By: Christopher Frerking (chris@ntknet.com)
`Reg. No. 42,557
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MICRON TECHNOLOGY, INC., INTEL CORPORATION
`
`AND GLOBALFOUNDRIES U.S., INC.
`
`Petitioners
`
`V.
`
`DANIEL L. FLAMM,
`
`Patent Owner
`
`CASE IPR2017-0391
`
`U.S. Patent No. 6,017,221
`
`DECLARATION OF DANIEL L. FLAMM, Sc.D.
`
`1, Daniel L.‘ Flamm, Sc.D., hereby declare as follows:
`
`1.
`
`I am a U.S. patent attorney, and member of the California State Bar.
`
`Prior to this, I worked in academia, research, and industry in various roles for more
`
`than 50 years. My curriculum vitae, which includes a more detailed summary of
`
`my background, experience, and publications, is attached as Appendix A.
`
`1
`
`Exhibit 2001
`IPR2017-0391
`
`
`Reg. No. 42,557
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MICRON TECHNOLOGY, INC., INTEL CORPORATION
`
`AND GLOBALFOUNDRIES U.S., INC.
`
`Petitioners
`
`V.
`
`DANIEL L. FLAMM,
`
`Patent Owner
`
`CASE IPR2017-0391
`
`U.S. Patent No. 6,017,221
`
`DECLARATION OF DANIEL L. FLAMM, Sc.D.
`
`1, Daniel L.‘ Flamm, Sc.D., hereby declare as follows:
`
`1.
`
`I am a U.S. patent attorney, and member of the California State Bar.
`
`Prior to this, I worked in academia, research, and industry in various roles for more
`
`than 50 years. My curriculum vitae, which includes a more detailed summary of
`
`my background, experience, and publications, is attached as Appendix A.
`
`1
`
`Exhibit 2001
`IPR2017-0391
`
`
`
`2.
`
`I have been a leading researcher and educator in the fields of
`
`semiconductor processing technology, air pollution control, materials science, and
`
`other areas of chemical engineering. My research has been funded by NASA,
`
`National Science Foundation, Environmental Protection Agency, and AT&T Bell
`
`Laboratories. While a Distinguished Member of Technical Staff at Bell
`
`Laboratories,
`
`I
`
`led a semiconductor processing research group comprised of
`
`research colleagues, visiting university scientists, postdoctoral associates, and
`
`summer students.
`
`I have also served as a technical consultant
`
`to various
`
`semiconductor device and processing equipment manufacturers.
`
`3.
`
`I have published over 150 technical journal articles and books, and
`
`dozens of articles in conference proceedings, most of them in highly competitive
`
`refereed conferences and rigorously reviewed journals.
`
`I am an inventor in more
`
`than 20 U.S. patents, a number of which have been licensed, and most being in the
`
`general field of semiconductor processing technology.
`
`4.
`
`I had experience studying and analyzing patents and patent claims
`
`from the perspective of a person having ordinary skilled in the art (“PHOSITA”)
`
`starting at least at the time of my employment at AT&T Bell Laboratories in 1977.
`
`At AT&T Bell Laboratories, I served as a member of the patent licensing review
`
`committee where I was responsible for reviewing hundreds of patents for potential
`
`utility and licensing potential.
`
`I have also served as a technical expert in patent
`
`2
`
`Exhibit 2001
`IPR2017-0391
`
`
`
`disputes and litigation.
`
`5.
`
`I was admitted to the patent bar as an Agent in 2003 and have been
`
`registered as a Patent Attorney since 2006.
`
`6.
`
`I am inventor of U.S. Patent No. 6,017,221, in the name of Daniel L.
`
`Flamm and titled “Process Depending on Plasma Discharges Sustained by
`
`Inductive Coupling” (“the ‘221 Patent”).
`
`7.
`
`I have read the Petitioners Petition for Inter Partes Review in this
`
`matter and the various art cited therein, including, among others, Lieberman (Ex.
`
`1006) and Dible (Ex. 1007).
`
`I have also reviewed the ‘Z21 patent and the art cited
`
`below.
`
`8.
`
`Lieberman provides no means to adjust or control anything. The
`
`isolated secondary winding in the conventional magnetic flux coupled balanced
`
`transformer suggested by Lieberman cannot control the coil potential because it is
`
`floating.
`
`Its voltage and voltage distribution when it is coupled to a processing
`
`chamber is determined by the detailed coupling of elements of the coil to process-
`
`specific plasma conditions and compositions.
`
`9.
`
`Lieberman teaches a conventional balanced magnetic transformer,
`
`which is not a balun.
`
`10. A magnetic transformer is not a balun transformer; it is an essentially
`
`different thing. A conventional magnetically coupled transformer, such as depicted
`
`3
`
`Exhibit 2001
`lPR2017-0391
`
`
`
`by Lieberman, transmits input energy to the output circuit through magnetic flux
`
`linkage, and the conventional
`
`transformer
`
`is capable of DC isolation.
`
`A
`
`conventional transformer suffers from large core and winding losses as frequency
`
`increases and inherently suffers from even higher disproportionate losses in higher
`
`power applications, such as here, powering a processing chamber plasma.
`
`11. A balun transformer is a transmission line transformer that depends on
`
`coupling input energy to a load using a transverse transmission line mode, wherein
`
`an electromagnetic field is completely contained within the transmission line.
`
`In a
`
`balun transmission line transformer, unlike conventional transformers, the magnetic
`
`flux is effectively canceled out in the core, whereby far higher efficiencies can be
`
`obtained over a far wider range of frequencies. A balun transformer, unlike the
`
`conventional magnetic transformer, is not capable of DC isolation because a balun
`
`requires a conductive connection to ground to be functional.
`
`12.
`
`A PHOSITA having expertise in high frequency matching systems
`
`would have recognized that in practice Lieberman’s coil midpoint, the so-called
`
`virtual ground, would not maintain ground potential when powering a plasma
`
`during processing. Because the transformer secondary is “floating,” all positions
`
`along the coil have no determinable voltage relative to ground before a load
`
`coupled to ground is provided. Having the midpoint coil voltage be midway from
`
`the upper and lower end voltages of the coil requires that the upper (above the
`
`4
`
`Exhibit 2001
`IPR2017-0391
`
`
`
`midpoint) and lower segments of the coil be coupled to identical
`
`loads (the
`
`capacitive and inductive coupling between the plasma and coil must be axially and
`
`radially symmetric about a midpoint).
`
`This,
`
`in turn, requires plasma sheath
`
`thickness and plasma density (and potential) at all positions above the midpoint to
`
`be a mirror image of the values below the midpoint, which is unlikely or impossible
`
`to occur where the plasma source is coupled to a processing chamber.
`
`13.
`
`Plasma processing requires that plasma stream from the source toward
`
`the workpiece in the chamber.
`
`Since the streaming creates a plasma density
`
`gradient along the vertical axis in cylindrical geometry there is no midpoint load
`
`symmetry.
`
`14.
`
`If the transformer secondary is “floating,” as Lieberman has stipulated,
`
`the values of all of the voltages along the coil, and in particular those of the upper
`
`end of the coil, the lower end of the coil, and the midpoint, will depend on the
`
`detailed “load” (e.g.,
`
`the plasma density,
`
`its spatial distribution,
`
`the plasma
`
`potential, and position of the inductive plasma current ring). This is because the
`
`voltage drop (voltage difference) between the midpoint and one end of any
`
`physical coil, and particularly one carrying high frequency current, varies with the
`
`local value of load coupled to that portion of the physical coil.
`
`15.
`
`The proposition that voltage would be reduced by a factor of two is
`
`flawed. That is at least because the geometric extent and position of the induced
`
`5
`
`Exhibit 2001
`19112017-0391
`
`
`
`plasma current ring (inductively coupled plasma absorbing power) depends on the
`
`detailed distribution of current along the applicator coil. Since Lieberman never
`
`clearly defines a reference configuration such as the electrical length (wavelength
`
`portion) of a coil, (other than stating itis “similar to helicon antennas” (Ex. 1002 at
`
`52)), and since the magnitude of voltage and power that are necessary to sustain a
`
`preselected local plasma density depends on how an applicator is powered, the
`
`relative voltages are indeterminate.
`
`16.
`
`Lieberman does not teach balancing any currents, whether they are
`
`capacitively coupled or phase and anti-phase portions as claimed, and Lieberman
`
`does not disclose or distinguish phase and anti-phase capacitively coupled currents
`
`as claimed.
`
`Lieberman’s conventional
`
`transformer has nothing operable to
`
`selectively balance any capacitive currents, not anything operable to adjust any
`
`phase and anti-phase portions of capacitive currents.
`
`17.
`
`Lieberman’s floating applicator coil and its isolated transformer
`
`secondary have no ground. The midpoint of Lieberman’s coil is only a midpoint.
`
`This midpoint is not a virtual ground because Lieberman has nothing to maintain
`
`the midpoint, nor any other portion of the coil, at a reference potential.
`
`18.
`
`Based on the current
`
`record,
`
`I declare neither Lieberman nor
`
`Lieberman in view of Dibble teach or suggest all of the limitations required by
`
`independent claims 1 or dependent claims 4 or 5-7.
`
`5
`
`Exhibit 2001
`IPR2017—0391
`
`
`
`I declare under penalty of perjury under the laws of the United States of
`
`America that the foregoing is true and correct.
`
`Executed March 14, 2017
`
`Walnut Creek, California
`
`Daniel L. Flamm
`
`Exhibit 2001
`IPR2017—0391
`
`
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