throbber
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`Eaton et al.
`In re Patent of:
`7,060,360 Attorney Docket No.: 43498-0002IP1
`U.S. Patent No.:
`June 13, 2006
`
`Issue Date:
`Appl. Serial No.: 10/443,342
`
`Filing Date:
`May 22, 2003
`
`Title:
`BOND COAT FOR SILICON BASED SUBSTRATES
`
`
`
`
`
`
`
`DECLARATION OF DR. DAVID R. CLARKE
`
`
`
`
`
`
`
`
`
`
`1
`
`UTC 2001
`General Electric v. United Technologies
`IPR2016-01289
`
`

`
`
`
`
`I. 
`
`II. 
`
`
`
`
`
`Table of Contents
`
`Introduction ...................................................................................................... 3 
`
`Qualifications ................................................................................................... 3 
`
`III.  Materials Considered ....................................................................................... 6 
`
`IV.  Applicable Legal Standards ............................................................................. 8 
`
`A.  My Understanding of Claim Construction ............................................ 8 
`
`B.  My Understanding of Anticipation ....................................................... 9 
`
`C.  My Understanding of Obviousness ....................................................... 9 
`
`V. 
`
`Level of Ordinary Skill in the Art ................................................................. 14 
`
`VI.  Overview of Coating Technology ................................................................. 15 
`
`A. 
`
`B. 
`
`C. 
`
`D. 
`
`Introduction to Coatings ...................................................................... 15 
`
`Properties of Multilayer Coatings ....................................................... 18 
`
`Coatings Under Extreme Environmental Conditions .......................... 23 
`
`Residual Stress in Multilayer Coatings ............................................... 26 
`
`VII.  Brief Overview of the ’360 Patent ................................................................. 27 
`
`VIII.  Claim Construction ........................................................................................ 30 
`
`IX.  U.S. Patent No. 5,677,060 to Terentieva (“Terentieva”) .............................. 32 
`
`X.  U.S. Patent No. 6,387,456 to Eaton (“Eaton ’456”) ...................................... 35 
`
`XI. 
`
`J. D. Webster et al., Oxidation Protection Coatings for C/SiC Based on
`Yttrium Silicate, J. Eur. Cer. Soc., vol. 18, No. 16 (Dec. 1998) pp. 2345-50.
`(“Webster”) .................................................................................................... 37 
`
`
`
`
`
`
`
`
`2
`
`

`
`
`
`
`
`XII.  Yoshikazu Suzuki et al., Improvement in Mechanical Properties of Powder-
`Processed MoSi2 by the Addition of Sc2O3 and Y2O3, J. Am. Ceram. Soc.,
`vol. 81, No. 12 (Dec. 1998) pp. 3141-49. (“Suzuki”) ................................... 37 
`
`XIII.  Terentieva’s protective coating is not a bond layer ....................................... 38 
`
`XIV.  The combination of Terentieva and either Eaton ’456 or the ’360 Patent is
`not obvious ..................................................................................................... 40 
`
`A. 
`
`B. 
`
`C. 
`
`The functionality of the barrier layer of Eaton ’456 or of the ’360
`Patent is redundant with the functionality of Terentieva’s protective
`coating ................................................................................................. 40 
`
`A POSITA would not have had a reasonable expectation of success . 44 
`
`Dependent claim 4 is not obvious in view of Terentieva, Eaton ’456,
`and the background of the ’360 Patent ................................................ 49 
`
`XV.  Conclusions .................................................................................................... 50 
`
`
`
`
`
`- 2 -
`
`
`
`
`
`
`3
`
`

`
`
`
`I.
`
`
`
`
`Introduction
`
`I, David R. Clarke, declare as follows:
`
`1.
`
`I have been retained on behalf of United Technologies Corporation to
`
`offer technical opinions relating to U.S. Patent No. 7,060,360 (the ’360 Patent),
`
`and prior art references relating to its subject matter.
`
`
`II. Qualifications
`
`2. My name is Dr. David R. Clarke. I am the Extended Tarr Family
`
`Chair of Materials at Harvard University. My current curriculum vitae is attached
`
`and some highlights follow.
`
`3.
`
`I earned my B.Sc. (1968) with First Class Honors in Applied Sciences
`
`from Sussex University in England and my Ph.D. (1974) in Physics from Cam-
`
`bridge University, England. I carried out research on high temperature silicon-
`
`containing materials and zirconia materials at Rockwell International Science Cen-
`
`ter from 1977-1982. After employment in various capacities related to materials
`
`research at IBM Research Division, Yorktown Heights, NY, I was subsequently a
`
`Professor of Materials and Professor of Mechanical Engineering at the University
`
`of California, Santa Barbara (UCSB), from 1990-2009, and served as the Chair of
`
`the Materials Department from 1991-1998. I have been a Professor of Materials
`
`and Applied Physics at Harvard University since 2009.
`
`
`
`
`- 3 -
`
`4
`
`

`
`
`
`
`
`4. My record of professional service includes recognitions from several
`
`professional organizations in my field of expertise. I was elected to the National
`
`Academy of Engineering in 1999. I was named a Distinguished Life Member of
`
`the American Ceramic Society (ACS) in 2009, and have been a Fellow of the
`
`American Physical Society since 1986 and of the ACS since 1985. I have been the
`
`recipient of a number of awards from the ACS, including James Mueller Award
`
`from the Engineering Ceramics Division of the ACS in 2014, the Edward C. Henry
`
`Award from the Electronics Division of the ACS in 1999, and the Sosman Memo-
`
`rial Award from the ACS in 1999. I am the author of a scientific paper that was
`
`identified as one of the 11 most significant papers in the 110 years of publication
`
`of the journal Ceramics.1 I have served as an editor for the Annual Reviews of Ma-
`
`terials Research since 1997 and as an associate editor for the Journal of the Ameri-
`
`can Ceramic Society since 1986.
`
`5. My work at Rockwell International, IBM, UCSB, and Harvard Uni-
`
`versity has appeared in more than 400 refereed and archival publications on which
`
`I am author or co-author. All publications are listed on my curriculum vitae. How-
`
`ever, a few examples of recent publications that involve thermal barrier coatings
`
`
`1 D.R. Clarke, On the Equilibrium Thickness of Intergranular Glass Phases in Ceramic
`
`Materials, 70 Journal of the American Ceramic Society. 15-22 (1987).
`
`
`
`
`- 4 -
`
`5
`
`

`
`
`
`
`
`for gas turbines include: Clarke and Levi (2003); Casadei, Bertoldi, and Clarke
`
`(2014); Limarga, Shian, Leckie, Levi, and Clarke (2014); Evans, Levi, and Clarke
`
`(2014); and Clarke, Oechsner, and Padture (2012).2,3,4,5,6
`
`6.
`
`I am a named inventor on 11 issued U.S. patents and 3 pending patent
`
`applications. Many of these patents and applications relate generally to composites,
`
`coatings, and glass-ceramic materials, inclusive of the following: U.S. Patent No.
`
`7,070,866, titled “Nickel Aluminide Coating with Improved Oxide Stability;” U.S.
`
`
`2 D. R. Clarke and C. Levi, Materials Design for the Next Generation Thermal Barrier
`
`Coatings, 33 Annual Reviews of Materials Research. 383-417 (2003).
`
`3 F. Casadei, K. Bertoldi, and D.R. Clarke, Vibration Damping of Thermal Barrier Coat-
`
`ings Containing Ductile Metallic Layers, 81 Journal of Applied Mechanics. 101001-101001-10
`
`(2014).
`
`4 A. M. Limarga, S. Shian, R. M. Leckie, C. G. Levi, and D. R. Clarke, Thermal Conduc-
`
`tivity of Single and Multi-phase Compositions in the ZrO2-Y2O3-Ta2O5 System, 34 Journal of
`
`the European Ceramic Society. 3085-3094 (2014).
`
`5 A. G. Evans, C. G. Levi, and D. R. Clarke. “Turbine Materials and Mechanics.” Turbine
`
`Aerodynamics, Heat Transfer, Materials and Mechanics, edited by T. Shih and V. Yang. Ameri-
`
`can Institute of Astronautics and Aeronautics, 2014.
`
`6 D. R. Clarke, M. Oechsner, and N. P. Padture, Thermal-barrier coatings for more effi-
`
`cient gas-turbine engines, 37 MRS Bulletin. 891-898 (2012).
`
`
`
`
`- 5 -
`
`6
`
`

`
`
`
`
`
`Patent No. 6,072,568, titled “Thermal Barrier Coating Stress Measurement;” U.S.
`
`Patent No. 5,277,725, titled “Process for Fabricating a Low Dielectric Composite
`
`Substrate;” and U.S. Patent No. 5,185,215, titled “Zirconia Toughening of Glass-
`
`Ceramic Materials.”
`
`7. My Curriculum Vitae is provided as Exhibit UTC-2005, which con-
`
`tains further details on my education, experience, publications, and other qualifica-
`
`tions to render an expert opinion. My work on this case is being billed at an hourly
`
`rate, with reimbursement for actual expenses. My compensation is not contingent
`
`upon the outcome of these proceedings or on the content of my opinions.
`
`
`III. Materials Considered
`
`8.
`
`In forming my opinions expressed in this declaration, I have consid-
`
`ered and relied upon my education, background, and experience. I reviewed U.S.
`
`Patent No. 7,060,360 (“the ’360 patent”) and its patent file history.
`
`9.
`
`Additionally, I have reviewed and relied upon the following list of
`
`materials in preparation of this declaration:
`
`
`
`
`
`
`
`
`
`
`U.S. Patent No. 5,677,060 to Terentieva et al. (“Terentieva,” GE-1005)
`
`U.S. Patent No. 6,387,456 to Eaton et al. (“Eaton ’456,” GE-1006)
`
`U.S. Patent No. 5,985,470 to Spitsberg et al. (GE-1013)
`
`- 6 -
`
`7
`
`

`
`
`
`
`
`Yoshikazu Suzuki et al., Improvement in Mechanical Properties of Pow-
`
`der-Processed MoSi2 by the Addition of Sc2O3 and Y2O3, J. Am. Ceram. Soc.,
`
`vol. 81, No. 12 (Dec. 1998) pp. 3141-49. (“Suzuki,” GE-1024”)
`
`
`
`J. D. Webster et al., Oxidation Protection Coatings for C/SiC Based on
`
`Yttrium Silicate, J. Eur. Cer. Soc., vol. 18, No. 16 (Dec. 1998) pp. 2345-50.
`
`(“Webster,” GE-1025)
`
`
`
`M.G. Hocking et al., Metallic & Ceramic Coatings: Production, High
`
`Temperature Properties & Applications (1989). (UTC-2002)
`
`
`
`Excerpt of Merriam Webster’s Collegiate Dictionary (10th ed. 2002).
`
`(UTC-2004)
`
`
`
`J.W. Hutchinson and A.G. Evans, On the delamination of thermal barrier
`
`coatings in a thermal gradient, 149 Surface and Coatings Technology. 179-184
`
`(2002). (UTC-2006)
`
`
`
`D.R. Clarke and C.G. Levi, Materials Design for the Next Generation
`
`Thermal Barrier Coatings, 33 Annual Review of Materials Research. 383-417
`
`(2003). (UTC-2007)
`
`
`
`D. Zhu and R.A. Miller, Sintering and creep behavior of plasma-sprayed
`
`zirconia- and hafnia-based thermal barrier coatings, 108-109 Surface and Coat-
`
`ings Technology. 114-120 (1998). (UTC-2008)
`
`- 7 -
`
`
`
`
`
`
`8
`
`

`
`
`
`
`
`
`
`J.W. Hutchinson and Z. Suo, Mixed Mode Cracking in Layered Materi-
`
`als, 29 Advances in Applied Mechanics. 63-191 (1991). (UTC-2009)
`
`
`
`A. Bagchi and A.G. Evans, The Mechanics and Physics of Thin Film
`
`Decohesion and its Measurement, 3 Interface Science. 169-193 (1996). (UTC-
`
`2010)
`
`
`
`D. Zhu and R.A. Miller, Investigation of thermal fatigue behavior of
`
`thermal barrier coating systems, 94-95 Surface and Coatings Technology. 94-
`
`101 (1997). (UTC-2011)
`
`
`
`A.G. Evans, D.R. Mumm, J.W. Hutchinson, G.H. Meier, and F.S. Pettit,
`
`Mechanisms controlling the durability of thermal barrier coatings, 46 Progress
`
`in Materials Science. 505-553 (2001). (UTC-2012)
`
`10.
`
`I have also considered all other materials cited herein.
`
`
`IV. Applicable Legal Standards
`
`A. My Understanding of Claim Construction
`
`11.
`
`I have been informed that claim terminology must be given the broad-
`
`est reasonable interpretation during an IPR proceeding. I have been informed that
`
`this means the claims should be interpreted as broadly as their terms reasonably al-
`
`low, but that such interpretation should not be inconsistent with the patent’s speci-
`
`fication and with usage of the terms by one of ordinary skill in the art at the time of
`
`
`
`
`- 8 -
`
`9
`
`

`
`
`
`
`
`invention. I have been informed that this may yield interpretations that are broader
`
`than the interpretation applied during a District Court proceeding.
`
`12. For the purpose of this proceeding, I have used May 22, 2003, which
`
`is the filing date of the ’360 patent, as the approximate time of the invention.
`
`B. My Understanding of Anticipation
`13.
`I understand that documents and materials that qualify as prior art can
`
`be used to invalidate a patent claim as anticipated or as obvious.
`
`14.
`
`I understand that, once the claims of a patent have been properly con-
`
`strued, the second step in determining anticipation of a patent claim requires a
`
`comparison of the properly construed claim language to the prior art on a limita-
`
`tion-by-limitation basis.
`
`15.
`
`I understand that a prior art reference “anticipates” an asserted claim,
`
`and thus renders the claim invalid, if all elements of the claim are disclosed in that
`
`prior art reference, either explicitly or inherently (i.e., necessarily present).
`
`16.
`
`I understand that anticipation in an inter partes review must be shown
`
`by a preponderance of the evidence.
`
`C. My Understanding of Obviousness
`
`17.
`
`I understand that a patent claim is invalid if the claimed invention
`
`would have been obvious to a person of ordinary skill in the field at the time of the
`
`claimed invention. This means that even if all of the requirements of the claim
`
`
`
`
`- 9 -
`
`10
`
`

`
`
`
`
`
`cannot be found in a single prior art reference that would anticipate the claim, the
`
`claim can still be invalid.
`
`18. As part of this inquiry, I have been asked to consider the level of ordi-
`
`nary skill in the field that someone would have had at the time the claimed inven-
`
`tion was made. In deciding the level of ordinary skill, I considered the following:
`
`
`
`
`
`
`
`the levels of education and experience of persons working in the field;
`
`the types of problems encountered in the field; and
`
`the sophistication of the technology.
`
`19. To obtain a patent, a claimed invention must have, as of the priority
`
`date, been nonobvious in view of the prior art in the field. I understand that an in-
`
`vention is obvious when the differences between the subject matter sought to be
`
`patented and the prior art are such that the subject matter as a whole would have
`
`been obvious at the time of the invention to a person having ordinary skill in the
`
`art.
`
`20.
`
`I understand that a person of ordinary skill in the art provides a refer-
`
`ence point from which the prior art and claimed invention should be viewed. This
`
`reference point prevents one from using his or her own insight or hindsight in de-
`
`ciding whether a claim is obvious.
`
`21.
`
`I also understand that an obviousness determination includes the con-
`
`sideration of various factors such as (1) the scope and content of the prior art, (2)
`
`
`
`
`- 10 -
`
`11
`
`

`
`
`
`
`
`the differences between the prior art and the asserted claims, (3) the level of ordi-
`
`nary skill in the pertinent art, and (4) the existence of secondary considerations
`
`such as commercial success, long-felt but unresolved needs, failure of others, etc.
`
`22.
`
`I understand that an obviousness evaluation can be based on a combi-
`
`nation of multiple prior art references. I understand that the prior art references
`
`themselves may provide a suggestion, motivation, or reason to combine, but other
`
`times the nexus linking two or more prior art references is simple common sense. I
`
`further understand that obviousness analysis recognizes that market demand, rather
`
`than scientific literature, often drives innovation, and that a motivation to combine
`
`references may be supplied by the direction of the marketplace.
`
`23.
`
`I understand that if a technique has been used to improve one device,
`
`and a person of ordinary skill in the art would recognize that it would improve sim-
`
`ilar devices in the same way, using the technique is obvious unless its actual appli-
`
`cation is beyond his or her skill.
`
`24.
`
`I also understand that practical and common sense considerations
`
`should guide a proper obviousness analysis, because familiar items may have ob-
`
`vious uses beyond their primary purposes. I further understand that a person of or-
`
`dinary skill in the art looking to overcome a problem will often be able to fit to-
`
`gether the teachings of multiple publications. I understand that obviousness analy-
`
`
`
`
`- 11 -
`
`12
`
`

`
`
`
`
`
`sis therefore takes into account the inferences and creative steps that a person of
`
`ordinary skill in the art would employ under the circumstances.
`
`25.
`
`I understand that a particular combination may be proven obvious by
`
`showing, among other things, that it was obvious to try the combination. For ex-
`
`ample, when there is a design need or market pressure to solve a problem and there
`
`are a finite number of identified, predictable solutions, a person of ordinary skill
`
`has good reason to pursue the known options within his or her technical grasp be-
`
`cause the result is likely the product not of innovation but of ordinary skill and
`
`common sense.
`
`26. The combination of familiar elements according to known methods is
`
`likely to be obvious when it does no more than yield predictable results. When a
`
`work is available in one field of endeavor, design incentives and other market forc-
`
`es can prompt variations of it, either in the same field or a different one. If a person
`
`of ordinary skill can implement a predictable variation, the patent claim is likely
`
`obvious.
`
`27.
`
`It is further my understanding that a proper obviousness analysis fo-
`
`cuses on what was known or obvious to a person of ordinary skill in the art, not
`
`just the patentee. Accordingly, I understand that any need or problem known in the
`
`field of endeavor at the time of invention and addressed by the patent can provide a
`
`reason for combining the elements in the manner claimed.
`
`
`
`
`- 12 -
`
`13
`
`

`
`
`
`
`
`28.
`
`I understand that a claim can be obvious in light of a single reference,
`
`without the need to combine references, if the elements of the claim that are not
`
`found explicitly or inherently in the reference can be supplied by the common
`
`sense of one of skill in the art.
`
`29.
`
`I understand that secondary indicia of non-obviousness may include
`
`(1) a long felt but unmet need in the prior art that was satisfied by the invention of
`
`the patent; (2) commercial success of processes covered by the patent; (3) unex-
`
`pected results achieved by the invention; (4) praise of the invention by others
`
`skilled in the art; (5) taking of licenses under the patent by others; (6) deliberate
`
`copying of the invention; (7) failure of others to find a solution to the long felt
`
`need; and (8) skepticism by experts. I understand that evidence of secondary indi-
`
`cia of non-obviousness, if available, should be considered as part of the obvious-
`
`ness analysis.
`
`30.
`
`I also understand that there must be a relationship between any such
`
`secondary considerations and the invention. I further understand that contempora-
`
`neous and independent invention by others is a secondary consideration supporting
`
`an obviousness determination.
`
`31.
`
`In sum, my understanding is that prior art teachings are properly com-
`
`bined where a person of ordinary skill in the art having the understanding and
`
`knowledge reflected in the prior art and motivated by the general problem facing
`
`
`
`
`- 13 -
`
`14
`
`

`
`
`
`
`
`the inventor, would have been led to make the combination of elements recited in
`
`the claims. Under this analysis, the prior art references themselves, or any need or
`
`problem known in the field of endeavor at the time of the invention, can provide a
`
`reason for combining the elements of multiple prior art references in the claimed
`
`manner.
`
`32.
`
`I understand that obviousness in an inter partes review must be shown
`
`by a preponderance of the evidence.
`
`
`V. Level of Ordinary Skill in the Art
`
`33. A person of ordinary skill in the art (“POSITA”) at or before the time
`
`of the invention of the ’360 patent7 would have had a Master’s degree in an aca-
`
`demic area emphasizing Materials Science, Mechanical Engineering, Applied
`
`Physics, or an equivalent field. Alternatively, a POSITA would have had a Bache-
`
`lor’s degree in an academic area emphasizing Materials Science, Mechanical Engi-
`
`neering, Applied Physics, or an equivalent field, as well as at least 2 years of in-
`
`dustry experience in thin film deposition or characterization, high temperature
`
`coating design, or mechanics. Additional education or industry experience in a rel-
`
`7 Unless noted otherwise, references herein to what would have been known or under-
`
`stood by a POSITA refers to the knowledge of a POSITA at or before the time of the invention
`
`of the ’360 patent.
`
`
`
`
`- 14 -
`
`15
`
`

`
`
`
`
`
`evant field, such as heat transfer, fluid flow, or materials engineering, may com-
`
`pensate for a deficit in one of the other aspects of the requirements stated above. I
`
`am familiar with the knowledge and capabilities of one of ordinary skill in these
`
`areas based on my own industrial experience, experience working with colleagues
`
`from academia, with undergraduate and graduate students, and with engineers
`
`practicing in industry.
`
`
`VI. Overview of Coating Technology
`
`A.
`Introduction to Coatings
`34. A coating is a thin layer of material that is formed on the surface of a
`
`substrate. The coated substrate is sometimes referred to as a composite material.
`
`35. A coating can be deposited or formed on the surface of a substrate by
`
`any of a variety of methods, examples of which include physical vapor phase dep-
`
`osition, electroplating, thermal or plasma spraying, dip coating, spin coating, and
`
`printing. The resulting composite material is a “system [that] is invariably hybrid,
`
`whether it has been achieved by means of a surface modification of the component
`
`substrate itself or one or more other materials have been applied as a coating to the
`
`component surface.” UTC-2002, p. 1.
`
`36. Often, a coating is applied to a substrate to create a composite materi-
`
`al that has properties that are not present in the substrate alone: “Coatings enable
`
`the attributes of two or more materials [e.g., the coating and the substrate] to be
`
`
`
`
`- 15 -
`
`16
`
`

`
`
`
`
`
`combined to form a composite having characteristics not readily available in a
`
`monolithic material.” UTC-2002, p. xii. Properties of a coating can include me-
`
`chanical properties, such as stiffness, toughness, and strength; protective proper-
`
`ties, such as corrosion resistance; electrical properties, such as resistivity or con-
`
`ductivity; optical properties, such as reflectivity or anti-reflectivity; adhesiveness;
`
`and other properties. When a coating is applied to a substrate, the resulting compo-
`
`site material generally inherits properties from both the coating and the substrate.
`
`37. As an example, a protective coating can be formed on a substrate that
`
`is susceptible to corrosion in the face of aggressive environmental conditions. Such
`
`protective coatings are sometimes referred to as barrier layers or environmental
`
`barrier layers. For instance, a metal component that oxidizes (e.g., corrodes) in the
`
`presence of oxygen or water can be coated with a barrier layer to prevent oxidation
`
`of the component when exposed to oxygen or water, thus expanding the range of
`
`environmental conditions in which the metal substrate or component can be used.
`
`38. To act as a barrier against aggressive environmental conditions (e.g.,
`
`oxygen or water at high temperatures), an environmental barrier layer should be
`
`more resistant to those environmental conditions than the underlying substrate:
`
`“The primary requirement of a protective surface is to have qualities superior to
`
`that of the substrate in order to shield the component from an aggressive environ-
`
`ment.” UTC-2002, p. 1.
`
`
`
`
`- 16 -
`
`17
`
`

`
`
`
`
`
`39. Many industrial applications involve the use of metal components un-
`
`der extreme environmental conditions, such as at very high temperatures, in moist
`
`environments in the presence of high velocity gas flows. Corrosion of metals is ac-
`
`celerated under such conditions, and thus components exposed to these conditions
`
`must be protected with an environmental barrier layer that is durable against high
`
`temperature, water, or high velocity gas flows. For instance, in aerospace applica-
`
`tions, metal components of jet turbine engines, such as the turbine sections, are
`
`subject to extremely high temperatures, repeated heating and cooling cycles, and
`
`are routinely in the presence of high velocity gas flows. Coating these turbine
`
`components, whether metallic or silicon containing compounds, with a durable en-
`
`vironmental barrier layer shields the components from these extreme, aggressive
`
`conditions, improving the reliability and lifetime of the components.
`
`40. A coating can sometimes include multiple layers of material formed
`
`as a stack on the surface of a substrate. A coating including multiple layers of ma-
`
`terials is called a multilayer coating and a substrate with a multilayer coating
`
`formed thereon is sometimes referred to as a multilayer composite. Multilayer
`
`composites are often formed to obtain a composite material having properties or a
`
`combination of properties or functions not available from a single coating material.
`
`41. The adhesion of a coating to a substrate depends on factors such as the
`
`chemical composition of the coating and the substrate, the surface energy of the
`
`
`
`
`- 17 -
`
`18
`
`

`
`
`
`
`
`coating and the substrate, residual or thermal stresses, and the method by which the
`
`coating was formed on the substrate, among other factors. Some coatings may ad-
`
`here well to some types of substrates but may adhere poorly to other types of sub-
`
`strates.
`
`42. When a layer of material with a desired property (e.g., an environmen-
`
`tal barrier layer) does not adhere well to a desired substrate, an additional layer can
`
`be incorporated between the environmental barrier layer and the substrate, forming
`
`a multilayer composite. The additional layer, sometimes referred to as a bond coat
`
`or a bond layer, has good adhesion to both the environmental barrier layer and the
`
`substrate, and thus causes the environmental barrier layer to adhere better to the
`
`substrate. For instance, the “adhesion of plasma sprayed ceramic coatings to metals
`
`is generally poor but can be considerably improved” with a bond layer. UTC-2002,
`
`p. 28.
`
`B.
`Properties of Multilayer Coatings
`43. Multilayer coatings can bring valuable and diverse properties to a
`
`composite material, but can be challenging to design: they “bring their own prob-
`
`lems … and coatings technology has thus emerged as a challenging field for both
`
`the fundamental and applied research worker.” UTC-2002, p. xiv.
`
`44. One major challenge faced during the development of a multilayer
`
`coating for use at high temperatures is that the component is also subjected to re-
`
`
`
`
`- 18 -
`
`19
`
`

`
`
`
`
`
`peated heating and cooling (referred to as thermal cycling), which affects interac-
`
`tions among the layers of the multilayer coating. This typically occurs during start-
`
`up and shutting down an engine, but can also occur during engine operation. Com-
`
`plex, coupled thermal-mechanical-chemical interactions can occur which can result
`
`in the multilayer composite having unexpected or unpredicted properties. A layer
`
`of material that exhibits a particular set of properties in isolation may behave dif-
`
`ferently when combined into a single, multilayer coating on a substrate because of
`
`such interactions. These interactions and the resulting changes in the properties of
`
`the layers of a multilayer coating make it difficult or impossible to predict how a
`
`multilayer coating will behave in service, even if the behavior of each constituent
`
`layer in isolation is well understood.
`
`45.
`
`Interactions among layers in a multilayer coating can include thermal
`
`interactions (e.g., due to a mismatch between the thermal expansion coefficients of
`
`adjacent layers and the substrate) and diffusion of elements between the layers.
`
`These interactions can be coupled; for instance, the inter-diffusion of elements be-
`
`tween layers can alter the thermal expansion coefficients of the individual layers.
`
`Such interactions can cause changes in the properties of a multilayer coating and
`
`can lead to mechanical failure of the coating, such as delamination or cracking.
`
`46. Thermal interactions between layers in a multilayer coating can arise
`
`due to a mismatch in the thermal expansion coefficients of the layers in the coat-
`
`
`
`
`- 19 -
`
`20
`
`

`
`
`
`
`
`ing. For instance, if adjacent layers in a multilayer coating, including the substrate,
`
`have different thermal expansion coefficients, those layers will expand or contract
`
`by a different amount when the multilayer coating is heated or cooled. These dif-
`
`ferences in expansion or contraction can cause stresses to develop within one or all
`
`of the layers, which in turn can have an effect on the properties of the multilayer
`
`coating or even compromise the structural integrity of the multilayer coating, for
`
`instance by cracking or delamination. For instance, “some failure modes” in multi-
`
`layer coatings are “caused by the large residual compression that develops in the
`
`thin TGO [thermally grown oxide] layer upon thermal cycling.” UTC-2006, p. 179.
`
`The effects of a mismatch in thermal expansion coefficients is exacerbated for
`
`multilayer coatings that are exposed to high temperatures or wide variations in
`
`temperature, such as for multilayer coatings used in aerospace applications, be-
`
`cause the temperature changes are typically larger than in other applications.
`
`Cracking can be manifest in a reduction in strength, for instance in four-point
`
`bending strength measured at room temperature.
`
`47.
`
`In many engine applications, multilayer coatings are also exposed to
`
`large temperature gradients. Because of differences in thermal expansion coeffi-
`
`cients in the individual layers and the substrate, temperature gradients can lead to
`
`stress gradients.
`
`
`
`
`- 20 -
`
`21
`
`

`
`
`
`
`
`48. Diffusion is a process by which atoms or molecules move from one
`
`region to another driven by differences in composition. In a multilayer coating,
`
`material can diffuse from one layer into an adjacent layer, changing the sharpness
`
`of the interface between the layers and the chemical composition of both layers in
`
`the vicinity of the interface. In turn, these compositional changes alter the thermal
`
`coefficient of expansion of the layers as well as the fracture energy of the interfac-
`
`es. Both of these changes can result in changes to the properties of the multilayer
`
`structure. Diffusion occurs more readily at high temperatures, and thus the effect of
`
`diffusion on the properties of a multilayer coating is enhanced in multilayer coat-
`
`ings that are exposed to high temperature environments, such as for multilayer
`
`coatings used in aerospace applications.
`
`49. There can also be changes in the coating layers with service at high
`
`temperature associated with sintering or densification of the material. This can lead
`
`to changes in the stresses in the composite coating as well as the onset of cracking.
`
`For instance, densification “increases the elastic modulus [of the coating] and
`
`thereby decreases the strain compliance of the coating.” UTC-2007, p. 399. This
`
`“reduction in strain compliance produced by sintering and densification at higher
`
`use temperatures is likely to control the life of coatings.” Id., p. 403. Indeed, “ce-
`
`ramic coating sintering and creep at high temperature can result in coating shrink-
`
`
`
`
`- 21 -
`
`22
`
`

`
`
`
`
`
`age and through-thickness cracking during cooling, thereby further accelerating the
`
`coating failure process.” UTC-2008, p. 114.
`
`50. Because of the complexity of these coupled inter-layer interactions,
`
`rather than predicting the behavior of a multilayer coating based on the known be-
`
`havior of the individual layers in isolation, a multilayer coating must be developed
`
`and tested as an integrated system. “Duplex and multilayer coatings must be stud-
`
`ied in a graded programme to enable assessment of the influence of each of the
`
`coating layers.” UTC-2002, p. 563. A graded programme can be, for instance, a
`
`“programme to test different properties of the same coating in a stand alone and in
`
`a coating-substrate configuration,” e.g., for each layer of a multilayer coating. Id.,
`
`p. 563.
`
`51. Because of the com

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket