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