By: Christopher Frerking (chris@ntknet.com)
`
`Reg. No. 42,557
`
`
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`INTEL CORPORATION, GLOBALFOUNDRIES U.S., INC.,
`
`AND MICRON TECHNOLOGY, INC.
`
`Petitioners
`
`v.
`
`DANIEL L. FLAMM,
`
`Patent Owner
`
`CASE IPR2017-0279
`U.S. Patent No. RE40,264 E
`
`
`
`PATENT OWNER’S PRELIMINARY RESPONSE
`UNDER 37 C.F.R. § 42.107
`Claims 13-26 & 64-65
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`
`
`
`
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`
`Reg. No. 42,557
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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
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`INTEL CORPORATION, GLOBALFOUNDRIES U.S., INC.,
`
`AND MICRON TECHNOLOGY, INC.
`
`Petitioners
`
`v.
`
`DANIEL L. FLAMM,
`
`Patent Owner
`
`CASE IPR2017-0279
`U.S. Patent No. RE40,264 E
`
`
`
`PATENT OWNER’S PRELIMINARY RESPONSE
`UNDER 37 C.F.R. § 42.107
`Claims 13-26 & 64-65
`
`
`
`
`
`
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`
`
`Inter Partes Review of U.S. Patent No. RE40,264
`IPR2017-00279
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`TABLE OF CONTENTS
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`Page(s)
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`TABLE OF CONTENTS ...................................................................................... i
`TABLE OF AUTHORITIES ................................................................................ ii
`I.
`Introduction ........................................................................................... 1
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`II. Overview of the ‘264 Patent .................................................................. 2
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`III. The Present Petition ............................................................................... 2
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`A. Anderson .......................................................................................... 3
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`B. Hinman ............................................................................................. 4
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`1. Hinman Does Not Teach a Selected Thermal Mass .................... 5
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`2. Hinman is Not Analogous Art ..................................................... 5
`
`(a) Hinman is not in the “Same Field of Endeavor”
`as Claim 13 ........................................................................... 6
`(b) Hinman is not “reasonably pertinent to the
`problem faced by the inventor” ............................................ 7
`(c) There would be no motivation to combine
`Hinman with the other cited art ............................................ 10
`IV. Conclusion ............................................................................................. 12
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`Inter Partes Review of U.S. Patent No. RE40,264
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`TABLE OF AUTHORITIES
`Cases Page(s)
`
`In re Bigio,
`381 F.3d 1320 (Fed. Cir. 2004)........................................................................... 7
`
`In re Kahn,
`441 F.3d 977 (Fed. Cir. 2006)........................................................................... 10
`
`KSR Int’l Co. v. Teleflex, Inc.,
`550 U.S. 398 (2007) .......................................................................................... 10
`
`Statutes Page(s)
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`37 C.F.R. § 42.107 .............................................................................................. 1
`
`MPEP § 2141.01(a) ............................................................................... 6, 7, 8, 11
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`Inter Partes Review of U.S. Patent No. RE40,264
`IPR2017-00279
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`Daniel L. Flamm, Sc.D., the sole inventor and owner of the U.S. Patent No.
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`RE40,264 (“the ‘264 patent”), through his counsel, submits this preliminary
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`response pursuant to 37 C.F.R. § 42.107 and asks that the Patent Trial and Appeals
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`Board decline to institute inter partes review on the instant petition because the
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`petition fails to show a reasonable likelihood that any challenged claim is
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`unpatentable.
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`I.
`
`Introduction
`
`This is not the first challenge to the validity of the ‘264 patent through inter
`
`partes review. Lam Research Corp. filed seven IPRs on this patent and Samsung
`
`filed two more. Petitioners, in addition to this IPR, have filed three more IPRs on
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`the ‘264 patent. Thirteen IPRs directed toward one patent, invented and owned by
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`an individual, Dr. Daniel Flamm.
`toward claims
`Of those thirteen petitions, this is the fourth petition directed
`13-26, 64-65 of the ‘264 patent. The Board previously denied institution in all
`three of the prior petitions.
` (Lam Research Corp. v. Flamm, IPR2015-01759,
`Paper No. 7 (Feb. 24, 2016); Lam Research Corp. v. Flamm, IPR2016-00468,
`Paper No. 6 (June 30, 2016); and Samsung Electronics Co., Ltd. v. Flamm,
`IPR2016-01510, Paper No. 6 (Feb. 14, 2017).) Each was denied for failure to
`present prior art teaching the final element of claim 13. The Board, in ruling on
`the Samsung petition, stated:
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`Putting aside that this is the third challenge to claims 13-26, 64, and
`65 of the ’264 patent, albeit by a different petitioner, the instant
`Petition suffers from the same thematic problem present in the
`previous petitions filed by Lam, because the proffered combination
`does not account properly for “the thermal mass of the substrate
`holder is selected for a predetermined temperature change within a
`specific interval of time during processing,” as recited in independent
`claim 13.
`(Samsung, IPR2016-01510, Paper No. 6 at 19.) The instant petition suffers the
`same flaw and, for that reason, it should meet the same fate: denial of institution.
`
`II. Overview of the ‘264 Patent
`
`The invention set forth in the ‘264 patent provides a method “for etching a
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`substrate,” including “a chamber and a substrate holder.” (Ex. 1001 at Abstract.)
`
`Multiple etching temperatures are employed; the change being “from a first
`temperature to a second temperature within a characteristic time period.” (Id.)
`
`While methods involving the use of various temperatures for manufacturing
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`semiconductors were known in the art prior to the ‘264 patent, none of the prior art
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`discloses a predetermined temperature change within a specific interval of time.
`III. The Present Petition
`Petitioners posit two prior art references, Anderson and Hinman, contending
`that they teach the final element of claim 13, i.e., “the thermal mass of the
`substrate holder is selected for a predetermined temperature change within a
`specific interval of time during processing.” Neither does, but rather both teach
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`away from the claimed combination in independent claim 13.
`A. Anderson
`This is the same Anderson reference that Samsung relied on in its Petition on
`Claim 13, et. al. (See Samsung, IPR2016-01510, Paper No. 6 at 8.) In rejecting
`that petition, the Board said this about Anderson:
`Neither Incropera nor Anderson remedy the deficiency in Okada I
`identified above, because Samsung’s reliance on their respective
`teachings is tenuous at best. In our view, Incropera and Anderson
`both stand for essentially the same proposition—namely, whether a
`solid object is of low or high thermal mass impacts the rate at which it
`changes temperature. Compare [Incropera] 228 (disclosing that
`equation 5.6 “may be used to compute the temperature reached by a
`solid at some time t”), with [Anderson] 6:24–28 (disclosing changing
`temperate in a matter of seconds, which requires a chuck with “low
`thermal mass”). This particular proposition tells us little, if anything,
`about selecting the mass of a substrate holder in order to ensure that
`the substrate holder changes a specific temperature over a discrete
`period of time. For instance, merely demonstrating that a chuck with
`low thermal mass has the ability to change temperatures rapidly is no
`more a specific teaching of the limitation at issue than demonstrating
`that a chuck with high thermal mass is less conducive to rapid
`temperature change.
` In other words, although Incropera and
`Anderson both demonstrate that there is a mathematical relationship
`between thermal mass and the rate of temperature change, these
`references do not disclose that it was known to select a substrate
`holder having a particular thermal mass based on this mathematical
`relationship.
`(Samsung, IPR2016-01510, Paper No. 6 at 19-20.)
`Further, Anderson teaches nothing about the “thermal mass of the substrate
`holder.” In the sole reference to thermal mass in the patent, Anderson is referring
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`to the “thermal mass of the heater employed.” (Ex. 1011 at 6:24-28.) If anything,
`Anderson teaches away from ‘264 by focusing on the thermal mass of the heater
`instead of the thermal mass of the substrate holder.
`Petitioners erroneously assert that:
`Anderson disclosed selecting the thermal mass of a substrate holder
`material to effect temperature changes in etch tools. According to
`Anderson, a substrate holder with a “low thermal mass” material near
`the surface was selected to rapidly change from room temperature to
`100°C-500°C in a matter of seconds.
`(Pet. at 34 (emphasis added).)
`Similarly, the parallel statement of Petitioners’ expert is equally false:
`Anderson also disclosed selecting a substrate holder having a low
`thermal mass in order to ensure that a particular temperature change
`occurred in a particular period of time.
`(Ex. 1006 ¶ 172 (emphasis added).)
`
`B. Hinman
`1. Hinman Does Not Teach a Selected Thermal Mass
`The 1949 patent to Hinman fails to teach “wherein the thermal mass of the
`substrate holder is selected for a predetermined temperature change within a
`specific interval of time during processing,” of the ‘264 patent. A careful reading
`of column 2 lines 59-63 explicitly recites:
`This can be readily provided through the use of a metal ring member
`34 having a thermal mass of about 5-10 times or more of the thermal
`mass of the total liquid in the cuvettes.
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`(Ex. 1010 at 2:59-63.) That is, Hinman did not have a thermal mass “selected,” but
`rather taught an indefinite range of thermal mass from 5-10 and more, which
`teaches away from any concept of selected thermal mass.
`Additionally, Hinman used a metal ring having a thermal mass relative to the
`thermal mass of the total liquid in the cuvettes, which does not disclose that the
`claimed thermal mass of a substrate holder is selected for a predetermined
`temperature change within a specific interval of time during processing.”
`Accordingly, Hinman still lacks the claimed feature of the ‘264 patent.
`There is no correspondence between the elements in Hinman and the
`substrate and substrate holder of the ‘264 patent. If, hypothetically, it were argued
`that Hinman’s liquid was analogous to a substrate, then cuvettes might be
`analogized to a substrate holder. Hinman, however, is silent about the thermal
`mass of cuvettes because they are initially at the final desired temperature value
`(Ex. 1010 at 3:14-15) and are at that same final temperature value (id. at 3:37-38)
`before the Hinman wet chemistry test period begins (id. at 1:28-29).
`
`2. Hinman is Not Analogous Art
`The courts and the Patent and Trademark Office apply a two-part test:
`[A] reference is analogous art to the claimed invention if: (1) the
`reference is from the same field of endeavor as the claimed invention
`(even if it addresses a different problem); or (2) the reference is
`reasonably pertinent to the problem faced by the inventor (even if it is
`not in the same field of endeavor as the claimed invention).
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`MPEP § 2141.01(a).
`(a) Hinman is not in the “Same Field of Endeavor” as
`Claim 13.
`The ‘264 patent, and specifically claim 13 thereof, pertain to semiconductor
`fabrication. The claim begins: “A method of etching a substrate in the
`manufacture of a device . . . .” (Ex. 1001 at 20:51-52.) Hinman, by contrast,
`pertains to, as it is entitled, a “Temperature Control Apparatus For A Centrifugal-
`Type Chemistry Analyzer.” (Ex. 1010 at 1.) The first paragraph of its
`specification further explains:
`More particularly, the present invention is directed to a temperature
`control system for controlling the temperature of small volumes of
`liquid undergoing analysis in a centrifugal-type chemistry analyzer.
`(Id. at 1:5-9.)
`Petitioners contend, without citing any pertinent law, that Hinman is
`“analogous art relating to the field of multi-temperature control in chemical
`processes.” (Pet. at 36) It is doubtful that anyone heard of this field prior to
`Petitioners’ conjuring of it. The law, which Petitioners studiously avoid, provides
`guidelines for determining what is and what is not analogous art. The Federal
`Circuit has held:
`This [field of endeavor] test for analogous art requires the PTO to
`determine
`the appropriate field of endeavor by reference
`to
`explanations of the invention's subject matter in the patent application,
`including the embodiments, function, and structure of the claimed
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`invention. See Wood, 599 F.2d at 1036 (confining the field of
`endeavor to the scope explicitly specified in the background of the
`invention); see also Deminski, 796 F.2d at 442 (determining that the
`cited references were within the same field of endeavor where they
`“have essentially the same function and structure”).
`In re Bigio, 381 F.3d 1320, 1325-26 (Fed. Cir. 2004).
`The “subject matter” of the ‘264 patent and the “embodiments, function, and
`structure of the claimed invention” establish that the “field of endeavor” is etching
`a substrate; the preamble to the claim states: “A method of etching a substrate in
`the manufacture of a device.” (Ex 1001 at 20:51-52.) Hinman’s “Temperature
`Control Apparatus For A Centrifugal-Type Chemistry Analyzer” is not in this field
`of endeavor.
`
`(b) Hinman is not “reasonably pertinent to the problem
`faced by the inventor.”
`The second prong of the analogous art analysis, as cited above, is whether
`“the reference is reasonably pertinent to the problem faced by the inventor (even if
`it is not in the same field of endeavor as the claimed invention).” As explained in
`the MPEP:
`In order for a reference to be “reasonably pertinent” to the problem, it
`must “logically [] have commended itself to an inventor’s attention in
`considering his problem.” In re Icon Health and Fitness, Inc., 496
`F.3d 1374, 1379-80 (Fed. Cir. 2007) (quoting In re Clay, 966 F.2d
`656,658, 23 USPQ2 1058, 1061 (Fed. Cir. 1992)). A recent decision
`from the U.S. Court of Appeals for the Federal Circuit, In re Klein,
`647 F.3d 1343, 98 USPQ2d 1991 (Fed. Cir. 2011), is instructive as to
`the “reasonably pertinent” prong for determining whether a reference
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`is analogous art. In determining whether a reference is reasonably
`pertinent, an examiner should consider the problem faced by the
`inventor, as
`reflected—either explicitly or
`implicitly—in
`the
`specification. In order to support a determination that a reference is
`reasonably pertinent, it may be appropriate to include a statement of
`the examiner’s understanding of the problem. The question of
`whether a reference is reasonably pertinent often turns on how the
`problem to be solved is perceived. If the problem to be solved is
`viewed in a narrow or constrained way, and such a view is not
`consistent with the specification, the scope of available prior art may
`be inappropriately limited. It may be necessary for the examiner to
`explain why an inventor seeking to solve the identified problem would
`have looked to the reference in an attempt to find a solution to the
`problem, i.e., factual reasons why the prior art is pertinent to the
`identified problem.
`MPEP at 2141.01(a) (emphasis added).
`Looking to ‘264 specification, it is clear that Dr. Flamm was addressing a
`problem in semiconductor etching: specifically, increased throughput while
`maintaining high etch selectivity. As the Summary of Invention of the ‘264 patent
`states:
`The present invention provides a technique, including a method and
`apparatus, for fabricating a product . . . . It overcomes serious
`disadvantages of prior art methods in which throughput and etching
`rate were lowered in order to avoid excessive device damage to a
`workpiece. . . .
`In another aspect, the present invention provides a process …to
`achieve high etch rates while simultaneously maintaining high etch
`selectivity between a layer which is being pattered or removed other
`material layers.
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`(Ex. 1001 at 2:7-14, 2:30-341.)
`The Hinman art would not “logically have commended itself to an inventor’s
`attention in considering his [the ‘264] problem.” Further, it would take a fruitful
`imagination to “explain why an inventor seeking to solve the identified problem
`[i.e., increased semiconductor throughput while maintaining selectivity] would
`have looked to the [Hinman] reference in an attempt to find a solution to the
`problem.”
`Hinman teaches away from the present invention for at least the following
`reasons:
`1)
`
`Hinman discloses “a temperature control system for (keeping the
`temperature of liquid in [a] cuvette constant) controlling the
`temperature of small volumes of liquid undergoing analysis” (Ex.
`1010 at 1:6-8), which teaches away from changing temperature while
`etching in a semiconductor process for the manufacture of a device of
`the ‘264 patent;
`Hinman discloses “liquid undergoing analysis in a centrifugal-type
`chemistry analyzer” (id. at 1:8-9), which teaches away from a method
`for manufacture of a device using a substrate holder in a vacuum
`chamber of the ‘264 patent;
`Hinman discloses “a combined volume of 300-600 milliliters into a
`series of cuvettes arranged around the periphery of a rotor” (id. at
`1:13-15), which teaches away from a substrate holder in a vacuum
`chamber of the ‘264 patent.
`Petitioners, to the extent that they address the analogous art issue at all,
`
`1 In both of these quotations, material that pertained to the solution to problem
`rather than the problem itself was omitted.
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`2)
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`3)
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`focus on the ‘264’s solution to the problem, rather than the problem itself. They
`argue:
`The rationale for combining Muller, Matsumura, Anderson, and
`Hinman is further reinforced because they are analogous art relating to
`the field of multi-temperature control in chemical processes. Muller
`and Hinman both sought to solve the same problem of carrying out
`rapid temperature changes as part of chemical processes.
`(Pet. at 36 (emphasis added, citation omitted).)
`The relevant “problem” to be addressed is the problem that the ‘264 inventor
`faced before the invention was made, i.e., increased throughput while maintaining
`or increasing high etch selectivity. Temperature had nothing to do with the
`problem; it only had to do with the solution to the problem. For that reason as well,
`Hinman is not analogous art.
`(c) There would be no motivation to combine Hinman
`with the other cited art.
`Even if Hinman were considered to be analogous prior art, petitioners have
`not presented a valid showing of a motivation to combine.
`As the Board held in denying Lam’s petition in IPR2015-01766:
`A showing of obviousness must be supported by an articulated
`reasoning with rational underpinning to support a motivation to
`combine the prior art teachings. KSR Int’l Co. v. Teleflex, Inc., 550
`U.S. 398, 418 (2007) (citing In re Kahn, 441 F.3d 977, 988 (Fed. Cir.
`2006) (“[R]ejections on obviousness grounds cannot be sustained by
`mere conclusory statements; instead, there must be some articulated
`reasoning with some rational underpinning to support the legal
`conclusion of obviousness.”)). As explained in KSR, “a patent
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`composed of several elements is not proved obvious merely by
`demonstrating that each of its elements was, independently, known in
`the prior art.” Id.
`(Lam Research Corp. v. Flamm, IPR2015-01766, Paper No. 7 (Feb. 24, 2016).)
`Petitioners contend that “a skilled person would have been motivated to use
`Hinman’s teaching” (Pet. at 35), but they do not explain why; they do not provide
`“articulated reasoning with rational underpinning to support a motivation to
`combine the prior art teachings.” Petitioners’ attempt to rely on the solution to the
`problem rather than the problem itself, as discussed above, is impermissible
`hindsight. As expounded in the MPEP: “the examiner must step backward in time
`and into the shoes worn by the hypothetical ‘person of ordinary skill in the art’
`
`when the invention was unknown and just before it was made.” MPEP § 2142.
`
`Obviously, at that point, before the invention was made, the skilled artisan would
`know only the problem, not the solution. Therefore, Petitioners’ reliance on
`“multi-temperature control in chemical processes” and “rapid temperature changes
`as part of chemical processes,” (Pet. at 36), is impermissible hindsight. The MPEP
`further admonishes: “Knowledge of applicant’s disclosure must be put aside in
`reaching this determination,” and “impermissible hindsight must be avoided and
`the legal conclusion must be reached on the basis of the facts gleaned from the
`prior art.” MPEP § 2142.
`This is precisely what petitioners are not doing. Again, the problem—just
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`throughput while
`increase
`to
`before the invention was made—was how
`maintaining selectivity. The only way that temperature and rapid temperature
`changes enter the fray is by having “[k]nowledge of applicant’s disclosure,” which
`“must be put aside in reaching this determination.”
`
`IV. Conclusion
`For the foregoing reasons, the Board should deny institution of this fourth
`petition directed toward claim 13 and its dependent claims just as it did with
`respect to the three that preceded it.
`
`Respectfully Submitted,
`
`By: /Christopher Frerking, reg. no. 42,557/
` Christopher Frerking, reg. no. 42,557
`
`174 Rumford Street
`Concord, New Hampshire 03301
`Telephone: (603) 706-3127
`Email: chris@ntknet.com
`
`Counsel for Daniel L. Flamm
`
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`Date: March 14, 2017
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`CERTIFICATION OF WORD COUNT UNDER 37 C.F.R. § 42.24(d)
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`Pursuant to 37 C.F.R. 42.24(d), the undersigned hereby certifies that the
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`word count for the foregoing PATENT OWNER’S PRELIMINARY RESPONSE
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`totals 2,866, excluding the cover page, signature block, and parts exempted by 37
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`C.F.R. § 42.24(d).
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`This word count was made by using the word count function tool in
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`Microsoft Word software Version 2010.
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`Respectfully Submitted,
`
`By: /Christopher Frerking, reg. no. 42,557/
` Christopher Frerking, reg. no. 42,557
`
`174 Rumford Street
`Concord, New Hampshire 03301
`Telephone: (603) 706-3127
`Email: chris@ntknet.com
`
`Counsel for Daniel L. Flamm
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`Date: March 14, 2017
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the foregoing PATENT OWNER’S
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`PRELIMINARY RESPONSE UNDER 37 C.F.R. § 42.107 SEVENTH
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`PETITION was served by electronic mail on this day, March 14, 2017, on the
`
`David M. Tennant
`dtennant@whitecase.com
`WHITE & CASE LLP
`701 Thirteenth St., NW
`Washington, DC 20005
`(202) 626-3600
`
`Nathan Zhang
`nathan.zhang@whitecase.com
`WHITE & CASE LLP
`3000 El Camino Real
`5 Palo Alto Square, 9th Floor
`Palo Alto, CA 94306
`(650) 213-0300
`
`WCGlobalFoundries-
`FlammTeam@whitecase.com
`
`Counsel for GLOBALFOUNDRIES
`U.S., Inc.
`
`following individuals:
`
`
`Jonathan McFarland
`JMcfarland@perkinscoie.com
`PERKINS COIE LLP
`1201 Third Ave., Suite 4900
`Seattle, WA 98101
`(206) 359-8000
`
`Daniel Keese
`DKeese@perkinscoie.com
`PERKINS COIE LLP
`1120 NW Couch St., 10th Floor
`Portland, OR 97209
`(503) 727-2000
`
`Chad S. Campbell
`CSCampbell@perkinscoie.com
`Tyler Bowen
`TBowen@perkinscoie.com
`PERKINS COIE LLP
`2901 North Central Ave., Suite 2000
`Phoenix, AZ 85012
`(602) 351-8000
`
`Intel-Flamm-Service-
`IPR@perkinscoie.com
`
`Counsel for Intel Corporation
`
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`Jared Bobrow
`Jared.bobrow@weil.com
`Jeremy Jason Lang
`Jeremy.lang@weil.com
`WEIL, GOTSHAL & MANGES LLP
`201 Redwood Shores, CA 94065
`(650) 802-3000
`
`Micron.flamm.service@weil.com
`
`Counsel for Micron Technology, Inc.
`
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`By: /Christopher Frerking, reg. no. 42,557/
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