By: Christopher Frerking (Chris@ntknet.com)
`Reg. No. 42,557
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MICRON TECHNOLOGY, INC., INTEL CORPORATION
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`AND GLOBALFOUNDRIES U.S., INC.
`
`Petitioners
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`V.
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`DANIEL L. FLAMM,
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`Patent Owner
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`CASE lPR2017—00392
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`US. Patent No. 5,711,849
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`DECLARATION OF DANIEL L. FLAMM IN
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`SUPPORT OF PATENT OWNER’S RESPONSE
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`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`US. Patent & Trademark Office
`
`PO. Box 1450
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`Alexandria, VA 22313—1450
`
`Exhibit 2003
`
`IPR2017—00392
`
`
`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 lPR2017—00392
`
`US. Patent No. 5,711,849
`
`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
`
`IPR2017—00392
`
`
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`Inter Partes Review of US. Patent No. 5,711,849
`IPR2017-00392
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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
`
`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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`I 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
`
`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.
`
`I
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`have also served as a technical consultant to various semiconductor device and
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`processing equipment manufactures.
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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 U.S. Patent No. 5,711,849
`IPR2017—00392
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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, 1 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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`l 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. 5,711,849,
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`in the name of Daniel L
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`Flamm and titled “(“the ‘849 Patent”).
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`7.
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`l 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 contends that the combination of Alkire and Kao discloses or
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`suggests all of the elements of claim 1.
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`I, however, respectfully disagree.
`
`9. Alkire does not teach “defining etch rate data comprising an etch rate and a
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`spatial coordinate which defines a position within said relatively non—uniform
`
`etching profile on said substrate” as admitted by Petitioner. Additionally, Figure
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`2 of Alkire shows a uniform etching profile.
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`10. As shown in Figure 2, Alkire’s etching profile is completely flat except for
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`edges of the film, which is typical before or after etching the wafer, and is not a
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`2
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`Inter Partes Review of US. Patent No. 5,711,849
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`relatively non-uniform etch profile. Also, Alkire solves for “r” along the length
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`of the wafer. Alkire emphasizes a “uniform” etching profile in its Abstract, and
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`throughout the Alkire document. A PHOSITA would never be able to extract a
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`surface reaction rate constant from this profile, even if the flat profile included
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`etch data, since a flat profile would not yield a surface reaction rate constant using
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`any of a model disclosed in Alkire or Kao. Additionally, as shown in Figure 2,
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`the two films face each other in Alkire, which would give a different model than
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`Flamm or even Kao. Moreover, Petitioner even acknowledges that “Alkire does
`
`not explicitly disclose measuring the etch rate at any spatial coordinates” in
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`Petitioner’s paper.
`
`1]. Furthermore, Alkire’s model lacks any temperature dependence, express or
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`otherwise,
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`to extract
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`the claimed surface reaction rate constant, which is
`
`temperature dependent. That is, Alkire assumes “operation is isothermal” [Alkire
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`p. 649 second column] and excludes any temperature dependence from his model.
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`At most, Alkire mentions in his conclusion section that because “chemical
`
`reactions are affected by temperature, the rate constant (k2) may not be a constant.”
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`The extracted surface reaction rate constant that is claimed in the “849 Patent, on
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`the other hand,
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`is an Arrhenius expression depending on temperature. [‘849
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`column 7, lines 10—14].
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`(Note that the term “surface reaction rate constant” has
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`a dual meaning, namely: a value of the constant corresponding to a selected value
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`Inter Partes Review of US. Patent No. 5,711,849
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`of temperature, and the function “surface reaction rate constant" which can be
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`written as an Arrhenius expression depending on temperature.) The claimed
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`surface reaction rate constant, that is extracted is the function, as is explicitly
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`taught at column 9, for example, of the “849 patent. The ‘849 patent expressly
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`requires k(T) to select uniformity conditions for the fabrication of a device [’see,
`
`Figs. 3—5, for example]. Alkire’s model fails to teach the claimed surface reaction
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`rate constant and would be useless to practice the ‘849 patent. Also, Kao focuses
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`on non-uniformity of wafers along a reactor not within the wafer so solves for a
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`completely different problem using a different model. Kao also fails to show or
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`suggest any relatively non-uniform etch profile as claimed, but rather shows non—
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`uniformity of wafers along spatial regions of the reactor. Kao also shows non—
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`symmetric etching rates, which would not be useful in any of Alkire‘s models.
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`Accordingly, Alkire and Kao lacks the fundamental elements of claim 1 of the
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`‘849 Patent.
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`12.
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`It would have not been obvious for a PHOSITA to combine Alkire with the
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`experimental measurement of reaction rate and the use of that data in modeling
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`as taught by Kao. As shown above in Figure 2, Alkire relies upon a set up for
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`an etching process having two wafer faces facing each other to formulate a model.
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`Kao, however, uses the following radial flow reactor in Figure 1 for silicon based
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`etching using a different combination of etching gases. Kao emphasizes solving
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`4
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`his model for the radius of the reactor, which is completely different from the
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`model of Alkire, which solves for the radius of the wafer, as taught by Alkire.
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`13. As shown, Figure 1 of Kao shows “r” as the radius of the reactor and solves
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`the Kao model for “r” along the radius of the reactor. The twelve distinct etch
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`rate measurements plotted in Figures 8 through 11 of Kao are not symmetrical
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`across the wafer as shown. Accordingly, a PHOSITA would not use Kao’s
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`empirical etch rate measurements at twelve distinct spatial coordinates due to the
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`lack of symmetry for analysis of a plasma etching model to the plasma etching
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`techniques and model of Alkire. Additionally, Kao focuses on different etch
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`rates on different spatial regions of the reactor as shown. Specifically, column 1
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`of page 955 of Kao discusses “[r]adial etch profiles were measured from the point
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`closest to the reactor exit (point A) to the point closest to the reactor entrance
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`(point B) for several wafer configurations” to determine etch conditions for
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`different wafers along different spatial positions of the reactor. Alkire, however,
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`provides a mathematical model for the reaction between a gas phase etchant and
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`a substrate film, which faces another substrate film for an etching process, and
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`completely lacks any experimental data to support or supplement the model.
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`Additionally, Alkire assumes constant etch conditions for each of the wafers
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`despite the location of the wafer within the reactor. A PHOSITA would not have
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`been motivated to improve the model disclosed in Alkire by using any
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`experimental data for independent confirmation of the accuracy of the model as
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`taught in Kao given that the etch rate data taught by Kao is not symmetrical, and
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`would not yield the claimed invention.
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`14.
`
`I disagree that Alkire teaches essentially the same mathematical model for
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`the etch rate reaction that the 849 Patent uses and explains that when “the same
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`mathematical model is used to describe the etch process, the solutions should be
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`the same” as declared by Graves. Rather, as noted above,
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`the Alkire’s
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`mathematical model uses (1) a uniform film, rather than a relatively non-uniform
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`film as claimed; (2) two uniform etchable films facing each other for an etching
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`process, which would yield a different model from the “849 patent; (3) isothermal
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`operation, rather than a temperature dependent model, as taught by the “849
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`patent; and (4) a purely mathematical model, rather than use of etching data, as
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`taught by the “849 patent.
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`15.
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`I also disagree that the two arguments of the Bessel functions in Alkire and
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`the ’849 patent are the same, and that the models predict the same results, and
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`that kS in the “849 patent is the same reaction rate constant as Alkire‘s k2. As
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`noted, Alkire teaches an isothermal model while the “849 patent
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`teaches a
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`temperature dependent model, and ks in the ‘849 patent is temperature dependent,
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`while k2 in Alkire is isothermal. A temperature dependent model of the ‘849
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`patent is different from an isothermal model of Alkire.
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`6
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`16.
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`l continues to believe that Alkire specifically teaches away from the use of
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`‘purely empirical programs of development’, which would teach away from the
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`use of etch rate data disclosed by Kao.
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`I assert that Alkire’s statement that
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`“purely empirical programs of development can be time consuming” does
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`criticize, discredit, or disparage the use of empirical data to improve the
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`fabrication of a device. Furthermore, Kao’s emphasizes that “the model predicts
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`a larger effect of pressure on etch rate than observed,” which confirms
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`incompatibility to discredit or discourage investigation. Kao tests “sensitivity of
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`predicted etch rate” in a failed attempt to overcome the conflict between data and
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`experiment. Kao finally admits that “the pressure dependence of ki is unknown
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`and further work is warranted” tacitly acknowledging that a PHOSITA could not
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`rely on his models or data and further discredits or discourages investigation.
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`Additionally, Kao further supports the difficulty of using his etch rate data by
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`way of the lack of correspondence in Figures 10 and 11, and concludes by
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`emphasizing “discrepancies between the model and the experimental data for
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`wafers located near the reactor exit are difficult to explain and could be the effect
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`of plasma nonuniformities at the reactor center, or an incomplete description of
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`the plasma chemistry” to further discredit or discourage investigation.
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`Accordingly, a PHOSITA would not combine the etching data or teaching of the
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`use of etching data from Kao with Alkire or any other reference in view of
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`7
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`established knowledge that Kao’s chemistries and reactor design would yield a
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`wide range of variation.
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`17.
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`I disagree that Kao teaches a PHOSITA to conduct experiments to determine
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`etch rate data and then extract a surface reaction rate constant
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`from the
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`experimental data, thus connecting the purely mathematical model of Alkire to
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`empirical data for the etch rate data to extract the surface reaction rate for defined
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`process conditions to test, validate, and improve Alkire’s model. That is.
`
`I
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`disagree that a PHOSITA would have looked to Kao to use empirical analysis
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`test and validate the model of Alkire with actual data of Kao. As discussed, the
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`model of Alkire is for an isothermal process with each wafer having the same
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`etching characteristic as other wafers within the reactor. The wafers are facing
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`each other, which is uncommon an etching process. Alkire‘s model does not
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`even use a relatively non-uniform etching profile, but rather uses a uniform
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`etching profile, which is completely flat.
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`In contrast, Kao focuses on different
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`etching rates for different wafers spatially positioned within the reactor for a
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`silicon etching process. Kao’s model and data do not even correlate with each
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`other, and have severe shortcomings as discussed. Accordingly, a PHOSITA
`
`would not connect the purely mathematical model of Alkire to empirical analysis
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`to test and validate the model of Alkire given that the data derived from Kao is
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`for a completely different purposes and use.
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`8
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`18. A PHOSITA would not have been motivated to improve the model disclosed
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`in Alkire by using experimental data to provide independent confirmation of the
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`accuracy of the model as taught by Kao. Again, as discussed, the model of Alkire
`
`is
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`for an isothermal process with each wafer having the same etching
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`characteristic as other wafers within the reactor. The wafers are facing each other,
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`which is uncommon for an etching process. Alkire’s model does not even use a
`
`relatively non-uniform etching profile, but rather uses a uniform etching profile,
`
`which is completely flat.
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`In contrast, Kao focuses on different etching rates for
`
`different wafers spatially positioned within the reactor for a silicon etching
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`process. Kao’s model and data do not even correlate with each other, and have
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`severe shortcomings as discussed. The experimental data in Kao did not
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`independently improve Alkire’s model or even Kao’s model. Accordingly, a
`
`PHOSITA would not have been motivated to improve the model disclosed in
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`Alkire by using experimental data to provide independent confirmation of the
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`accuracy of the model as taught by Kao.
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`19. A PHOSITA would not find it obvious to use the empirical analysis of Kao
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`in the similar plasma etching reaction of Alkire to test and validate the model of
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`Alkire. As discussed, the etching processes in Alkire and Kao are not similar at
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`all. Alkire taught an isothermal process with each wafer having the same etching
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`characteristic as other wafers in the reactor. The wafers are facing each other,
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`9
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`which is uncommon, and for an etching process.
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`In contrast, Kao focuses on
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`different etching rates for different wafers spatially positioned within the reactor
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`for a silicon etching process. The etching reactor design in Alkire is also different
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`from Kao’s radial flow reactor. Accordingly, the etching processes in Alkire and
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`Kao are not similar and therefore a PHOSITA would not combine them together.
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`Even if they were combined, the combination would still not lead to the claimed
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`invention.
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`20.
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`I further emphasize that Petitioner misinterprets the significance ofKao‘s ks,
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`which is not a determined reaction rate constant but instead arises as one of three
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`empirical fitting parameters, each of which alone or in combination, fails to
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`reasonably fit Kao’s experimental results. As shown in the “849 patent,
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`I
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`explained in great detail on how k6 is established, and has also supplemented this
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`Response with the Declaration from Dr. Daniel L. Flamm.
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`I would like
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`reconsideration of its arguments and does not agree with the testimony from Dr.
`
`Graves, which is not as detailed and complete as my analysis.
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`21.
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`In view of the foregoing, I would respectfully like for the Board to reconsider
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`the Decision on claim 1 and challenge Petitioner’s arguments regarding all claims
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`based upon the combined teachings of Alkire and Kao.
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`22.
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`I declare that a PHOSITA would not have combined Alkire with Kao.
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`23. First, it would not have been obvious to a PHOSITA to improve Alkire with
`
`10
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`the use of actual experimental data, such as disclosed in Kao, and there would be
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`no motivation to do so. Alkire specifically teaches “purely empirical programs of
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`development,” which does not require the use of etch rate data disclosed by Kao.
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`Nothing in Alkire shows or suggests that Alkire intended to have Alkire’s
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`model‘s supplemented in anyway by experimental data, was silent on the use of
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`any experimental data. Kao’s, however, did attempt to validate Kao’s own
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`models with experimental data, but failed miserably. Only empirical curve fitting
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`seemed to accommodate the use of any of Kao’s data, rather than Kao’s models.
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`In particular, Kao focused on the “analysis” of non-uniformities in the plasma
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`etching of silicon, using only one specific feed gas composition, with a deficient
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`reactor design which resulted in the “large degree of nonuniformity in etch rate”,
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`“discrepancies between the model and experimental data,” and “unpredictable
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`experimental results,” each ofwhich supports Kao’s failure in using experimental
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`data to confirm a mathematical model, and a PHOSITA would not combine
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`Kao’s use of experimental data with the theoretical model of Alkire.
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`24. Additionally, a PHOSITA would never use the actual experimental data or
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`related techniques reported by Kao in combination with any modeling technique
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`or with any other rector design and related process.
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`In particular, Kao was
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`etching wafers in a tragically deficient geometry using a feed gas mixture known
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`to generate a complex product composition that shifts widely responsive to
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`ll
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`variations in flow, pressure, and electrical discharge parameters. Specifically, it
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`was well known that the concentration of silicon etchant made from Kao’s
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`mixture—thought
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`to
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`be mostly
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`fluorine
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`atoms—and the
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`concomitant
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`concentrations of species that inhibit silicon etching (e.g., oxygen atoms that can
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`oxidize a silicon surface, and/or flurocarbon species that can inhibit etchant
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`attack) vary greatly as wafer surface area, RF power, pressure, flow, temperature
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`and other discharge variables are changed.
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`(See David Edelson and Daniel L.
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`Flamm, Computer Simulation ofa CF4 Plasma Etching Silicon, 56 J. APPLIED
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`PHYSICS 1522 (1984), attached hereto as Exhibit 2001; see also l.C. Plumb and
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`KR. Ryan,A Model ofthe Chemical Processes Occurring in CF4/02 Discharges
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`Used in Plasma Etching, 6 Plasma Chem. and Plasma Processing 205 (1986),
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`attached hereto as Exhibit 2002.) Accordingly, without any knowledge of Kao’s
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`gaseous product composition, there was no known way to extract an extensible
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`etch rate based on profile or point etch rate data measured using a CF4/O2 plasma,
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`in Kao’s reactor, and the Kao reference did nothing to change this.
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`25. Kao supports this conclusion. He explicitly states, “the model predicts a
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`larger effect of pressure on etch rate than observed,” which confirms
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`incompatibility. Kao tests “sensitivity of predicted etch rate" in a failed attempt
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`to overcome the conflict between data and experiment. Kao finally admits that
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`“the pressure dependence of ki is unknown and further work is warranted” tacitly
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`12
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`acknowledging that
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`a PHOSITA could not
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`rely on his models or data.
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`Additionally, Kao further supports the difficulty of using his etch rate data by
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`way of the lack of correspondence in Figures 10 and 11. Finally, Kao concludes
`
`by emphasizing “discrepancies between the model and the experimental data for
`
`wafers located near the reactor exit are difficult to explain and could be the effect
`
`of plasma nonuniformities at the reactor center, or an incomplete description of
`
`the plasma chemistry.” Most critically, Kao did not measure chemical
`
`composition or any products of his complex plasma chemistry,
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`the identity,
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`. relative concentrations, and spatial distributions of species interacting with his
`
`silicon wafers were unknown. Accordingly, a PHOSITA could not combine the
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`etching data from Kao with Alkire or any other reference in view of established
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`knowledge that Kao’s chemistries and reactor design would yield a wide range
`
`of variation. No PHOSITA would ever use results or data or the concept of using
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`data from Kao’s analysis for the fabrication of any device with Alkire’s model.
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`26. As further background, and reemphasized herein, this Petition is not the first
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`initiated against the ‘849 patent. Lam Research Corp. initiated a petition for inter
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`partes review ofthe '849 patent based upon Battey. Dr. Flamm overcame Lam’s
`
`invalidity arguments based upon Battey.
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`(Lam Research Corp. v. Flamm,
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`lPR2016—0466, Paper No. 7, at 8-10 (Jul. 19, 2016).) The Petitioners now argue
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`that: “Kao, unlike Battey, explicitly discloses the calculation of a surface reaction
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`rate constant (k6) based on the empirical measurements of an etch rate profile.
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`Accordingly, Kao is materially different than Battey.”
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`27. Petitioners, however, misinterpret the significance of Kao’s kc, which is not
`
`a determined reaction rate constant. In actuality, it arises as one of three empirical
`
`fitting parameters, each of which alone or in combination, fails to reasonably fit
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`Kao’s experimental results, despite that they were for a rather narrow range of
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`conditions using only one rf power level and a single temperature in the reactor.
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`28. Kao discloses that what are tantamount to three fitting parameters, kd kg, kc
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`(shown in Table 2), were calculated by iteratively using a general finite element
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`numerical equation solver code (TWODEPEP) to solve greatly oversimplified
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`transport/reaction equations (8a—b) they applied to represent a very complex
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`system, then comparing the solutions obtained for various combinations of etch
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`rate values to obtain the set that most closely representing the etch rates of silicon
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`they observed. The single set of system parameters are listed in Table l and the
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`radial flow reactor is shown in Fig. 1. Kao never discloses how such analysis
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`was performed, explicitly or implicitly, but merely recites that TWODEPEP is
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`available with reference “22. International Mathematical and Statistical Libraries
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`TWODEPEP, 1983.” A PHOSITA would not have been able to understand or
`
`use a general finite element numerical equation solver code (TWODEPEP) in this
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`manner.
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`29. Unsurprisingly, Kao’s fitted parameters do not work well, as shown by
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`comparing the effects of pressure (at Fig. 9), on the etch rates amongst different
`
`wafers (at Figs 10, 11) or by comparing the parameter identified with “etch rate”
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`from the Kao three parameter fit to the accepted etch rate constant for fluorine
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`atoms (which Kao assumes is the only surface reacting species emanating from
`
`this complex chemistry).
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`In fact, the authors admit as much: “At 70°C, kC from
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`(20) has a value of 49 cm/s, which is a factor of six less than that found from our
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`work.” Kao further states: “The three rate constants [i.e., the number used to fit
`
`the solver to their data] are assumed to be independent of pressure. However,
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`when the model was use to predict the etch rates for the data of Fig. 4 (pressure
`
`effect), the model predicts a larger effect of pressure on the etch rate than was
`
`observed.
`
`.
`
`.
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`. The reason for this pressure dependence of kt is unknown and
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`further work is warranted.”
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`30. Kao thereby acknowledges, as a PHOSITA would, that even using the exact
`
`same equipment and general process conditions (e.g.,
`
`the reactor parameters
`
`shown in Table I) which the fitted parameters (kd, ke, kt) were based on, these
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`“rate constants” do not agree with their model predictions. Moreover, even if
`
`their original assumption that ki is as constant is arbitrarily changed to make kt
`
`proportional to pressure, things do not get much better.
`
`31. No PHOSITA would consider Kao’s data, modeling, or associated
`
`15
`
`
`
`Inter Partes Review of US. Patent No. 5,711,849
`IPR2017-00392
`
`techniques useful for anything, never mind obtaining a surface reaction rate
`
`constant that could be useful
`
`in the fabrication of a device or be useful
`
`in
`
`motivating a PHOSITA to combine with Alkire’s model.
`
`32. I declare under penalty of perjury under the laws of the United States of
`
`America that the foregoing is true and correct.
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`Executed on this 6th day of September, 2017.
`
` 92M
`
`Daniel L. Flamm
`
`16
`
`
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