecting a substrate to entities, at least one of said entities
`emanating from a gaseous discharge
`1b. excited by a high frequency field
`1c. from an inductive coupling structure
`1d. in which a phase portion and an anti ‐phase portion of
`capacitive currents coupled from the inductive coupling
`structure are selectively balanced;
`1e. wherein said inductive coupling structure is adjusted using a
`wave adjustment circuit,
`1f. said wave adjustment circuit adjusting the phase portion and
`the anti –phase portion of the capacitively coupled currents.
`
`58
`
`LAM Ex 1028-p. 58
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Dr. Flamm Does Not Dispute That Lieberman Teaches
`The Limitations Of Dependent Claims 5‐7
`
`5. The process of claim 1 wherein said process is
`provided in a chamber.
`
`6. The process of claim 5 wherein the chamber is
`provided for a process selected from etching,
`deposition, sputtering, or implantation.
`
`7. The process of claim 1 wherein said inductive
`coupling structure provides a wave multiple
`selected from a one‐sixteenth wave, a one‐eighth‐
`wave, a quarter‐wave, a half‐wave, a three‐quarter
`wave, and a full‐wave.
`
`59
`
`LAM Ex 1028-p. 59
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Either Lieberman 93 Or Lieberman 94
`Teach Claim 5
`
`
`
`5. wherein said process is provided in a chamber.5. wherein said process is provided in a chamber.
`
`Processing
`Chambers
`
`Ex. 1012 at Fig. 25
`
`60
`
`LAM Ex 1028-p. 60
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Either Lieberman 93 Or Lieberman 94
`Teach Claim 6
`
`
`6. the chamber is provided for a process selected from etching, 6. the chamber is provided for a process selected from etching,
`
`deposition, sputtering, or implantation.deposition, sputtering, or implantation.
`
`Lieberman discloses:
`
`Ex. 1002 at 1
`
`61
`
`LAM Ex 1028-p. 61
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Either Lieberman 93 Or Lieberman 94
`Teach Claim 7
`
`
`7. said inductive coupling structure provides a wave multiple 7. said inductive coupling structure provides a wave multiple
`
`selected from a one sixteenth wave, a one‐eighth‐wave, a selected from a one sixteenth wave, a one‐eighth‐wave, a
`
`quarter‐wave, a halfwave, a three‐quarter wave, and a full‐wave.quarter‐wave, a halfwave, a three‐quarter wave, and a full‐wave.
`
`• Dr. Cecchi: “In my opinion, a POSITA would
`understand that the balanced transformer creates a
`voltage configuration which has a 180 degree phase
`difference between the ends of the coil, and by
`symmetry would have ‘virtual ground in the middle of
`the coil.’ in my opinion, a POSITA would understand
`this would be a half‐wave multiple.”
`
`Ex. 1007, ¶80.
`• Dr. Flamm does not dispute otherwise
`
`62
`
`Ex. 1002 at 23
`
`LAM Ex 1028-p. 62
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Road Map
`
`1. The Purported Invention
`
`2. The Claim Language
`
`3. The Prior Art Anticipates Claims 1, 5‐7
`
`4. The Prior Art Renders Obvious Claims 1, 4‐7
`
`63
`
`LAM Ex 1028-p. 63
`LAM v FLAMM
`IPR2015-01767
`
`
`
`If Not Anticipated,
`Then Claims 1, 5‐7 Are Obvious
`
`Ground 3
`
`Ground 4
`
`Lieberman 93
`
`Dible
`
`Lieberman 94
`
`Dible
`
`64
`
`LAM Ex 1028-p. 64
`LAM v FLAMM
`IPR2015-01767
`
`
`
`And Claim 4 Is Obvious
`
`Ground 3
`
`Ground 4
`
`Lieberman 93
`
`Dible
`
`Lieberman 94
`
`Dible
`
`65
`
`LAM Ex 1028-p. 65
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Dible Teaches Using Its Invention
`For Inductive Plasma Processing
`
`Ex. 1003 (Dible) at 1:1‐12
`
`66
`
`LAM Ex 1028-p. 66
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Dible Teaches Selectively Balancing
`A Phase Portion And An Anti‐Phase Portion
`
`Institution Decision at 11
`
`67
`
`LAM Ex 1028-p. 67
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Dible Is Not Limited To
`Controlling Only Magnitude As Dr. Flamm Argues
`
`Ex. 1003 (Dible) at 2:42‐52
`
`68
`
`LAM Ex 1028-p. 68
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Institution Decision: POSITA Would Have
`Combined Lieberman With Dible
`
`Institution Decision at 12‐13 (citation omitted)
`
`69
`
`LAM Ex 1028-p. 69
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Dr. Cecchi Agrees: A POSITA Would Have
`Combined Lieberman With Dible
`
`Dr. Cecchi:
`“In my opinion, a POSITA would have reasons to use the
`Dible control circuit in the plasma generating apparatus of
`Lieberman. First, the two disclosed systems have a high
`degree of similarity in structure, purpose and operation.
`…Both also discuss the manipulation of phase and anti‐phase
`portions of a radio frequency field exciting the inductive
`coupling element as a means of adjusting capacitive coupling
`of the element to plasma.”
`
`Ex. 1007 ¶ 98
`
`70
`
`LAM Ex 1028-p. 70
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Dr. Flamm Does Not Dispute That Dependent
`Claims 4‐7 Are Obvious If Claim 1 Is Obvious
`
`4. The process of claim 1 wherein the wave
`adjustment circuit comprises a transmission line.
`
`5. The process of claim 1 wherein said process is
`provided in a chamber.
`
`6. The process of claim 5 wherein the chamber is
`provided for a process selected from etching,
`deposition, sputtering, or implantation.
`
`7. The process of claim 1 wherein said inductive
`coupling structure provides a wave multiple
`selected from a one‐sixteenth wave, a one‐eighth‐
`wave, a quarter‐wave, a half‐wave, a three‐quarter
`wave, and a full‐wave.
`
`71
`
`LAM Ex 1028-p. 71
`LAM v FLAMM
`IPR2015-01767
`
`
`
`LAM RESEARCH CORP.,
`Petitioner
`
`Demonstrative Exhibits
`
`Inter Partes Review Case No. IPR2015‐01767
`
`U.S. Patent No. 6,017,221
`
`October 11, 2016
`Michael Fleming
`Samuel Lu
`
`72
`
`LAM Ex 1028-p. 72
`LAM v FLAMM
`IPR2015-01767
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