By: Christopher Frerking (chris@ntknet.com)
`
`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
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`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
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`
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`PATENT OWNER’S PRELIMINARY RESPONSE
`UNDER 37 C.F.R. § 42.107
`Claims 56-63 & 70-71
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`Inter Partes Review of U.S. Patent No. 6,071,221
`IPR2017-0391
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`TABLE OF CONTENTS
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`Page(s)
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`TABLE OF CONTENTS ...................................................................................... i
`TABLE OF AUTHORITIES ................................................................................ iii
`EXHIBIT LIST ..................................................................................................... iv
`I.
`Introduction ........................................................................................... 1
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`II. Overview of the ‘221 Patent .................................................................. 2
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`III. Ground 1—Lieberman ........................................................................... 3
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`A. Claim Element [1.2] .................................................................... 3
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`B. Claim Element [1.3] .................................................................... 10
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`IV. Ground 2—Dible ................................................................................... 11
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`A. Claim Element [1.2] .................................................................... 12
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`B. Claim Element [1.3] .................................................................... 14
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`V. Ground 3— Lieberman, or Lieberman
`In View of Dible, In View of Hanawa .................................................. 16
`A. Claim 2 ........................................................................................ 16
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`B. Claim 3 ........................................................................................ 17
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`VI. Ground 3—Qian .................................................................................... 17
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`VII. Ground 6—Qian in View of Hanawa .................................................... 19
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`A. Claim 2 ........................................................................................ 19
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`B. Claim 3 ........................................................................................ 20
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`VIII. Dependent Claims ................................................................................. 21
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`IX. Conclusion ............................................................................................. 22
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`Inter Partes Review of U.S. Patent No. 6,071,221
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`
`TABLE OF AUTHORITIES
`Cases Page(s)
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`Hartness Int’l Inc. v. Simplimatic Eng. Co.,
`819 F.2d 1100 (Fed. Cir. 1987)......................................................................... 11
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`Kimberly Clark Corp. v. Johnson & Johnson,
`745 F.2d 1437 (Fed. Cir. 1984)......................................................................... 11
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`Statutes Page(s)
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`37 C.F.R. § 42.107 .............................................................................................. 1
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`MPEP § 2143.03 ............................................................................................... 11
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`Inter Partes Review of U.S. Patent No. 6,071,221
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`EXHIBIT LIST
`
`Declaration of Daniel L. Flamm, Sc.D.
`U.S. Pat. No. 5,824,606
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`Ex. 2001
`Ex. 2002
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`iv
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`Inter Partes Review of U.S. Patent No. 6,071,221
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`Daniel L. Flamm, Sc.D., the sole inventor and owner of the U.S. Patent No.
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`6,017,221 (“the ‘221 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 claim is unpatentable.
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`I.
`
`Introduction
`
`This is not the first challenge to the validity of the ‘221 patent through inter
`
`partes review.
`
` Lam Research Corp. sells tools used in semiconductor
`
`manufacturing to entities such as the Petitioners and Samsung Electronics Co., Ltd.
`
`Lam filed a petition for inter partes review of the ‘221 patent. Lam also
`
`commenced an action in the Northern District of California seeking a declaration,
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`inter alia, that neither it nor its products infringe the ‘221 patent.
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`The Board instituted the inter parties review filed by Lam based upon an
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`incorrect characterization of Lieberman, the same art on which Petitioners rely,
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`which Dr. Flamm responded by a correct characterization in the Patent Owner’s
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`Response in IPR2015-01767. The Board instituted review on claims 1, 4, and 5-7,
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`but then then terminated in light of a settlement agreement negotiated between
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`Lam and Dr. Flamm.
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`The instant petition is directed toward independent claim 1 and all of the
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`claims that depend from those claims. Petitioners rely primarily on three
`1
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`Inter Partes Review of U.S. Patent No. 6,071,221
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`references, Lieberman, Dible, and Qian, in their attempt to invalidate ‘221 patent.
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`As will be demonstrated, those references, alone or in combination of with the
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`additional references relied upon, fail to provide a basis for inter partes review of
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`the ‘221 patent.
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`II. Overview of the ‘221Patent
`
`The problems that Dr. Flamm was addressing in making the invention of the ‘221
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`patent were reduction, elimination, and/or control of ion bombardment or ion flux
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`to semiconductor device surfaces being processed in inductively coupled plasmas,
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`while maintaining desired etching selectivity. (Ex. 1001 at 2:7-16.)
`
`Conventional ion assisted plasma etching, however, often requires
`control and maintenance of ion flux intensity and uniformity within
`selected process limits and within selected process energy ranges.
`Control and maintenance of ion flux intensity and uniformity are often
`difficult to achieve using conventional techniques. For instance,
`capacitive coupling between high voltage selections of the coil and the
`plasma discharge often cause high and uncontrollable plasma
`potentials relative to ground.
`
`(Id. at 2:64-3:2.)
`
`The specification discusses at length the “conventional techniques,”
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`including “shields, baffles, large separation distances between the plasma source
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`and the chamber.” (Id. at 2:17-19; see also generally id. at 1:44-4:57.) The
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`specification also discusses the many drawbacks of these conventional techniques.
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`(Id. at 1:44-4:57.)
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`Most particularly, Dr. Flamm’s solution, as reflected in claim 1 of the patent,
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`was to balance the phase and anti-phase portions of capacitive currents coupled
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`from the inductive coupling structure using a wave adjustment circuit. Instead of
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`suppressing the charged species, as conventional techniques had done via blockage
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`or distance, Dr. Flamm went to the source of the ion flux problem and reduced or
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`eliminated the undesired capacitive ion current flux by selectively balancing a
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`phase portion and an anti-phase portion of capacitive currents coupled form the
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`inductive coupling structure using the wave adjustment circuit.
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`III. Ground 1—Lieberman
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`A. Claim Element [1.2]
`
`The claim element denominated by Petitioners as [1.2] reads:
`
`in which a phase portion and an anti-phase portion of capacitive
`currents coupled from the inductive coupling structure are selectively
`balanced
`
`(Pet. at 30.)
`
`Petitioners rely exclusively on Lieberman. Lieberman fails to disclose a
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`phase portion and an anti-phase portion of capacitive currents coupled from the
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`inductive coupling structure. At best, Lieberman discloses an inductive coil push-
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`pull via a balanced transformer, which is silent on the phase portion and the anti-
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`phase portion of capacitive currents. As shown in Figure 2A of the ‘221 patent, the
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`phase portion and the anti-phase portion of the capacitive currents from the
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`inductive coupling structure are selectively balanced.
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`Petitioners misinterpret Lieberman as disclosing phase and anti-phase
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`portions of capacitive currents with the inductive “coil can be driven push-pull
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`using a balanced transformer.” (Ex. 1006 at 56.)
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`A PHOSITA would not have understood Lieberman’s choice to drive the
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`inductive coil “push-pull” to correspond to the claimed “phase and an anti-phase
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`portion of capacitive currents . . . are selectively balanced.” Additionally, the
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`phase voltages do not “push” capacitively coupled current into the plasma while
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`the anti-phase voltages “pull” capacitively coupled current out of the plasma as
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`argued by Petitioners. (Ex. 1001 at 16:18-45.)
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`Further, a PHOSITA would not have understood what is alleged to be
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`Lieberman’s “balanced transformer, which places a virtual ground in the middle of
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`the coil,” to be a balun that results in a voltage distribution on the inductive coil
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`that is symmetric about the midpoint. Rather, the thing that the ‘221 Patent
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`discloses as a wave adjustment circuit produces balanced phase and anti-phase
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`potentials and currents. (Ex. 1001 at 16:18-45.)
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`Lieberman also fails to teach said inductive coupling structure is adjusted
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`using a wave adjustment circuit. In particular, the capacitive currents referenced in
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`Lieberman are not the same as the capacitive currents in the ‘221 patent.
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`Lieberman makes it very clear that he considers only the capacitive current
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`proportional to the coil voltage in saying: “using a balanced transformer . . .
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`reduces [sic] the maximum coil-to-plasma voltage by a factor of two” (singular)
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`“reduces the undesired capacitively couple rf current flowing from coil to plasma”
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`(singular). (Ex. 1006 at 56.) In other words, Lieberman concerns only a
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`magnitude of capacitive current flowing from a momentary positive portion of the
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`coil to the plasma (and, thus, returning from the plasma to a momentary negative
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`portion of the coil). This is not the subject of Claim 1, and does not teach a phase
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`and anti- phase portion of capacitive currents in the manner claimed.
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`In contrast, rather than a magnitude, claim 1 mainly concerns selectively
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`balancing the vector sum of phase and anti-phase currents flowing from the coil as
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`a whole to the plasma—the selected difference current, if any, flows through the
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`plasma to grounded chamber bodies, the wafer chuck, etc. The current magnitude
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`and vector sum are quite different things. The magnitude taught by Lieberman is
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`not susceptible to selective balancing. Lieberman merely addresses lowering the
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`magnitude of a current that flows in a closed path within the plasma source by
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`itself (e.g., coil to plasma and return). The ‘221 patent, on the other hand, concerns
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`using a wave adjustment circuit to selectively adjust an inductive coupling
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`structure such that the total sum of different phased amounts of current flowing
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`from an applicator (coil) into the plasma are selectively balanced, whereby a
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`selected amount of current flows from the plasma source to grounded chamber
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`bodies, the wafer chuck, etc.
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`Thus, the claim 1 sub-element “a phase portion and an anti-phase portion of
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`capacitive currents coupled from the inductive coupling structure are selectively
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`balanced” cannot be met by Lieberman because Lieberman merely teaches a static
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`structure to decrease the magnitude of plasma to coil voltage.
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`Similarly, the wave adjustment as claimed by the ‘221 patent is not taught by
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`Lieberman. Lieberman provides no means to adjust or control anything. (Ex.
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`2001 (Declaration of Daniel L. Flamm) ¶ 8.) The isolated secondary winding in
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`the conventional magnetic flux coupled balanced transformer suggested by
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`Lieberman cannot control the coil potential because it is floating. (Id.) Its voltage
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`and voltage distribution when it is coupled to a processing chamber is determined
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`by the detailed coupling of elements of the coil to process-specific plasma
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`conditions and compositions. (Id.) Accordingly, the voltages and voltage
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`distribution are not controlled; they are decided by the load encountered in a
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`specific condition.
`
` Lieberman has nothing operable to adjust a voltage
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`distribution, let alone adjusting an inductive coupling structure using a wave
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`adjustment circuit or adjusting phase and anti-phase portions of the capacitively
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`coupled currents.
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`In its decision instituting review on Lam’s IPR215-01767, the Board wrote:
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`As Petitioner points out, the ‘221 patent describes an embodiment that
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`includes a wave adjustment circuit comprising a balun (balanced-
`unbalanced) toroidal transformer, where “the midpoint 406 between
`the phase 405 and anti-phase voltage on the coil is effectively rf
`grounded,” and also uses push-pull balanced coupling, which
`Lieberman also teaches.
`
`(Lam Research Corp. v. Flamm, IPR2015-01767, Decision Institution of Inter
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`Partes Review, Paper 10 at 26-27 (Feb. 24, 2015).) Lam’s allegation is both
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`contrary to fact and bad science for at least the following reasons. Lieberman
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`teaches a conventional balanced magnetic transformer, which is not a balun. (Ex.
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`2001 ¶ 9.) A magnetic transformer is not a balun transformer; it is an essentially
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`different thing. (Id. ¶ 10.) A conventional magnetically coupled transformer, such
`
`as depicted by Lieberman, transmits input energy to the output circuit through
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`magnetic flux linkage, and the conventional transformer is capable of DC isolation.
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`(Id.) However, a conventional transformer suffers from large core and winding
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`losses as frequency
`
`increases and
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`inherently suffers from even higher
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`disproportionate losses in higher power applications, such as here, powering a
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`processing chamber plasma. (Id.)
`
`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. (Id.
`
`¶ 11.) In a balun transmission line transformer, unlike conventional transformers,
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`the magnetic flux is effectively canceled out in the core, whereby far higher
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`efficiencies can be obtained over a far wider range of frequencies. (Id.) A balun
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`transformer, unlike the conventional magnetic transformer, is not capable of DC
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`isolation because a balun requires a conductive connection to ground to be
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`functional. (See id.; see also Ex. 1001 at 16:32-:36.)
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`Moreover, 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. (Ex. 2001 ¶ 12.) Because the transformer secondary is
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`“floating,” all positions along the coil have no determinable voltage relative to
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`ground before a load coupled to ground is provided. (Id.) Having the midpoint
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`coil voltage be midway from the upper and lower end voltages of the coil requires
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`that the upper (above the midpoint) and lower segments of the coil be coupled to
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`identical loads (the capacitive and inductive coupling between the plasma and coil
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`must be axially and radially symmetric about a midpoint). (Id.) This, in turn,
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`requires plasma sheath thickness and plasma density (and potential) at all positions
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`above the midpoint to be a mirror image of the values below the midpoint, which is
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`unlikely or impossible to occur where the plasma source is coupled to a processing
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`chamber. (Id.)
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`First, plasma processing requires that plasma stream from the source toward
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`the workpiece in the chamber. (Id. ¶ 13.) Since the streaming creates a plasma
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`density gradient along the vertical axis in cylindrical geometry there is no midpoint
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`load symmetry. (See id.; see also Ex. 1002 at 56, Fig. 25(a).) As for the planar
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`geometry coil, it does not even have a perceptible midpoint position. (Ex. 1002 at
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`56, Fig. 25(b).)
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`Second, if the transformer secondary is “floating,” as Lieberman has
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`stipulated, the values of all of the voltages along the coil, and in particular those of
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`the upper end of the coil, the lower end of the coil, and the midpoint, will depend
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`on the detailed “load” (e.g., the plasma density, its spatial distribution, the plasma
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`potential, and position of the inductive plasma current ring). (Ex. 2001 ¶ 14.) This
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`is because the voltage drop (voltage difference) between the midpoint and one end
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`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. (Id.)
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`Even 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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`plasma current ring (inductively coupled plasma absorbing power) depends on the
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`detailed distribution of current along the applicator coil. (Id. ¶ 15.) Since
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`Lieberman never clearly defines a reference configuration such as the electrical
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`length (wavelength portion) of a coil, (other than stating it is “similar to helicon
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`antennas” (Ex. 1006 at 55)), and since the magnitude of voltage and power that are
`
`necessary to sustain a preselected local plasma density depends on how an
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`applicator is powered, the relative voltages are indeterminate. (Id.)
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`In fact, Lieberman does not teach balancing any currents, whether they are
`
`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
`
`as claimed. (Id. ¶ 16.) Furthermore, Lieberman’s conventional transformer has
`
`nothing operable to selectively balance any capacitive currents, nor anything
`
`operable to adjust any phase and anti-phase portions of capacitive currents. (Id.)
`
`Accordingly, Lieberman fails to teach key elements of claim 1.
`
`B. Claim Element [1.3]
`
`The claim element denominated by Petitioners as [1.3] reads:
`
`wherein said inductive coupling structure is adjusted using a wave
`adjustment circuit, said wave adjustment circuit adjusting the phase
`portion and the anti-phase portion of the capacitively coupled currents.
`
`(Pet. at 36.)
`
`The ‘221 Patent provides a toroidal transformer as an example of a wave
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`adjustment circuit: “a ferrite or powdered iron core ‘balun’ (balanced-unbalanced)
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`toroidal transformer . . . can be used to provide balanced matching . . . between the
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`RF power source 122 and the coil 132.” (Ex. 1001 at 16:27-36.)
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`Although as expressed by Petitioners, Lieberman
`
`teaches
`
`that an
`
`“[inductive] coil can be driven push-pull using a balanced transformer.” (Ex. 1006
`
`at 56.) A PHOSITA would not have understood that Lieberman’s balanced
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`transformer results in “a virtual ground in the middle of the coil,” and does not
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`corresponds to the claimed “wave adjustment circuit” that adjusts “the phase and
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`anti-phase portion of the capacitively coupled currents.”
`
`IV. Ground 2—Dible
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`The ‘221 patent balances the phase portion and the anti-phase portion of the
`
`capacitive currents from an inductive coupling structure using a wave adjustment
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`circuit to adjust the inductive coupling structure in order to reduce or eliminate
`
`capacitively coupled power from the plasma source to chamber bodies. Dible
`
`teaches nothing about adjusting any inductive coupling structure in order to reduce
`
`or eliminate capacitively coupled power, adjusting phase and antiphase portions of
`
`capacitive currents from an inductive coupling structure, or any other such thing.
`
`What, Dible teaches is using two separate power sources and respective matching
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`networks to apply two separate excitation currents to two respective ends of a coil,
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`and adjusting the phase of those power sources relative to each other in order
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`purporting to thereby control the type of coupling generated, i.e., capacitive
`
`coupling, inductive coupling or some combination thereof:
`
`whereby said device becomes essentially an inductive coupling device
`when said first phase and said second phase are opposite in phase,
`said device becomes essentially a capacitive coupling device when
`said first phase and said second phase are in phase, said device
`becomes a combination inductive and capacitive coupling device
`when said first phase and said second phase differs by an angle that is
`between in phase and opposite in phase.
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`(Ex. 1007 at 10:33-:41.)
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`A. Claim Element [1.2]
`
`The claim element denominated by Petitioners as [1.2] reads:
`
`in which a phase portion and an anti-phase portion of capacitive
`currents coupled from the inductive coupling structure are selectively
`balanced”
`
`(Pet. at 42.)
`
`As stated, Dible does not disclose anything about “a phase portion and an
`
`anti-phase portion of capacitive currents” emanating from an inductive coupling
`
`structure much less that they should be “selectively balanced.” In fact Dible
`
`teaches that currents at the two terminals of an inductive coupling coil have a 180
`
`degree difference with respect to each other, which is what the conventional half-
`
`wave prior art structure that is disclosed in the ‘221 patent. (Ex. 1001 at 3:44-49.)
`
`Therefore, Dible teaches away from selectively balancing a phase portion and an
`
`anti-phase portion of capacitive currents coupled from an inductive coupling
`
`structure.
`
`Furthermore, Dible’s scheme is itself fraught with problems that a
`
`PHOSITA in the field of RF matching would immediately recognize. For example,
`
`Dible provides a circuit teaching two power supplies powering each other through
`
`a coil (the coil that Dible identifies for power to the plasma). Dible teaches
`
`nothing about managing the electrical length of the coil, nothing about controlling
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`the amplitudes of currents to the respective ends of the coil, and nothing about any
`
`means to prevent power emanating from one power supply from burning out the
`
`other power supply and/or its matching network, never mind overcoming the
`
`instability that may arise from having two independent power supplies and
`
`matching networks power the same thing. Six months after filing the ‘529 patent
`
`application, even Dibble himself admitted that keeping two generators at the same
`
`frequency and in a phase relationship, even using a master-slave arrangement, may
`
`give undesirable or unexpected process and electrical characteristics and lead to
`
`uncertain consequences on process results:
`
`While the configuration of the two generators in a master-and-slave
`configuration enables both generators to deliver power at the same RF
`frequency, such a configuration does not guarantee that power will be
`delivered by the two generators at the same phase. A phase difference
`may arise due to factors internal to the generators themselves or due to
`system parameters such as the difference in the lengths of the cables
`that couple the generators to their respective electrodes. It is
`discovered that the phase difference may give rise to undesirable or
`unexpected process and electrical characteristics, which may lead to
`uncertain consequences on the process results.
`
`(U.S. Pat. No. 5,824,606, attached hereto as Exhibit 2002, at 1:64-2:8.):
`
`Without solutions
`
`to
`
`these problems,
`
`the circuit would burn out.
`
`Furthermore, a PHOSITA would recognize that two prior art high frequency
`
`plasma power supplies and matching networks connected to each other in the
`
`manner shown would not admit an arbitrary relative phase relation between the
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`ends of the coil for reasons of stability and various other fundamental problems
`
`such as those mentioned above. Dible offers no means to impose a stable
`
`selectable phase relation on a coil by powering the plasma with two power sources
`
`in the circuits shown, and there was no prior art control circuit operable to perform
`
`the necessary function(s).
`
`The passage from Dible relied on by Petitioners make it clear that Dible is
`
`not saying anything about “selectively balance[ing]” phase and anti-phase portions
`
`of capacitive currents coupled from an inductive coupling structure. (Pet. at 42-
`
`43.) What Dible is teaching is an approach for controlling the type of coupling—
`
`inductive, capacitive, or some combination of inductive and capacitive—by
`
`adjusting the relative phases of two separate “excitation currents” from two
`
`separate “excitation source[s].” (Ex. 1007 at 2:42-56 and 4:45-55.)
`
`B. Claim Element [1.3]
`
`The claim element denominated by Petitioners as [1.3] reads:
`
`wherein said inductive coupling structure is adjusted using a wave
`adjustment circuit, said wave adjustment circuit adjusting the phase
`portion and the anti-phase portion of the capacitively coupled currents
`
`(Pet. at 44.)
`
`Even if one were to assume that Dible’s “plasma generating system” were an
`
`“inductive coupling structure,” once it were “adjusted” it would be, according to
`
`Dible, a capacitive coupling structure (or some combination coupling structure),
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`thus it would no longer an “inductive coupling structure.” (See Ex. 1007 at 4:45-
`
`55.) The claim limitation “said inductive coupling structure is adjusted using a
`
`wave adjustment circuit” is not met by Dible.
`
`While this perspective is technical, it evokes the underlying reality that the
`
`problems and solutions set forth in Dible, excepting the aspiration to invent a
`
`workable method to adjust phase, are totally alien from the problems and solutions
`
`set forth in the ‘221 patent.
`
`Additionally, Dible does not address “adjusting the phase portion and an
`
`anti-phase portion of the capacitively coupled currents.” Dible was focused
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`entirely on adjusting the phases of two separate excitation currents delivered to the
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`ends of a coil for the aspirational purpose of changing the form of coupling.
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`In short, the only aspect of Dible that relates to phase is adjusting the relative
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`phase of two RF power sources, which, of course, was long known before Dible.
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`Dible further teaches away from Flamm because it positively teaches the use
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`of capacitively coupled discharges—“When the first phase and the second phase
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`are in phase, the device essentially becomes a capacitive coupling device” (Ex.
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`1007 at 1)—the very discharges that the ‘221 patent reduces or eliminates.
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`V. Ground 3— Lieberman, or Lieberman In View of Dible, In View
`of Hanawa
`A. Claim 2
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`Claim 2 reads: “The process of claim 1 wherein the wave adjustment circuit
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`selectively adjusts a frequency of an rf power supply.” (Ex. 1001 at 23:3-4.)
`
`A combination of Lieberman and Hanawa does not show or suggest the
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`elements of claim 2. At best, Hanawa, as even argued by Petitioners, discloses the
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`concept to “adjust the power supply frequency for impedance matching.” (Pet. at
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`50.) As argued by Petitioners, Hanawa discloses a control circuit that enables
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`adjusting the variable frequency RF power source to match the impedance. (Ex.
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`1010 at 3:28-47.)
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`Hanawa, however, does not show or suggest Flamm’s invention of the wave
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`adjustment circuit selectively adjusts a frequency of an rf power supply in
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`combination with using the wave adjustment circuit to adjust the inductive
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`coupling structure and adjusting the phase portion and the antiphase portion of the
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`capacitively coupled currents of the gaseous discharge. No such concept is shown,
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`explicitly or implicitly, or suggested by Hanawa. No concept of to selectively
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`adjust is shown or suggested, as well.
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`Accordingly, Hanawa in combination with Lieberman lacks this element of
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`the ’221 patent.
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`B. Claim 3
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`Claim 3 reads: “The process of claim 1 wherein the high frequency field is
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`adjusted using a variable frequency power supply.” (Ex. 1001 at 23:5-6.)
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`A combination of Lieberman and Hanawa does not show or suggest the
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`elements of claim 3. Petitioner agrees that Hanawa discloses a variable frequency
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`power supply, which is cumulative of the record. Hanawa, however, teaches using
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`the “variable frequency RF power source as to either increase the transmitted
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`power or decrease the reflected power, so as to provide an accurate RF match
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`instantly responsive to changes in plasma impedance” (Ex. 1010 at Abstract),
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`which focuses entirely upon impedance matching only.
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`Most particularly, Hanawa does not show or suggest Flamm’s invention of
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`the wave adjustment circuit selectively adjusts a variable frequency power supply
`
`in combination with using the wave adjustment circuit to adjust the inductive
`
`coupling structure and adjusting the phase portion and the antiphase portion of the
`
`capacitively coupled currents of the gaseous discharge. No such concept is shown,
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`explicitly or implicitly, or suggested by Hanawa. No concept to adjust the high
`
`frequency field using the variable frequency power supply as claimed is shown or
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`suggested, as well.
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`VI. Ground 5—Qian
`
`The claim element denominated by Petitioners as [1.2] reads:
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`in which a phase portion and an anti-phase portion of capacitive
`currents coupled from the inductive coupling structure are selectively
`balanced
`
`(Pet. at 60.)
`
`Qian discloses an inductive coil with a balanced transformer. A PHOSITA
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`would not have understood that Qian disclosed the phase portion and the anti-
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`phase portion of capacitive currents coupled from the inductive coupling structure
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`are selectively balanced. That is, Qian is silent on any concept of selectively
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`balanced, and a PHOSITA would not find that Qian taught “selectively balanced”
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`that meant “chosen to be made substantially equally distributed.”
`
`Qian teaches driving an inductive coil with an “isolation transformer,” 80 in
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`Figure 2, having “a primary winding 82 and a secondary winding 84” wound on a
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`“ferrite core 90” which “may be circular.” (Ex. 1009 at 2:21-51.) This isolation
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`transformer causes the inductive coil to have a floating potential with respect to the
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`wafer 30 and wafer pedestal 20. (Ex. 1009 at Abstract, 2:30-36.)
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`However, Qian did not teach employing this structure to balance (i.e.,
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`equally distribute) the phase and anti-phase capacitively coupled currents, and to
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`reduce the overall capacitive coupling from the antenna. (Ex. 1009 at 1:45-56 (“In
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`an inductively coupled RF plasma reactor having an inductive coil antenna
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`connected through an RF impedance match network to an RF power source,
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`capacitive coupling from the antenna to the plasma is reduced by isolating the coil
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`antenna from the RF power source by an isolation transformer, so that the coil
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`antenna has a floating potential.”).) In particular, Qian teaches that the isolation
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`transformer reduces the RF current induced by capacitive coupling by at least