Samsung Electronics Co., Ltd. v. Demaray LLC
`Samsung Electronic's Exhibit 1004 Vol . 3
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`Ex. 1004, Page 1107
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`Samsung Electronic's Exhibit 1004 Vol . 3
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`Ex. 1004, Page 1107
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`IPR2021-00104
`Patent 7,381,657 B2
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`explained during prosecution that the claimed filter ‘is a filter that passesall
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`of the frequencies of the [] power supply except within a narrow band
`centered on the RF frequency of the RF bias.” See Prelim. Resp. 24 (citing
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`Ex. 1052, 1130-31, 1134). We do not understand the claim term to be so
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`limited. The parties are invited to address the construction of this term if
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`they choose.
`Based on our review of the present record, we determinePetitioner,
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`relying onthe deposition testimony of Dr. Subramanian,has sufficiently
`shown that Barber and Hirose teach the subject matter recited in claim
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`element 2[d]. See, e.g., Pet. 28 (citing Ex. 1002 { 101; Pet. 15-28). For
`example, Petitioner has provided sufficient evidence that Hirose teaches a
`narrow bandfilter (filter 20) (see e.g., Pet. 22; Ex. 1002
`81), that is placed
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`between a powersupply andanelectrodeto selectively filter high current
`output to protect the powersupply(see e.g., Pet. 20; Ex. 1002 { 79), and also
`teaches modifying the filter’s optimum resonance point to adjust plasma
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`process conditions(see, e.g., Pet. 19 (citing Ex. 1006, code (57), 3:45-4:38;
`Ex. 1002 99 77-78)). Additionally, Dr. Subramaniantestifies that a person
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`of ordinary skill in the art would have configured Barber’s system such that
`RF power supply 235 would provide an RF bias to the substrate, where the
`RF bias that corresponds to the narrow bandrejection filter to protect the DC
`powersupply from damage while also assisting in providing as stable
`waveform. Ex. 1002 7 101; id ¥ 83 (stating a POSITA would have been
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`motivated to configure the filter to be implement in Barber’s system to be a
`narrow bandrejection filter to ensure the appropriate frequency of
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`frequencies associated with RF power supply 235 are isolated from DC
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`powersupply 230).
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`38
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`Ex. 1004, Page 1108
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`Ex. 1004, Page 1108
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`IPR2021-00104
`Patent 7,381,657 B2
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`Petitioner has sufficiently shownat this stage of the proceeding that
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`POSITA would have understood that choosingto reject a specific frequency,
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`or a narrow bandoffrequencies, depending on the bandwidth of RF supply
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`235 selected in Barber’s system would have been a known wayto achieve
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`the benefits disclosed in Hirose and known atthe time. See, e.g., Pet. 24
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`(citing Ex. 1002 7 89; Ex. 1006, Figs. 1, 6; Ex. 1023, 7:51-61; Ex. 1013, 4—
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`6; Ex. 1057, 7:23-34; Ex. 1058, 1:63—2:1).
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`e) Claim element 2[e] - Providing a Magnetic Field
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`Claim element 2[e] recites “providing a magnetic field to the target.”
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`Ex. 1001, 23:24. Petitioner contends that Barber discloses rotating magnet
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`assembly 280 that produces a magnetic field that penetrates Barber’s target
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`260. Pet. 28-29 (citing Ex. 1005, 6:17—27, 8:66—9:2; Ex. 1002 4 102).
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`Patent Ownerdoesnotdispute Petitioner’s contentions at this stage of the
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`proceeding. See generally Prelim. Resp.
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`Wehave reviewedPetitioner’s arguments and evidence and determine
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`that Petitioner sufficiently shows Barber discloses the subject matter recited
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`in claim element 2[e].
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`J) Claim element 2[f] - Wherein Clause
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`Claim element 2[f] recites “wherein an oxide material is deposited on
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`the substrate, and the insulating film is formed by reactive sputtering in a
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`mode between a metallic mode and a poison mode.” Ex. 1001, 23:25-27.
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`Petitioner asserts Barber describes depositing silicon dioxide and
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`aluminum nitride. Pet. 29 (citing Ex. 1005, 3:44—-55; Ex. 1002 f¥ 103-104).
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`Petitioner further asserts that Barber’s deposition process discloses forming
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`an insulating film by reactive sputtering in a mode between a metallic mode
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`and a poison modein multiple ways. Pet. 29-34(citing, inter alia, Ex. 1002
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`qq 105-114; Ex. 1005, code (54), 3:44-57, 4:24-26, 6:32-42, 6:51-62, 7:1-
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`39
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`Ex. 1004, Page 1109
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`Ex. 1004, Page 1109
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`IPR2021-00104
`Patent 7,381,657 B2
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`8:12, 7:65-8:5, 8:45-48, Figs. 3, 5); see, e.g, Pet. 30-31 (asserting the curve
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`shown in Barber Figure 3 reflects the behavior of a metallic target fully
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`consuming reactive gas to the behavior of the fully poisoned target). Patent
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`Ownerdoesnotdispute Petitioner’s contentionsat this stage of the
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`proceeding. Wehave reviewed Petitioner’s arguments and determine that
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`Petitioner sufficiently shows Barber discloses the subject matter recited in
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`claim element 2[f].
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`g) Conclusion for the Claim 2
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`For the reasons stated above, Petitioner has sufficiently shownthat
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`Barber and Hiroseteach all of the subject matter recited in claim 2 and has
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`articulated a reasonable rationale to combinethe teachings of the references
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`to arrive at the subject matter of claim 2. As such, wefind that Petitioner’s
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`arguments and evidenceare sufficient to show a reasonable likelihood
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`Petitioner would prevail in showing that claim 2 would have been obvious
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`over the combination of Barber and Hirose.
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`4.
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`Analysis for Claims 3, 4, 6, 8, 10-12, and 21
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`Wehavereviewed Petitioner’s arguments and evidencethat
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`dependentclaims3, 4, 6, 8, 10-12, and 21 would have been obviousover the
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`combination of Barber and Hirose. Pet. 34-41. Patent Owner does not
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`dispute Petitioner’s challenges to these dependentclaims, aside from arguing
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`that Petitioner’s analysis for the dependent claims do not cure the
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`deficiencies in Petitioner’s arguments for claim 2. Prelim. Resp. 61. Based
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`on the preliminary record before us, we find that Petitioner’s arguments and
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`evidenceare sufficient to show a reasonable likelihood Petitioner would
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`prevail in proving unpatentability of dependent claims3, 4, 6, 8, 10-12, and
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`21.
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`40
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`Ex. 1004, Page 1110
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`Ex. 1004, Page 1110
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`IPR2021-00104
`Patent 7,381,657 B2
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`H. Remaining Asserted Challenges
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`Petitioner also asserts an additional fifteen obviousness groundsthat,
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`collectively, challengé claims 1-21. See Pet. 3-5, 41-72. Each challengeis
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`based on the Barber and Hirose in combination with one or more additional
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`references. Jd. Other than arguing that Barber and Hirose do not teach
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`certain limitations of claim 1 for the same reasons Barber and Hirose do not
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`teach the correspondinglimitations of claim 2, Patent Ownerdoes not
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`present any arguments directed specifically to the remaining asserted
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`challenges. See, e.g., Prelim. Resp. 2-61.
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`Having considered the parties’ arguments and evidence, we determine
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`Petitioner makesa sufficient showing on these challenges.
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`IH. CONCLUSION
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`For the reasons set forth above, we determine that Petitioner has
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`demonstrated a reasonable likelihood of prevailing with respect to at least
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`one challenged claim of the ’657 patent. Thus, we institute an inter partes
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`review onall challenged claims and onall grounds presented.
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`IV. ORDER
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`In consideration of the foregoing, it is hereby:
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`ORDEREDthatan inter partes review is instituted on each ofthe
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`groundsasserted in the Petition; and
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`FURTHER ORDEREDthat, pursuant to 35 U.S.C. § 314(c) and
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`37 C.F.R. § 42.4,notice is hereby given of the institution ofa trial, which
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`shall commence onthe entry date of this decision.
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`41
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`Ex. 1004, Page 1111
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`Ex. 1004, Page 1111
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`IPR2021-00104
`Patent 7,381,657 B2
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`FOR PETITIONER:
`Naveen Modi
`Joseph Palys
`PAUL HASTINGS LLP
`Naveenmodi@paulhastings.com
`Josephpalys@paulhastings.com
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`FOR PATENT OWNER:
`Hong Zhong
`Crawford Wells
`Benjamin Hattenbach
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`mwells@irell.com |
`bhattenbach@irell.com
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`42
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`Ex. 1004, Page 1112
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`Ex. 1004, Page 1112
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