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—00391
`
`US. Patent No. 6,017,221
`
`SECOND DECLARATION OF DANIEL L. FLAMM IN
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`SUPPORT OF PATENT OWNER’S RESPONSE
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`US. Patent & Trademark Office
`
`PO. Box 1450
`
`Alexandria, VA 22313—1450
`
`Exhibit 2003
`
`lPR2017—0039]
`
`
`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—00391
`
`US. Patent No. 6,017,221
`
`SECOND DECLARATION OF DANIEL L. FLAMM IN
`
`SUPPORT OF PATENT OWNER’S RESPONSE
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`US. Patent & Trademark Office
`
`PO. Box 1450
`
`Alexandria, VA 22313—1450
`
`Exhibit 2003
`
`lPR2017—0039]
`
`
`
`Inter Partes Review of US. Patent No. 6,017,221
`
`IPR2017—00391
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`1, Daniel L. Flamm, Sc.D., hereby declare as follows:
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`1.
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`I worked in academia, research, and industry in various roles for more than 50
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`years. My curriculum vitae, which includes a more detailed summary of my
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`background, experience, and publication, is attached as Appendix A.
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`2.
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`l have been a leading researcher and educator in the fields of semiconductor
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`processing technology, air pollution control, materials science, and other areas of
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`chemical engineering. My research has been funded by NASA, National Science
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`Foundation, Environmental Protection Agency, and AT&T Bell Laboratories.
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`While a Distinguished Member of Technical Staff at Bell Laboratories, I led a
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`semiconductor processing research group comprised of research colleagues,
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`visiting university scientists, post—doctoral associates, and summer students.
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`I
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`have also served as a technical consultant to various semiconductor device and
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`processing equipment manufacturers.
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`3.
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`I have published over one hundred and fifty (150) technical journal articles
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`and books, and dozens of articles in conference proceedings, most of them in
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`highly competitive referred conferences and rigorously reviewed journals.
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`I am
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`an inventor listed in more than 20 US. patents, a number of which have been
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`licensed through the industry, and most being in the general
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`field of
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`semiconductor processing technology.
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`4.
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`I had experience studying and analyzing patents and patent claims from the
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`1
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`Inter Partes Review of US. Patent No. 6,017,221
`lPR20'l7—0039l
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`perspective of a personal having ordinary skilled in the art (“PHOSTIA”) starting
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`at least at the time of my employment at AT&T Bell laboratories in 1977. At
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`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
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`potential utility and licensing potential.
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`I have also served as a technical expert
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`in patent 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 registered
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`as a Patent Attorney since 2006.
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`I am also a member of the California State Bar.
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`6.
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`I am the inventor of US. Patent No. 6,017,221,
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`in the name of Daniel L
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`Flamm and titled “(“the ‘221 Patent”).
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`7.
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`I have read the Petitioners Petition for Inter Partes Review in this matter and
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`the various art cited therein, including, among others,
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`8.
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`Petitioner inflates the significance of three sentences in a brief four sentence
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`paragraph in Lieberman that amounts to suggesting use of a radiofrequency
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`isolation transformer to apply voltage to a coil used to induce inductive current
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`in a plasma source. This teaches nothing about the ‘221’s inductive coupling
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`structure being adjusted using a wave adjustment circuit.
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`9. Lieberman’s article as a whole makes it very clear that
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`the “balanced
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`transformer” means an isolation transformer that isolates the output side from
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`ground —— on page 42 (EX. 1006) in the second paragraph he teaches powering a
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`2
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`Inter Partes Review of US. Patent No. 6,017,221
`IPR2017-00391
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`helicon antenna “driven through a balanced transformer so that the coil is isolated
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`from ground.” As a matter of fact, the main teaching of the Qian reference is to
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`use an isolation transformer, the same type of transformer identified in Lieberman.
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`Qian teaches the transformer is to isolate a “coil antenna” from the RF power
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`source”. Qian further teaches the result of the isolation is that “the potential of
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`the coil antenna is floating” to reduce capacitive coupling from the antenna to the
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`plasma.
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`10. None of this has anything do with any balancing, adjusting, or wave
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`adjustment circuits. Qian correctly teaches an isolation transformer can eliminate
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`any DC potential between the generator and the inductive coil antenna so that the
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`electric potential of the coil antenna is floating with respect to the wafer pedestal
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`(aka “chuck”). Qian’s focus on the Chuck relates to another critical distinction
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`between the subject matter ofthe ‘221 patent and the subject matter of Qian, and
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`Lieberman.
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`11. The capacitive currents referenced in Lieberman are not the same thing as
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`the capacitive currents referenced in the ‘22l patent. The “capacitive current”
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`Lieberman refers to is only the magnitude of that portion of capacitive current
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`which flows from the coil to the plasma and returns to the coil.
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`In Lieberman,
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`this is the entire capacitive current emanating (or returning) to the coil, because
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`Lieberman’s coil has been isolated. This is not the subject of Claim 1, and
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`3
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`Inter Partes Review of US. Patent No. 6,017,221
`IPR2017—00391
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`Lieberman does not teach a phase and anti- phase portion of capacitive currents
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`in the manner claimed.
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`12. In this regard, the main point is that claim 1 concerns selectively balancing
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`the vector sum of phase and anti-phase currents flowing from the coil as a whole
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`to the plasma— to obtain a selected difference current, if any, flowing through
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`the plasma to grounded chamber bodies, the wafer chuck, etc. The magnitude of
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`current flowing from and returning to an isolated coil from the plasma and the
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`vector sum of differently phased currents flowing to chamber bodies are quite
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`different things. The magnitude current taught by Lieberman is not susceptible
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`to selective balancing. And the voltage of an isolated coil relative to ground is
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`uncontrolled, as explained by Qian (“the electrical potential of the coil antenna
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`50 is floating with respect to the wafer pedestal 20”, eg. it has no value without
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`making a connection (in which case it would no longer be isolated or floating).
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`Lieberman merely suggests lowering the magnitude of a current that flows in a
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`closed path within the plasma source by itself (e.g., coil to plasma and return).
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`However,
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`the meaning of “lowering” is never defined (lowering relative to
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`what?). One can only guess that Lieberman may be thinking of comparison to a
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`coil that is grounded at one end, rather than being isolated, and having an equal
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`magnitude of voltage applied to it. But this would be a misguided comparison,
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`and in any case it is not the teaching of the ‘221 patent. The comparison is
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`4
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`Inter Partes Review of US. Patent No. 6,017,221
`IPR2017—00391
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`misguided because grounding the applicator coil allows current flow to chamber
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`bodies including the chuck, which engages completely different equivalent
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`circuits and current flows. The voltage along a grounded coil is susceptible to
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`wave adjustment using a wave adjustment circuit.
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`13. The ‘22] teaches using a wave adjustment circuit to selectively adjust an
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`inductive coupling structure such that the total sum of differently phased amounts
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`of current flowing from an applicator (coil) into the plasma are selectively
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`balanced, whereby a selected amount of current flows from the plasma source to
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`grounded chamber bodies, the wafer chuck, etc. Lieberman merely teaches a
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`static structure he believes to decrease the magnitude of plasma to coil voltage
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`(although it is not entirely clear what configuration the decrease is in reference
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`to), and teaches nothing about the subject of claim 1, “a phase portion and an
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`anti—phase portion of capacitive currents coupled from the inductive coupling
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`structure are selectively balanced”.
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`l4. Petitioner’s contention (e.g., Pet. 32—33) that Lieberman’s coil is “effectively
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`grounded” at the midpoint is fiction. The coil is floating, there is NO ground,
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`period. The currents and voltage distribution will not be symmetric, and certainly
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`never on the spiral coil. For the isolated coil, symmetry has nothing to do with
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`the principle of operation- the principle of operation is isolation, so current out
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`equals current in. This is not flexible or determined by any wave adjustment or
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`5
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`Inter Parties Review of US. Patent No. 6,017,221
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`lPR2017—00391
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`wave distribution or anything of the sort. The coil floats, period. The concern of
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`the ‘221 is the net current into the plasma (which is the concern of Qian as well),
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`which is NOT reduced by a factor of 2. As a matter of fact, Qian found
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`experimentally that his isolation transformer reduced net capacitive current to the
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`chuck in an embodiment by a factor of 2.5. This is explained by isolation, not by
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`any wave adjustment circuit changing any voltage distribution along the coil.
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`In
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`fact, the voltage distribution on Qian’s spiral coil is unknown and considered to
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`be of no consequence (the coil is floating). The meaning of a midpoint on
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`Lieberman’s spiral coil is not understandable.
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`Is it midway radially from the
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`center to the circumference? or is it midway along the spiral from inside to
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`outside. Either way, the voltage distribution is unlikely to be symmetric and
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`would be of no consequence anyway,
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`the cause of the capacitive current
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`reduction is isolation, not a voltage distribution.
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`15. Lieberman expressly references driving a coil push—pull using a balanced
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`transformer, not a “push—pull” transformer. As to a what a push-pull
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`transformer is, Petitioner has omitted Graf’s definition from its Exhibit 1016,
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`but in the 7th 1999 edition, Graf has: push-pull transformer —An audio—
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`frequency transformer that has a center-tapped winding and is used in a push—
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`pull amplifier circuit. Which apparently would be “inconvenient” for
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`Petitioner’s arguments. As for the term “virtual ground”, it is not found in the
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`6
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`Inter Partes Review of US. Patent No. 6,017,221
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`Graf reference.
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`16. Respondent respectfully submits that none of this definition about push-pull,
`
`balanced, or “virtual” grounds is of consequence anyway because, as a matter of
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`fact, the injection and return of the same magnitude of current to the coil is an
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`inherent consequence of inserting the isolation transformer.
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`17. Accordingly, none of the art relied on by Petitioners for claim 1, Lieberman,
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`Bible and Qian, teaches the ‘221 claim 1 limitation “a phase portion and anti—
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`phase portion of capacitive currents. . .are selectively balanced.
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`18.The objects of these three references were different from the ‘221’s object of
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`selectively balancing a phase and anti—phase portion of capacitive currents (Id).
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`The object of Lieberman’s configuration (which is mentioned, but never shown)
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`was to reduce the magnitude of capacitively coupled current flowing from the
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`coil
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`to plasma:
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`Lieberman stated his transformer
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`reduces the undesired
`
`capacitively coupled rf current circulating from the coil through his plasma by a
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`factor of two.
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`19.Thus, not only do these prior art references fail to meet the claim limitation “a
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`phase portion and anti—phase portion of capacitive currents...are selectively
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`balanced,” but each ofthese references is focused on a different aspect of plasma
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`processing than that of claiml ofthe ‘221 patent.
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`20.
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`At the outset, one should be wary about any assertion that the cited prior
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`7
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`Inter Partes Review of US. Patent No. 6,017,221
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`art teaches a “wave adjustment circuit “given, as we have just seen, that none of
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`this art,
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`in contradistinction with the ‘221 patent, was aimed at selectively
`
`balancing a phase and anti—phase portions of capacitive currents coupled from the
`
`inductive coupling structure.
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`21. One embodiment ofa “wave adjustment circuit” in the ‘221 specification is
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`a combination of open circuits and a broadband balanced—unbalanced toroidal
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`transmission line transformer, typically shortened to “balun.” Petitioner contends
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`that the transformer in Lieberman is a balun.
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`It is not.
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`22. A balanced output transformer, by definition, including the definition in
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`Petitioner’s Ex. 1016, means a transformer with a grounded center tap on its
`
`secondary winding. However, Lieberman’s secondary has no center tap and that
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`winding is floating, i.e., it is not grounded. Since Lieberman’s transformer is an
`
`isolation transformer it cannot be a broadband balanced—unbalanced toroidal
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`transmission line transformer, because a broadband balanced—unbalanced
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`toroidal transmission line transformer has an electrical continuity between its
`
`input and output and it must be grounded to function.
`
`23. Petitioners contend that “Lieberman’s balanced transformer results in ‘a
`
`virtual ground in the middle ofthe coil,’ and therefore corresponds to the claimed
`
`“wave adjustment circuit” that adjusts ‘the phase and anti—phase portion of
`
`capacitive currents.
`
`(Pet. at 37) Although Lieberman does not explain his use
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`’7?
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`8
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`Inter Partes Review of US. Patent No. 6,017,221
`IPR20l7-00391
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`of the term “virtual ground” in this context, various internet sites suggest it refers
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`to a circuit element not directly connected to ground, that is held at a reference
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`voltage. Lieberman’s coils are connected to an isolation transformer, they have
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`no voltage and no part of the coil comprises any reference voltage.
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`24. Petitioner contends that Lieberman teaches “a phase portion and an anti-
`
`phase portion of capacitive currents coupled from the inductive coupling
`
`structure are selectively balanced” because it “discloses choosing to drive an
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`inductive coil push—pull via a balanced transformer (i.e., allegedly a wave
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`adjustment circuit), which creates a phase configuration that makes the phase and
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`anti-phase portions selectively balanced. However, Lieberman does not teach
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`any balanced transformer,
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`it
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`is only an isolation transformer. The isolation
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`transformer does not perform any balancing, it only isolates a primary winding
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`from a secondary winding.
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`25. Petitioner argues that a person having ordinary skill in the art “would have
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`understood Lieberman’s choice to drive the inductive coil
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`push—pull’
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`to
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`6
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`correspond to the claimed ‘phase and an anti—phase portion of capacitive
`
`currents .
`
`.
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`. are selectively balancedm because “the phase voltages ‘push’
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`capacitively coupled current into the plasma while the anti—phase voltages ‘pull’
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`capacitively coupled current out of the plasma”. Lieberman does not have an
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`inductive coil driven push pull, but merely an isolation transformer with the
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`9
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`Inter Partes Review of US. Patent No. 6,017,221
`IPR2017—0039l
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`limitations discussed. Accordingly, Lieberman would not have any “phase and
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`an anti—phase portion of capacitive currents. . .are selectively balanced”.
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`26. Petitioner argues, “[d]riving the coil push-pull with” Lieberman’s “wave
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`adjustment circuit
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`(the inductively—coupled push-pull arrangement, e.g.,
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`a
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`toroidal balun) causes a midpoint on the coil to be effectively RF grounded,
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`adjusting the phase portion and the anti—phase portion of the capacitively coupled
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`currents so that they are selectively balanced about the midpoint”. Lieberman
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`does not have a wave adjustment circuit as discussed in 1 and 2, and does not
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`show an inductively coupled push pull arrangement. Lieberman does not have a
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`toroidal balum, but taught a magnetic flux coupled isolation transformer. The
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`isolation transformer would not have its midpoint at ground potential given that
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`it is isolated and has no relation to ground
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`27. Qian’s isolation transformer is not a balun and does not produce a balanced
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`output. The isolation transformer has an output that is merely isolated, and
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`floating. Where an output is floating, it is neither balanced nor unbalanced.
`
`28. Dible teaches nothing about adjusting any inductive coupling structure in
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`order to reduce or eliminate capacitively coupled power, adjusting phase and anti-
`
`phase portions of capacitive currents from an inductive coupling structure, or any
`
`other such thing. Dible does not disclose anything about “a phase portion and an
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`anti-phase portion of capacitive currents” emanating from an inductive coupling
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`10
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`structure, much less that they should be “selectively balanced.” Furthermore,
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`Dible’s scheme is itselffraught with problems that a PHOSITA in the field of RF
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`matching would immediately recognize. Dible teaches nothing about managing
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`the electrical
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`length of the coil, nothing about controlling the amplitudes of
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`currents to the respective ends of the coil, and nothing about any means to prevent
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`power emanating from one power supply from burning out the other power
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`supply and/or its matching network, never mind overcoming the instability that
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`may arise from having two independent power supplies and matching networks
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`powering each other through a coil.
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`29.A PHOSITA would recognize that two prior art high frequency plasma power
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`supplies and matching networks connected to each other in the manner shown
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`would not admit an arbitrary relative phase relation between the ends of the coil
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`for reasons of stability and various other fundamental problems such as those
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`mentioned above. Dible offers no means to impose a stable selectable phase
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`relation on a coil by powering the plasma with two power sources in the circuits
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`shown, and there was no prior art control circuit operable to perform the
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`necessary function(s).
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`30. I disagree with Petitioners and would like to reiterate that Hanawa does not
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`teach the wave adjustment circuit... as claimed. As background, in the “221
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`patent, a wave adjustment circuit
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`is generally defined by its function and
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`11
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`Inter Partes Review of US. Patent No. 6,017,221
`lPR2017—00391
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`configuration of a device: “The wave adjustment circuits are used to select a
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`wavelength portion to be applied in [Sic] the plasma applicator. l have studied
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`and searched Hanawa, and found nothing in Hanawa that teaches or suggests to
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`select any wavelength portion (or equivalent term) to be applied to a plasma
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`applicator, and Petitioners never identified any such thing in Hanawa.
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`31.1 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 on this 6th day of September, 2017
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`
`
`Daniel L. Flamm
`
`12
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