Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`As described in the following claim chart, claims 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, and 12 of U.S. Patent No. 6,968,248 (“the ’248
`Patent”) are invalid under 35 U.S.C. §§ 102 and/or 103 in view of U.S. Patent No. 6,671,570 (“Schulze”). To the extent that Schulze
`is found not to anticipate one or more of the claims of the ’248 Patent, those claims are obvious in view of Schulze, alone or in
`combination with other prior art references, including, without limitation, one or more references identified in Exhibit D to
`Defendant’s Preliminary Invalidity Contentions. Defendant’s Preliminary Invalidity Contentions provide additional details regarding
`the motivation to combine Schulze and the references cited in that exhibit.
`Citations to particular documents or passages are merely exemplary of where each limitation is found. Defendant reserves the right to
`rely on other documents or passages providing comparable evidence of how Schulze alone or in combination with other prior art
`renders the ’248 Patent invalid.
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`1[pre] A method for scheduling in an automated
`manufacturing environment, comprising:
`
`Defendant does not concede that the preamble is limiting. To the extent
`it is limiting, Schulze discloses a method for scheduling in an automated
`manufacturing environment. See, e.g.:
`
`Schulze at Title: “System and Method for Automated Monitoring and
`Assessment of Fabrication Facility.”
`
`Schulze at Abstract: “During monitoring various messages are
`transmitted on the system bus between the semiconductor fabrication
`tools and the manufacturing execution system and the monitoring and
`assessment system, and appropriate triggers are generated based upon
`the messages where the triggers are selected from a set of defined
`triggers.”
`
`Schulze at 1:14-17: “The field of the present invention relates to system
`and methods for monitoring and assessing the performance and
`
`- 1 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`operation of fabrication facilities, such as semiconductor fabrication
`facilities.”
`
`Schulze at 4:34-40: “In accordance with a first embodiment of the
`invention, a method for monitoring and assessing operation of a semi-
`conductor fabrication facility comprises the steps of connecting a
`monitoring and assessment system to a system bus which is connected
`directly or indirectly to a manufacturing execution system and a plurality
`of semiconductor fabrication tools.”
`
`Schulze at 5:36-39: “FIGS. 1 through 3 are top-level diagrams
`illustrating examples of semiconductor fabrication systems in which an
`automated monitoring and assessment system incorporates features of
`the present invention.”
`
`Schulze at 5:40-43: “FIG. 4 is a top-level diagram illustrating further
`details of a semiconductor fabrication system in which an automated
`monitoring and assessment system incorporates features of the present
`invention.”
`
`Schulze at 5:48-52: “FIGS. 6A and 6B are diagrams illustrating one
`embodiment of a system logic flow for processing messages at an
`automated monitoring and assessment system based upon a transition
`initiation type.
`
`- 2 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`Schulze at 5:53-56: “FIGS 7A and 7B are diagrams illustrating one
`embodiment of a system logic flow for receiving and filtering trigger
`messages at an automated monitoring and assessment system.”
`
`Schulze at 5:54-59: “FIG. 8 is a block diagram showing details in
`accordance with one embodiment of a automated monitoring and
`assessment system incorporating features of the present invention.”
`
`Schulze at 6:62-7:4: “As illustrated in FIG. 1, a manufacturing execution
`system 102 is connected to a system bus 105, along with a plurality of
`semiconductor fabrication tools 115 (simply labeled ‘equipment’ in FIG.
`1), which may include processing tools and/or metrology tools. The
`manufacturing execution system 102 controls the manufacture of
`semiconductor wafers or other products according to a programmed
`recipe, by sending commands to the various semiconductor fabrication
`tools 115 and monitoring their activity.”
`
`Schulze at FIGS. 1-4, 6A-6B, 7A-7B, 8.
`
`Furthermore, this limitation would have been obvious in light of Schulze
`alone or in combination with references identified in Exhibit D relating
`to this limitation. Defendant’s Preliminary Infringement Contentions
`describes the motivations to combine Schulze and those references.
`
`- 3 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`
`
`NO.
`
`1[a]
`
`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`automatically detecting an occurrence of a
`predetermined event in an integrated,
`automated process flow;
`
`Schulze discloses automatically detecting an occurrence of a
`predetermined event in an integrated, automated process flow. See, e.g.:
`
`Schulze at Abstract: “Through a user interface, the state models for each
`fabrication tool can be configured where each state model is based upon
`a set of defined triggers for each tool.” See also id. at 4:40-51.
`
`Schulze at 4:52-63: “In another embodiment of the invention, a system
`for monitoring and assessing operation of a semiconductor fabrication
`facility for assessing overall equipment effectiveness and overall
`fabrication effectiveness comprises a monitoring and assessment system
`for receiving messages having equipment information therein for
`tracking operation states of a plurality of semiconductor fabrication
`tools. A manufacturing execution system for controlling the manufacture
`of semiconductor wafers or other products according to a programmed
`recipe sends commands to the semiconductor fabrication tools, monitors
`their activity and sends messages to the monitoring and assessment
`system. These messages are transmitted over a system bus that is
`connected directly or indirectly to the manufacturing execution system
`and the monitoring and assessment system.”
`
`Schulze at 5:3-8: “A user may configure state models for the
`semiconductor fabrication tools in which the state models are based on a
`set of defined triggers for each tool. Base[d] on the trigger information
`
`- 4 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`and other events, the state transitions are maintained in a tracking
`database for recording state transitions within the state models.”
`
`Schulze at 5:27-33: “A user interface may monitor and configure state
`models for the semiconductor fabrication tools in the state model logic,
`may configure trigger/event information in the trigger/event interface,
`may monitor state 30 transitions in the tracking database, and may
`monitor equipment effectiveness and overall fabrication effectiveness of
`the fabrication tools.”
`
`Schulze at 6:67-7:7: “The manufacturing execution system 102 controls
`the manufacture of semiconductor wafers or other products according to
`a programmed recipe, by sending commands to the various
`semiconductor fabrication tools 115 and monitoring their activity. Also
`connected to the system bus 105 is an automated monitoring and
`assessment system 107, which may comprise one or more computers,
`servers and databases, as further described herein.”
`
`Schulze at 10:1-18: “As shown in FIG. 8, the automated monitoring and
`assessment system 800 preferably comprises a trigger/event interface
`processor 810 for receiving messages and various other event
`information which may cause state changes to occur. The trigger/event
`interface processor 810 may receive sensor events 802, SECS messages
`803 (or messages in other formats besides SECS) and MES messages
`804, as well as manually entered information 805 via a user interface
`820. A state model processor 815 is defined for the semiconductor
`
`- 5 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`fabrication facility and maintained in the automated monitoring and
`assessment system 800. The state model processor 815 may be initially
`set up via the user interface 820. When messages or events occur, the
`trigger/event interface 810 processes them and forwards them to the
`state model logic processor 815 to transition states as necessary, upon
`which a state change transition logger 823 logs the state change, along
`with any pertinent information, in a tracking database 830.”
`
`Schulze at FIGS. 1, 8.
`
`Furthermore, this limitation would have been obvious in light of Schulze
`alone or in combination with references identified in Exhibit D relating
`to this limitation. Defendant’s Preliminary Infringement Contentions
`describes the motivations to combine Schulze and those references.
`
`1[b]
`
`automatically notifying a software scheduling
`agent of the occurrence; and
`
`Schulze discloses automatically notifying a software scheduling agent of
`the occurrence. See, e.g.:
`
`Schulze at Abstract, 4:42-48: “During monitoring various messages are
`transmitted on the system bus between the semiconductor fabrication
`tools and the manufacturing execution system and the monitoring and
`assessment system…”
`
`Schulze at 4:52-66: “In another embodiment of the invention, a system
`for monitoring and assessing operation of a semiconductor fabrication
`facility for assessing overall equipment effectiveness and overall
`
`- 6 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`fabrication effectiveness comprises a monitoring and assessment system
`for receiving messages having equipment information therein for
`tracking operation states of a plurality of semiconductor fabrication
`tools. A manufacturing execution system for controlling the manufacture
`of semiconductor wafers or other products according to a programmed
`recipe sends commands to the semiconductor fabrication tools, monitors
`their activity and sends messages to the monitoring and assessment
`system. These messages are transmitted over a system bus that is
`connected directly or indirectly to the manufacturing execution system
`and the monitoring and assessment system.”
`
`Schulze at 7:37-42: “The automated monitoring and assessment system
`107 receives information from the transmitted or published messages,
`and uses that information to track the operation states of the various
`semi-conductor fabrication tools 115, according to techniques described
`in more detail herein.”
`Schulze at 7:56-61: “As further shown in FIG. 2, also connected to the
`system bus 205, via a software bridge 208, is one embodiment of an
`automated monitoring and assessment system 207 incorporating features
`of the present invention, which may comprise one or more computers,
`servers, and databases, as further described herein.”
`Schulze at 8:13-19: “[M]essages transmitted or published over the
`system bus 205 from the various semiconductor fabrication tools 215 to
`the manufacturing execution system 202 may be sent as SECS
`messages, and may include, for example, various alarm messages, event
`
`- 7 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`messages, parameter updates (e.g., SVID messages), symptom (or
`trigger) messages and the like.”
`Schulze at 8:65-9:9: “Messages transmitted or published over the system
`buses 305 or 306 from the various semiconductor fabrication tools 315
`to the manufacturing execution system 302 or automated monitoring and
`assessment system 307 may be sent as SECS messages, and may
`include, for example, various alarm messages, event messages,
`parameter updates (e.g., SVID messages), symptom (or trigger)
`messages, and the like. The automated monitoring assessment system
`307 receives information from the transmitted or published messages,
`and uses that, information to track the operation states of the various
`semi-conductor fabrication tools 315, according to techniques described
`in more detail herein.”
`Schulze at 15:49-58, 17:10-15: “FIGS. 6A and 6B are diagrams
`illustrating a software logic flow for processing messages at the
`automated monitoring and assessment system 407 based upon the
`transition initiation type. As shown in FIGS. 6A and 6B, the automated
`monitoring and assessment system 407 first receives a message or other
`trigger event in step 601. In step 602, the software determines whether
`the transition initiation type is a “1”, indicating an alarm ID. If so, then
`in step 630, the alarm event ID (ALID) is processed.”
`
`- 8 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`Schulze at 35:17-20: “The present invention may also include software
`and computer programs incorporating the process steps and instructions
`described above that are executed in different computers.”
`
`Schulze at FIGS. 1, 2, 3, 6A, and 6B.
`
`Furthermore, this limitation would have been obvious in light of Schulze
`alone or in combination with references identified in Exhibit D relating
`to this limitation. Defendant’s Preliminary Infringement Contentions
`describes the motivations to combine Schulze and those references.
`
`1[c]
`
`reactively scheduling an action from the
`software scheduling agent responsive to the
`detection of the predetermined event.
`
`Schulze discloses reactively scheduling an action from the software
`scheduling agent responsive to the detection of the predetermined event.
`See, e.g.:
`
`Schulze at Abstract, 4:42-51: “During monitoring various messages are
`transmitted on the system bus between the semiconductor fabrication
`tools and the manufacturing execution system and the monitoring and
`assessment system, and appropriate triggers are generated based upon
`the messages where the triggers are selected from a set of defined
`triggers. During operation, the state models are updated for each tool
`affected by one of the triggers and transitions within the state models are
`recorded in a tracking database.”
`
`Schulze at 6:62-7:4: “As illustrated in FIG. 1, a manufacturing execution
`system 102 is connected to a system bus 105, along with a plurality of
`
`- 9 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`semiconductor fabrication tools 115 (simply labeled ‘equipment’ in FIG.
`1), which may include processing tools and/or metrology tools. The
`manufacturing execution system 102 controls the manufacture of
`semiconductor wafers or other products according to a programmed
`recipe, by sending commands to the various semiconductor fabrication
`tools 115 and monitoring their activity.”
`
`Schulze at 10:1-9: “As shown in FIG. 8, the automated monitoring and
`assessment system 800 preferably comprises a trigger/event interface
`processor 810 for receiving messages and various other event
`information which may cause state changes to occur. The trigger/event
`interface processor 810 may receive sensor events 802, SECS messages
`803 (or messages in other formats besides SECS) and MES messages
`804, as well as manually entered information 804 via a user interface
`820.”
`
`Schulze at 10:9-18: “A state model processor 815 is defined for the
`semiconductor fabrication facility and maintained in the automated
`monitoring and assessment system 800. The state model processor 815
`may be initially set up via the user interface 820. When messages or
`events occur, the trigger/event interface 810 processes them and
`forwards them to the state model logic processor 815 to transition states
`as necessary, upon which a state change transition logger 823 logs the
`state change, along with any pertinent information, in a tracking
`database 830.”
`
`- 10 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`Schulze at 11:44-50: “Preferably, each state also has an associated state
`description and set of state properties. The state description may simply
`be a text field of, for example, 80 characters. The state properties may
`include the following: Automatic Transition Triggers—collectively
`define the symptoms (i.e., trigger message) which cause a state
`transition to this state.” See also id. at 11:51-12:18, 12:22-13:21.
`
`Schulze at 15:49-58, 17:10-15: “FIGS. 6A and 6B are diagrams
`illustrating a software logic flow for processing messages at the
`automated monitoring and assessment system 407 based upon the
`transition initiation type. As shown in FIGS. 6A and 6B, the automated
`monitoring and assessment system 407 first receives a message or other
`trigger event in step 601. In step 602, the software determines whether
`the transition initiation type is a “1”, indicating an alarm ID. If so, then
`in step 630, the alarm event ID (ALID) is processed…”
`Schulze at 16:26-29: “If the transition initiation type is neither “1”, “2
`nor “3”, then the software determines whether the message contains a
`trigger. If so, the trigger is processed using the state model logic.”
`Schulze at 17:24-43: “Certain trigger messages from the manufacturing
`execution system 402 may be set up to cause a delayed transition
`between states in a tool’s state table logic, by modifying a tool’s external
`state(s). For example, a No Operator or No Product trigger message
`from the manufacturing execution system 402 may cause a delayed
`transition. As an illustration of this operation, assume a semiconductor
`fabrication tool 415 is processing wafers in the Productive state. The
`
`- 11 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`manufacturing execution system 402 (or manufacturing execution
`system) sends a No Product trigger message for the tool 415. The
`automated monitoring and assessment system does not transition to a
`Standby state until the tool 415 has completed processing. However, the
`tool’s external state is modified to reflect the fact that there is no further
`product. When the tool 415 eventually finishes processing at a later
`time, the tool 415 will transition to a Standby/No Product state instead
`of a Standby/Idle state, due to the effect of the No Product trigger
`previously received. In step 703, the automated monitoring and
`assessment system sets external states that are keyed to the particular
`trigger that has been received.”
`
`Schulze at 18:4-16: “If the current state is not locked, then the process
`700 moves forward to step 715, in which the automated monitoring and
`assessment system determines whether or not the current state is
`configured for state branching based upon recipe (PPID) classification
`responses. If so, then in step 718 a state transition is carried out based
`upon the recipe (PPID) classification. Otherwise, in step 720 the
`automated monitoring and assessment system determines whether the
`current state is configured for state branching based upon the existence
`of external states. If so, then in step 723 a transition is carried out based
`upon the external state(s). Otherwise, in step 725 a state transition is
`carried out based upon the particular trigger.”
`
`Schulze at 18:17-28: “In some cases, a trigger may initiate a transition
`from a sub-state causing the state model to return to the previous state.
`
`- 12 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`For example, an “Tool Alarm Cleared” trigger may transition the tool
`from an Unscheduled Down state back to a Production, Engineering or
`Standby state. The new state may depend upon what state the tool was
`in prior to the original trigger (e.g., “Tool Alarm”) causing the state
`change to the Unscheduled Down state in the first place. If the state
`model calls for a transition to a previous state, then the previous state
`can be looked up from the tracking database 430 (based upon the tool
`ID), and the previous state will then be used as the new state.”
`
`Schulze at 19:3-6: “For example, a trigger message for ‘Flow Abort’
`may be classified as an ‘Interrupt’ and may cause a transition to
`‘Unscheduled Down Time (UDT)/Flow Problem.’”
`
`Schulze at 26:49-52: “Normally, the trigger may cause a state change for
`the tool 415; however, the trigger may also set an external state (such as
`No Operator, or No Product) with or without causing a state transition.”
`
`Schulze at 34:60-35:11: “In one or more embodiments as described
`herein, an automated monitoring and assessment system performs state
`tracking and logic-based determination of transition states, on a tool-by-
`tool basis. External states are provided for events that do not necessarily
`impact the tool at the moment, but can be used to help determine the
`next transition state when an appropriate trigger occurs. The external
`states are not necessarily known to the particular tool, but are maintained
`by the automated monitoring and tracking software. A message from
`one tool may be used to set a trigger to change the external state or
`
`- 13 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`2
`
`The method of claim 1, wherein automatically
`detecting the occurrence of the predetermined
`event includes detecting an unplanned event
`or an unexpected event.
`
`internal state of a second tool, or any number of other tools. External
`conditions may be aggregated to form a single super-condition requiring
`all its constituent parts (i.e., conditions) to be satisfied in order to be
`true. In addition to external conditions, recipe classifications may also be
`used to select new states based upon trigger events. Thus, state
`branching may be based upon the current state, trigger, and any external
`states or recipe classification.”
`
`Schulze at FIG. 8; see also id. at 22:3-9, FIGS. 10B-1 & 10B-2.
`
`Furthermore, this limitation would have been obvious in light of Schulze
`alone or in combination with references identified in Exhibit D relating
`to this limitation. Defendant’s Preliminary Infringement Contentions
`describes the motivations to combine Schulze and those references.
`
`Schulze discloses detecting an unplanned event or an unexpected event.
`See, e.g.:
`
`Schulze at 11:51-55: “[A] state change to Unscheduled Maintenance of a
`main tool would automatically change the states of all associated
`chambers on the cluster tool.” See also id. at 22:66-23:23.
`
`Schulze at 12:33-35, 12:51-53: “The following are possible default
`transition types, as defined by the E58 Standard:… Transition 5, Fault
`
`- 14 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`Detect in Productive… Defined as an automatic transition from a
`Productive state to an Unscheduled Down state.”
`
`Schulze at 12:57-59: “Transition 7, Fault Detected in Standby… Defined
`as an automatic transition from a Standby State to an Unscheduled
`Down state.”
`
`Schulze at 13:15-17: “Transition 14, Fault Detected in Engineering
`State… Defined as an automatic transition from an Engineering state to
`an Unscheduled Down state.”
`
`Schulze at 19:3-6: “For example, a trigger message for ‘Flow Abort’
`may be classified as an ‘Interrupt’ and may cause a transition to
`‘Unscheduled Down Time (UDT)/Flow Problem.’”
`
`Furthermore, this limitation would have been obvious in light of Schulze
`alone or in combination with references identified in Exhibit D relating
`to this limitation. Defendant’s Preliminary Infringement Contentions
`describes the motivations to combine Schulze and those references.
`
`Schulze discloses detecting an occurrence of an appointment state
`change. See, e.g.:
`
`Schulze at 5:13-23: “The monitoring and assessment system comprises a
`trigger/event interface for receiving messages having fabrication tool
`information therein for tracking operation states of a plurality of
`
`- 15 -
`
`3
`
`The method of claim 1, wherein automatically
`detecting the occurrence of the predetermined
`event includes detecting an occurrence of an
`appointment state change.
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`semiconductor fabrication tools. A state model logic receives the
`tracking operation information for each fabrication tool having defined
`states and a state transition logic defining triggering events and the state
`transitions related to the triggering event.”
`
`Schulze at 7:31-37: “Messages (e.g., SECS messages) transmitted or
`published over the system bus 105 from the various semiconductor
`fabrication tools 115 to the manufacturing execution system 102 may
`include, for example, various alarm messages, event messages,
`parameter updates (e.g., SVID messages), symptom (or trigger)
`messages, and the like.”
`
`Schulze at 9:55-63: “Messages (e.g., SECs messages) transmitted or
`published over the system bus 405 or through the equipment supervisor
`workstation 425 from the various semiconductor fabrication tools 415
`may include, for example, various alarm messages, event messages,
`parameter updates (e.g., SVID messages), symptom (or trigger)
`messages, and the like, which may be used in connection with the
`automated monitoring and assessment system 407 as hereinafter
`described.”
`
`Schulze at 11:51-56: “[A] state change to Unscheduled Maintenance of a
`main tool… automatically change[s] the states of all associated
`chambers on the cluster tool.”
`
`- 16 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`Schulze at 15:49-58, 17:10-16: “FIGS. 6A and 6B are diagrams
`illustrating a software logic flow for processing messages at the
`automated monitoring and assessment system 407 based upon the
`transition initiation type. As shown in FIGS. 6A and 6B, the automated
`monitoring and assessment system 407 first receives a message or other
`trigger event in step 601. In step 602, the software determines whether
`the transition initiation type is a “1”, indicating an alarm ID. If so, then
`in step 630, the alarm event ID (ALID) is processed.” See also id. at
`15:66-16:16 (describing a “collection event ID (CEID)”), 16:13-17
`(describing a “system variable ID (SVID)”), 27:48-28:34 (describing
`user interface to define ALID, CEID, and SVID mappings to triggers).
`Schulze at 18:17-28: “In some cases, a trigger may initiate a transition
`from a sub-state causing the state model to return to the previous state.
`For example, an “Tool Alarm Cleared” trigger may transition the tool
`from an Unscheduled Down state back to a Production, Engineering or
`Standby state. The new state may depend upon what state the tool was
`in prior to the original trigger (e.g., “Tool Alarm”) causing the state
`change to the Unscheduled Down state in the first place. If the state
`model calls for a transition to a previous state, then the previous state
`can be looked up from the tracking database 430 (based upon the tool
`ID), and the previous state will then be used as the new state.”
`
`Schulze at 18:32-59: “In step 735, the automated monitoring and
`assessment system determines whether the new state is configured for
`sub-state linkage, as in the case where a cluster tool has a main tool
`
`- 17 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`linked to individual modules, or has interlinked modules. Each
`processing module of a cluster tool is preferably processed with its own
`independent state model. Any part (i.e., module) of a cluster tool may
`interact with other tools based on its state model. As an illustration of
`the effect of this software structure, if a robot failure occurs on a cluster
`tool, each chamber (i.e., module) should transition to an appropriate
`Non-Productive state until the robot is repaired. This type of action is
`implemented through the logic in step 735, which checks for sub-state
`linkages when a trigger is received and acted upon. If the new state of
`the current tool is configured for sub-state linkage, then the process 700
`(i.e., steps 703 et seq.) are repeated for each linked tool, as indicated by
`step 738. In some instances, this may lead to nested processing, where a
`first tool has a sub-state linkage to a second tool, which in turn has a
`sub-state linkage to a third tool. The automated monitoring and
`assessment system preferably prohibits a cross-referencing sub-state
`linkages between tools. That is, if a tool has already been processed
`according to the steps in process 700, then step 738 is blocked for that
`particular tool so that the processing will not be repeated for it. If there
`are no sub-state linkages for the new state, or if all sub-state linkages
`have been processed, then the process 700 is complete.”
`
`Schulze at 22:66-23:16: “FIGS. 10C-1 and 10C-2 depict an example of
`the state properties screen display with the Cluster Tool State Linkage
`tab 1042 selected. The cluster tool state linkage sub-screen 1050 allows
`the change of a state for one tool to initiate a trigger for a different tool.
`When the tab 1042 is selected, the user is presented with a display of all
`
`- 18 -
`
`IPR2021-01342
`Ocean Semiconductor Exhibit 2025
`
`

`

`Exhibit D-9 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,968,248 and U.S. Patent No. 6,671,570 (“Schulze”)
`
`
`
`NO.
`
`’248 CLAIM ELEMENT
`
`U.S. Patent No. 6,671,570 (“Schulze”)
`
`tools 1053 in the system. The user can select the trigger 1054 that will
`be initiated for any of the tools 1053 in the system. In the present
`example, the trigger “Main_Module_Down” has been selected for the
`four chambers of cluster tool “ToolABCMain”. The automated
`monitoring and assessment system automatically generates the selected
`trigger for each tool 1054 according to the relationships defined in th