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 IPR No. Unassigned
`U.S. Patent No. 6,017,221
`Issued: January 25, 2000
`Named Inventor: Daniel L. Flamm
`
`Title: PROCESS DEPENDING ON PLASMA DISCHARGES SUSTAINED BY
`INDUCTIVE COUPLING
`
`
`DECLARATION OF DAVID B. GRAVES IN SUPPORT OF PETITION
`FOR INTER PARTES REVIEW OF U.S. PATENT NO. 6,017,221
`UNDER 35 U.S.C. §§ 311-319 AND 37 C.F.R. §§ 42.1-.80, 42.100-.123
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`Ex.1003 p.1
`
`

`
`
`
`
`
`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
`
`TABLE OF CONTENTS
`
`Page
`
`V. 
`
`I. 
`INTRODUCTION ........................................................................................... 6 
`QUALIFICATIONS AND PROFESSIONAL EXPERIENCE ...................... 6 
`II. 
`III.  RELEVANT LEGAL STANDARDS ............................................................. 8 
`IV.  TECHNOLOGY TUTORIAL ....................................................................... 12 
`A. 
`Creation of Plasma for Fabrication Processes ..................................... 12 
`B. 
`How The Coil Transfers Power To The Plasma ................................. 13 
`C. 
`Inductive And Capacitive Coupling .................................................... 14 
`D. 
`“Phase” And “Anti-Phase” Of Currents and Voltages On A
`Primary Coil ........................................................................................ 16 
`THE 221 PATENT ........................................................................................ 17 
`A. 
`Independent Claim 1 ........................................................................... 18 
`B. 
`The 221 Patent Disclosure ................................................................... 18 
`1. 
`Inductively-Coupled Plasma Source ......................................... 18 
`2. 
`Capacitively Coupled Currents ................................................. 19 
`3. 
`Phase and Anti-Phase Portions of the Capacitively
`Coupled Currents ...................................................................... 19 
`4.  Wave Adjustment Circuit ......................................................... 22 
`VI.  PERSON HAVING ORDINARY SKILL IN THE ART ............................. 25 
`VII.  CLAIM CONSTRUCTION .......................................................................... 26 
`A. 
`“selectively balanced” ......................................................................... 26 
`1. 
`Correct Construction: “selectively balanced” means
`“chosen to be made substantially equally distributed.” ............ 26 
`Flamm’s Construction: “selectively balanced covers a
`range, per one’s selection, between 100% balanced to
`various lesser percentages” ....................................................... 30 
`VIII.  SUMMARY OF PRIOR ART REFERENCES ............................................ 31 
`A. 
`Lieberman ............................................................................................ 31 
`B. 
`Dible .................................................................................................... 33 
`
`2. 
`
`i
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`Ex.1003 p.2
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`

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`
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`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
`
`b) 
`
`Qian ..................................................................................................... 34 
`C. 
`D.  Hanawa ................................................................................................ 35 
`E. 
`Collins.................................................................................................. 37 
`IX.  OPINIONS RELATING TO EACH OF THE GROUNDS .......................... 37 
`A.  Ground 1: Claims 1 and 5-7 Are Rendered Obvious by
`Lieberman Under 35 U.S.C. § 103(a). ................................................ 37 
`1. 
`Lieberman Independent Claim 1 ............................................... 38 
`a) 
`[1.P.] A process for fabricating a product using a
`plasma source .................................................................. 38 
`[1.1] subjecting a substrate to entities, at least one
`of said entities emanating
`from a gaseous
`discharge excited by a high frequency field from
`an inductive coupling structure....................................... 39 
`[1.2] in which a phase portion and an anti-phase
`portion of capacitive currents coupled from the
`inductive coupling
`structure are
`selectively
`balanced .......................................................................... 40 
`[1.3] 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. ........................................ 51 
`Lieberman discloses all limitations of dependent claims
`5-7. ............................................................................................ 53 
`a) 
`Claim 5: The process of claim 1 wherein said
`process is provided in a chamber. ................................... 53 
`Claim 6: The process of claim 5 wherein the
`chamber is provided for a process selected from
`etching, deposition, sputtering, or implantation. ............ 55 
`Claim 7: The process of claim 1 wherein said
`inductive coupling structure provides a wave
`multiple selected from a one-sixteenth wave, a
`one-eighth-wave, a quarter-wave, a half-wave, a
`three-quarter wave, and a full-wave. .............................. 55 
`
`c) 
`
`d) 
`
`2. 
`
`b) 
`
`c) 
`
`ii
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`Ex.1003 p.3
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`

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`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
`
`
`
`
`
`B. 
`
`C. 
`
`2. 
`
`Ground 2: Claims 1 and 5-7 Are Rendered Obvious by
`Lieberman In View of Dible Under 35 U.S.C. § 103(a). .................... 56 
`1. 
`Lieberman In View Of Dible Discloses All
`the
`Limitations of Claim 1. ............................................................. 57 
`a) 
`[1.P] A process for fabricating a product using a
`plasma source .................................................................. 57 
`[1.1] Subjecting a substrate to entities, at least one
`of said entities emanating
`from a gaseous
`discharge excited by a high frequency field from
`an inductive coupling structure....................................... 57 
`[1.2] in which a phase portion and an anti-phase
`portion of capacitive currents coupled from the
`inductive coupling
`structure are
`selectively
`balanced .......................................................................... 58 
`[1.3] 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. ........................................ 61 
`Lieberman in view of Dible discloses all limitations of
`dependent claims 5-7. ............................................................... 62 
`a) 
`Claim 5: The process of claim 1 wherein said
`process is provided in a chamber. ................................... 62 
`Claim 6: wherein the chamber is provided for a
`process
`selected
`from
`etching, deposition,
`sputtering, or implantation. ............................................. 63 
`Claim 7: wherein said inductive coupling structure
`provides a wave multiple selected from a one-
`sixteenth wave, a one-eighth-wave, a quarter-
`wave, a half-wave, a three-quarter wave, and a
`full-wave. ........................................................................ 63 
`Reasons to Combine Lieberman and Dible .............................. 64 
`3. 
`Ground 3: Claims 2-3 Are Rendered Obvious by Lieberman
`(Ground 1), Or Lieberman in view of Dible (Ground 2
`Combination), in View of Hanawa Under 35 U.S.C. § 103(a). .......... 66 
`
`b) 
`
`c) 
`
`d) 
`
`b) 
`
`c) 
`
`iii
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`Ex.1003 p.4
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`

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`
`
`1. 
`
`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
`
`Lieberman (Ground 1), or Lieberman in view of Dible
`(Ground 2 Combination), in view of Hanawa teaches all
`limitations of claims 2 and 3. .................................................... 66 
`a) 
`Claim 2: The process of claim 1 wherein the wave
`adjustment circuit selectively adjusts a frequency
`of an rf power supply. ..................................................... 66 
`Claim 3: The process of claim 1 wherein the high
`frequency field
`is adjusted using a variable
`frequency power supply. ................................................. 68 
`Reasons to Combine Lieberman and Hanawa .......................... 69 
`2. 
`D.  Ground 4: Claim 4 is Rendered Obvious by Lieberman in View
`of Collins, Or Alternatively in view of Dible and Collins ,
`Under 35 U.S.C. § 103(a). ................................................................... 75 
`1. 
`Lieberman in View of Collins teaches all limitations of
`Claim 4. ..................................................................................... 75 
`a) 
`Claim 4: The process of claim 1 wherein the wave
`adjustment circuit comprises a transmission line. .......... 75 
`Reasons to Combine Lieberman and Collins ............................ 77 
`2. 
`Ground 5: Claims 1, 5-7 Are Rendered Obvious by Qian Under
`35 U.S.C. § 103(a). .............................................................................. 78 
`1. 
`Qian Independent Claim 1 ........................................................ 79 
`a) 
`[1.P] A process for fabricating a product using a
`plasma source .................................................................. 79 
`[1.1] Subjecting a substrate to entities, at least one
`of said entities emanating
`from a gaseous
`discharge excited by a high frequency field from
`an inductive coupling structure....................................... 80 
`[1.2] in which a phase portion and an anti-phase
`portion of capacitive currents coupled from the
`inductive coupling
`structure are
`selectively
`balanced .......................................................................... 82 
`[1.3] wherein said inductive coupling structure is
`adjusted using a wave adjustment circuit, said
`wave adjustment circuit adjusting
`the phase
`
`E. 
`
`b) 
`
`b) 
`
`c) 
`
`d) 
`
`iv
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`Ex.1003 p.5
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`

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`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
`
`2. 
`
`F. 
`
`
`
`
`
`X. 
`
`
`
`b) 
`
`c) 
`
`b) 
`
`the
`the anti-phase portion of
`portion and
`capacitively coupled currents. ........................................ 90 
`Qian discloses all limitations of dependent claims 5-7 ............ 93 
`a) 
`Claim 5: The process of claim 1 wherein said
`process is provided in a chamber. ................................... 93 
`Claim 6: The process of claim 5 wherein the
`chamber is provided for a process selected from
`etching, deposition, sputtering, or implantation. ............ 94 
`Claim 7: The process of claim 1 wherein said
`inductive coupling structure provides a wave
`multiple selected from a one-sixteenth wave, a
`one-eighth-wave, a quarter-wave, a half-wave, a
`three-quarter wave, and a full-wave. .............................. 94 
`Ground 6: Claims 2-3 Are Rendered Obvious by Qian in View
`of Hanawa Under 35 U.S.C. § 103(a). ................................................ 96 
`1. 
`Qian in view of Hanawa teaches all limitations of claims
`2 and 3. ...................................................................................... 96 
`a) 
`Claim 2: The process of claim 1 wherein the wave
`adjustment circuit selectively adjusts a frequency
`of an RF power supply. ................................................... 96 
`Claim 3: The process of claim 1 wherein the high
`frequency field
`is adjusted using a variable
`frequency power supply. ................................................. 98 
`Reasons to Combine Qian and Hanawa .................................... 98 
`2. 
`G.  Ground 7: Claim 4 is Rendered Obvious by Qian in View of
`Collins Under 35 U.S.C. § 103(a). ....................................................104 
`1. 
`Qian in view of Collins discloses all limitations of claim
`4. ..............................................................................................104 
`a) 
`Claim 4: The process of claim 1 wherein the wave
`adjustment circuit comprises a transmission line. ........104 
`Reasons to combine Qian and Collins ....................................105 
`2. 
`CONCLUSION ............................................................................................ 107 
`
`v
`
`Ex.1003 p.6
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`

`
`
`
`
`I, David B. Graves, declare as follows:
`
`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
`
`I.
`
`INTRODUCTION
`1.
`
`I am over 18 years of age and otherwise competent to make this
`
`Declaration.
`
`2.
`
`I have been asked to provide my views regarding technical issues in
`
`connection with the above-captioned inter partes review of U.S. Patent
`
`No. 6,017,221 (Ex.1001, “the 221 Patent”). I have also have been asked to provide
`
`my opinion on whether claim 1-7 of the 221 Patent are valid in light of the prior art
`
`in Grounds 1-7 and the knowledge of one of ordinary skill in the art at the time of
`
`the alleged invention. It is my opinion that claims 1-7 are invalid for the reasons
`
`set forth in this declaration.
`
`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`3.
`I am currently a Professor of Chemical and Biomolecular Engineering
`
`at the University of California, Berkeley. I was the first Lam Research
`
`Distinguished Professor in Semiconductor Processing from 2011-2016. I have
`
`been a Full Professor since 1997. I was an Associate Professor from 1991-1997,
`
`and an Assistant Professor from 1986-1991. My prior employment also includes
`
`being a computer process control engineer for Standard Oil of California from
`
`1978-81. I have also provided research support for a number of major
`
`semiconductor manufacturing and processing companies.
`
`6
`
`Ex.1003 p.7
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`

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`
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`
`
`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
`
`4.
`
`I obtained my Ph.D. in Chemical Engineering from the University of
`
`Minnesota in 1986. I also received my Master’s degree in Chemical Engineering
`
`from the University of Arizona in 1981, and my Bachelor’s degree in Chemical
`
`Engineering from the University of Arizona in 1978.
`
`5.
`
`I have significant research experience in many issues relating to
`
`semiconductor devices and their processing, including thin film etching and
`
`deposition in semiconductor manufacturing, plasma chemistry and plasma
`
`processing for semiconductors, modeling and simulation of low temperature
`
`nonequilibrium plasmas, plasma-surface
`
`interactions and plasma-surface
`
`chemistry, nanofeature profile evolution simulation, molecular dynamics of
`
`plasma-surface interactions, particles and photons in plasmas, optical and mass
`
`spectroscopy in low temperature plasmas, and microplasmas. I have published
`
`over two hundred peer-reviewed papers and given many presentations on these
`
`topics, among others.
`
`6.
`
`I have taught courses in solid state device processing, process control,
`
`transport processes, and mathematical methods at the undergraduate and graduate
`
`level. I have supervised the research of approximately 50 students and scholars in
`
`the area of semiconductor plasma processing and manufacturing as part of their
`
`work for their PhDs as well as post-doctoral work.
`
`7. My curriculum vitae (CV) (Ex.1004) includes additional details about
`
`7
`
`Ex.1003 p.8
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`

`
`
`
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`my experience and professional background.
`
`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
`
`8.
`
`I am being compensated for my time at my standard hourly rate of
`
`$400 in connection with this proceeding. My compensation is in no way contingent
`
`upon my performance or the outcome of this case.
`
`9.
`
`I have been asked my technical opinions regarding the understanding
`
`of a person of ordinary skill in the art (discussed below) as it relates to the 221
`
`Patent and other reference documents. I have also been asked to provide my
`
`technical opinions on concepts discussed in the 221 Patent and other reference
`
`documents, as well as my technical opinions on how these concepts relate to
`
`several claim limitations of the 221 Patent in the context of the specification.
`
`Finally, I have been asked to provide my opinion regarding whether claims 1-7 of
`
`the 221 Patent are invalid in light of the prior art in Grounds 1-7, viewing that art
`
`from the perspective of one of ordinary skill in the art.
`
`10.
`
`In reaching the opinions stated herein, I have considered the 221
`
`Patent, its prosecution history, and the Exhibits to the Petition. I have also drawn,
`
`as appropriate, upon my own education, training, research, knowledge, and
`
`personal and professional experience.
`
`III. RELEVANT LEGAL STANDARDS
`11. My opinions are informed by my understanding of the relevant law. I
`
`understand that the patentability analysis is conducted on a claim-by-claim basis.
`
`8
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`Ex.1003 p.9
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`

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`
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`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
`
`12.
`
`I understand that the 221 Patent has expired. Accordingly, in my
`
`analysis, all claim terms have been accorded their plain and ordinary meaning, as
`
`understood by a person having ordinary skill in the art and consistent with the
`
`specification and file history of the 221 Patent.
`
`13.
`
`I understand that a single piece of prior art “anticipates” a claim if
`
`each and every element of the claim is disclosed in that prior art. I further
`
`understand that, where a claim element is not explicitly disclosed in a prior art
`
`reference, the reference may nonetheless anticipate a claim if the missing claim
`
`element is necessarily present in the apparatus or is a natural result of the method
`
`disclosed—i.e., if the missing element is “inherent.”
`
`14.
`
`I understand that the prior art may render a patent claim “obvious.” I
`
`understand that two or more pieces of prior art that each disclose fewer than all
`
`elements of a patent claim may nevertheless be combined to render a patent claim
`
`obvious if the combination of the prior art collectively discloses all elements of the
`
`claim and a person having ordinary skill in the art at the time would have had
`
`reason to combine the prior art. I understand that this reason to combine need not
`
`be explicit in any of the prior art, but may be inferred from the knowledge of a
`
`person having ordinary skill in the art at the time the patent application was filed. I
`
`also understand that a person having ordinary skill in the art is not an automaton,
`
`but is a person having ordinary creativity. I further understand that one or more
`
`9
`
`Ex.1003 p.10
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`

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`
`
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`pieces of prior art that disclose fewer than all of the elements of a patent claim may
`
`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
`
`render a patent claim obvious if including the missing element would have been
`
`obvious to a person having ordinary skill in the art (e.g., the missing element
`
`represents only an insubstantial difference over the prior art or a reconfiguration of
`
`a known system).
`
`15.
`
`I understand that a patent claim is obvious if the differences between
`
`the subject matter claimed and the prior art are such that the subject matter as a
`
`whole would have been obvious at the time the alleged invention was made. I
`
`understand that the obviousness analysis must focus on the knowledge available to
`
`one of ordinary skill in the art at the time of the alleged invention in order to avoid
`
`impermissible hindsight. I further understand that the obviousness inquiry assumes
`
`that the person having ordinary skill in the art would have knowledge of all
`
`relevant references available at the time of the alleged invention.
`
`16.
`
`I also understand that the USPTO has identified exemplary rationales
`
`that may support a conclusion of obviousness, and I have considered those
`
`rationales in my analysis. The rationales include:
`
`
`
`
`
`Combining prior art elements according to known methods to yield
`
`predictable results;
`
`Simple substitution of one known element for another to obtain
`
`predictable results;
`
`10
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`Ex.1003 p.11
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`

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`
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`
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`
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`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
`
`Use of known technique to improve similar devices (methods or
`
`products) in the same way;
`
`Applying a known technique to a known device (methods or products)
`
`ready for improvement to yield predictable results;
`
`Choosing from a finite number of identified, predictable solutions,
`
`with a reasonable expectation of success, such that the effort was
`
`“obvious to try”;
`
`
`
`Known work in one field of endeavor that may prompt variations on
`
`the work for use in either the same field or a different one based on
`
`design incentives or other market forces if the variations are
`
`predictable to a person having ordinary skill in the art;
`
`
`
`Some teaching, suggestion, or motivation in the prior art that would
`
`have led a person having ordinary skill in the art to modify the prior
`
`art reference or to combine prior art reference teachings to arrive at
`
`the claimed invention.
`
`17.
`
`I appreciate that secondary considerations may be considered, if
`
`present, as part of the overall obviousness analysis. Such considerations do not
`
`appear to be present here. For example:
`
`
`
`I have never heard anyone offer praise for the 221 Patent, nor am I
`
`aware of any commercial success attributable to the 221 Patent.
`
`11
`
`Ex.1003 p.12
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`

`
`
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`
`
`
`
`
`
`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
`
`I am unaware of any copying of the alleged invention of the 221
`
`Patent.
`
`I am unaware of any use to which the owner of the 221 Patent has put
`
`the patent except to assert it in litigation.
`
`IV. TECHNOLOGY TUTORIAL
`18.
`I provide in this section a brief description of certain concepts of the
`
`221 Patent that are relevant to my opinions.
`
`A. Creation of Plasma for Fabrication Processes
`19. The term “plasma” means “ionized gas,” or a collection of negatively
`
`and positively charged gaseous particles. Usually, the negative particles are free
`
`electrons and the positive particles are termed “positive ions.” Negative ions can
`
`also form.
`
`20. The charged particles in the plasma will tend to recombine back into
`
`uncharged molecules—either in the gas phase, or at walls. Since the charged
`
`particles that make the plasma are constantly being lost by recombination, new
`
`charged particles must be made continuously, or the plasma “goes out.” This is
`
`what happens, for example, when the switch to a fluorescent light is turned off: the
`
`electric field that was ionizing some of the gas in the tube, leading ultimately to
`
`light being created by the lamp, is removed and the plasma is extinguished and the
`
`light goes out.
`
`12
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`Ex.1003 p.13
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`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
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`Ex.1003 (“Graves Decl.”)
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`21. The gas molecules under normal conditions are initially uncharged—
`
`or “un-ionized”—and in order to create plasma, at least some of the gaseous
`
`particles (e.g. air molecules) must somehow be ionized. Uncharged gas molecules
`
`are ionized by experiencing collisions with energetic particles that are capable of
`
`removing an electron from the orbit of the uncharged molecules, thereby creating a
`
`free negative electron and leaving behind a positive ion. This ionizing, energetic
`
`particle could be a photon of light (equivalently, radiation) of sufficient energy or
`
`it can be, and usually is, an energetic electron in the plasma itself.
`
`22. By applying an external electric field, existing free electrons in the
`
`plasma are accelerated to energies that are sufficient to ionize an initially
`
`uncharged molecule. To create the plasma, therefore, an external electric field
`
`must be applied to the gas. To sustain the plasma, a field must be continuously
`
`accelerating electrons in the plasma.
`
`B. How The Coil Transfers Power To The Plasma
`23. First, it should be understood that one transfers power to the plasma
`
`by applying an electric field, therefore causing a current to flow in the plasma. The
`
`power deposited per unit volume is the product of the current density (current per
`
`unit area) and the electric field in the plasma. Current can be either “conduction
`
`current” corresponding to the motion of charged particles (electrons and/or ions) or
`
`it can be “displacement current,” associated with a time varying electric field. But
`
`13
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`Ex.1003 p.14
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`

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`
`
`only conduction current dissipates power, as in a resistor. Pure displacement
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`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
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`current dissipates no net power in the capacitor. Accordingly, we are interested
`
`mainly in conduction current in the context of transferring power from an external
`
`coil to the plasma.
`
`24. There are multiple ways that an electric field can cause current to flow
`
`in a plasma—or in any other conductor like a piece of metal. One way to get
`
`current to flow in an adjacent conductor is through “inductive coupling.” In
`
`inductive coupling, a time-varying external current (in a coil for example) induces
`
`a corresponding current in the adjacent conducting medium. The adjacent
`
`conducting medium can be a plasma.
`
`C.
`25.
`
`Inductive And Capacitive Coupling
`
`In inductively coupled plasmas in the simplest case, the situation is
`
`similar to a transformer: a primary coil induces a current in a secondary coil. In
`
`the case of powering the plasma, the external coil is the primary coil and the
`
`plasma acts as a 1-turn secondary coil.
`
`26. One can also use an external primary coil coupled through a
`
`transformer to a secondary external coil (e.g., as I describe below with respect to
`
`Lieberman and Qian that both drive the coil with a transformer) that itself acts to
`
`transfer power to the plasma. This configuration has the advantage of eliminating
`
`the DC (direct current) voltage on the coil, thus reducing “capacitive coupling.”
`
`14
`
`Ex.1003 p.15
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`
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`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
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`Ex.1003 (“Graves Decl.”)
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`27. Capacitive coupling is another way to transfer power to the plasma.
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`In capacitive coupling, an electrode has a time-varying (usually radiofrequency or
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`RF) voltage applied to it. Either the electrode is in the low pressure chamber and
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`touches the plasma directly or the electrode can be outside the chamber with an
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`insulating wall material between it and the plasma. An external coil has a time-
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`varying voltage applied to it, so it can act to couple power capacitively to the
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`plasma. As noted above, there is no power dissipated in the dielectric part of the
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`capacitor. However, in the plasma, electrons moving in the weekly ionized neutral
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`gas act as a kind of resistor in series with the capacitor (the dielectric wall). The
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`current that passes “capacitively” through the dielectric wall enters the plasma and
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`pushes electrons to form an electron conduction current, thereby heating the
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`plasma. In addition, positive ions will in general be accelerated by voltages
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`associated with “capacitive coupling.” Indeed, it is this aspect of capacitive
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`coupling that is most relevant to the 221 Patent.
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`28. The degree to which the coupling is inductive or capacitive depends
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`on multiple factors, but it is known that at lower plasma density, the coupling must
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`be capacitive. This is the reason that capacitive coupling is generally required to
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`ignite the plasma—before ignition, the plasma density is very low. It also known
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`that using a balanced transformer, such as in Qian and Lieberman as I discuss
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`below, at least significantly reduces, if not eliminates, capacitive current and
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`15
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`Ex.1003 p.16
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`reduces capacitively coupling.
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`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
`
`D.
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`“Phase” And “Anti-Phase” Of Currents and Voltages On A
`Primary Coil
`29. The term “phase and anti-phase” is not in common use in this context.
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`30.
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`It is of course obvious that any alternating current source (e.g., a
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`sinusoid) has a phase associated with it. The voltage first rises and then falls as a
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`function of time, repeating again and again, so one refers to the phase of the
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`voltage varying between zero degrees and 360 degrees or equivalently (i.e.,
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`between zero and 2*π radians).
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`31. The 221 Patent uses the terminology phase and anti-phase to refer to
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`the fact that the voltage will go through a positive maximum (calling it the “phase”
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`portion) and a negative minimum (calling it the “anti-phase” portion)1 at every
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`point along a cable through which an RF current is flowing. With a sinusoid, and
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`with a push-pull arrangement, the midpoint will be at a virtual ground due to the
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`symmetry of the waveform (i.e., while the ends are V+ and V-, the midpoint
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`becomes a virtual ground due to the shape of a sinusoid waveform).
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`32. The current is RF as well as the voltage—so it goes back and forth to
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`1 Anti-phase portion could likewise refer to the fact that the voltage will go through
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`a positive maximum, and phase portion could refer to the fact that the voltage will
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`go through a negative maximum.
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`16
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`Ex.1003 p.17
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`and from the source and whatever ground surface the coil or plasma experiences.
`
`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
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`The RF current is approximately 90° out of phase with the voltage, see, e.g., Ex.
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`1001 at Fig. 4.
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`33. Flamm confirmed the relationship between voltages and current in the
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`file history. Flamm argued during prosecution in response to an Examiner’s
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`rejection, the terms “phase portion” and “anti-phase portion” “are described
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`throughout the specification in relation to voltages, since electrical current is
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`fundamentally related to voltage by an impedance.” Ex. 1002 at p.5. Flamm
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`further argued that support for these terms “can be found at, for example, Vcoil at
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`Fig. 5B, which illustrates a phase and anti-phase relationship of a waveform.” Id.
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`Figure 5B shows the correspondence between voltage and current in this context.
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`V. THE 221 PATENT
`34.
`I understand Petitioners are challenging claims 1-7 (“challenged
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`claims”) of the 221 Patent.
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`35.
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`I understand that the 221 Patent is a continuation-in-part of a U.S.
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`patent application filed on October 23, 1996 (now abandoned) which, in turn,
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`claims priority to another application filed on December 4, 1995 (also abandoned).
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`I have been asked to assume that the priority date of the 221 Patent is December 4,
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`1995, but I have not evaluated whether the continuation-in-part or provisional
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`applications properly support the claims of the 221 Patent. I further understand
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`17
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`Ex.1003 p.18
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`that the references relied upon in the petition all predate Dec. 4, 1995, the earliest
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`Petition for Inter Partes Review of U.S. Patent No. 6,017,221
`
`Ex.1003 (“Graves Decl.”)
`
`possible priority date recited by the 221 Patent.
`
`A.
`Independent Claim 1
`36. Claim 1 is representative of the claimed subject matter. For example,
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`claim 1 recites a process for fabricating a product using a plasma source
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`comprising (a) “subjecting a substrate to entities, at least one of said entities
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`emanating from a gaseous discharge excited by a high frequency field from an
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`inductive coupling structure,” (b) “in which a phase portion and an anti-phase
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`portion of capacitive currents coupled from the inductive coupling structure are
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`selectively balanced;” and (c) “wherein said inductive coupling structure is
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`adjusted using a wave adjustment circuit, said wave adjustment circuit adjusting
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`the phase portion and the anti-phase portion of the capacitively coupled currents.”
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`Ex. 1001 at 22:58-23:2.
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`B.
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`The 221 Patent Disclosure
`1.
`Inductively-Coupled Plasma Source
`37. The 221 Patent relates to “plasma processing of devices using an
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`inductive discharge,” such processing including, for example, “plasma etching and
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`resist stripping of semiconductor devices. . . . [and] chemical vapor deposition
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`(CVD) of semiconductor devices.” Ex. 1001 at 1:16-21.