Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`As described in the following claim chart, claims 1-9 of U.S. Patent No. 6,836,691 (“the ‘691 Patent”) are invalid under 35 U.S.C.
`§§ 102 and/or 103 in view of U.S. Patent No. 7,123,980 (“Funk ‘980”). To the extent that Funk ‘980 is found not to anticipate one or
`more of the claims of the ‘691 Patent, those claims are obvious in view of Funk ‘980 alone or in combination with other prior art
`references, including, without limitation, one or more references identified in Exhibit G to Defendant’s Preliminary Invalidity
`Contentions. Defendant’s Preliminary Invalidity Contentions provide additional details regarding the motivation to combine Funk
`‘980 and the references cited in those exhibits.
`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 Funk ‘980 alone or in combination with other prior art
`renders the ‘691 Patent invalid.
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`1[p]
`
`A method, comprising:
`
`Defendant does not concede that the preamble is limiting. To the extent
`it is limiting, see, e.g.:
`
`Funk ‘980 at 1:41-42: “Computers are generally used to control,
`monitor, and initialize manufacturing processes.”
`
`Funk ‘980 at 2:23-44: “Accordingly, it is an object of the present
`invention to provide an Advanced Process Control (APC) system for
`controlling a processing tool in a semiconductor processing
`environment, where the APC system comprises an APC server providing
`a plurality of APC related applications; an Interface Server (IS) coupled
`to the APC server; a database coupled to the IS and APC server; and a
`GUI component coupled to the APC server, wherein the IS comprises
`means for coupling to a processing tool, and means for coupling to a
`plurality of process modules coupled to the processing tool.
`
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`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`In addition, it is an object of the present invention to provide a method
`for using an Advanced Process Control (APC) system for controlling a
`processing tool in a semiconductor processing environment, the method
`comprising: providing an APC server providing a plurality of APC
`related applications; providing an Interface Server (IS) coupled to the
`APC server; providing a database coupled to the IS and APC server; and
`providing a GUI component coupled to the APC server, wherein the IS
`comprises means for coupling to a processing tool, and means for
`coupling to a plurality of process modules coupled to the processing
`tool.”
`
`Funk ‘980 at 5:23-55: “In FIG. 1 four process modules are shown, but
`this is not required for the invention. The semiconductor processing
`system can comprise any number of processing tools having any number
`of process modules associated with them and independent process
`modules. The APC system 145 (including one or more TL controllers)
`can be used to configure, control, and monitor any number of processing
`tools having any number of process modules associated with them and
`independent process modules. The APC system can collect, provide,
`process, store, and display data from processes involving processing
`tools, process modules, and sensors.
`
`Process modules can be identified using data such as ID, module type,
`gas parameters, and maintenance counters, and this data can be saved
`into a database. When a new process module is configured, this type of
`data can be provided using a module configuration panel/screen in GUI
`component 180. For example, the APC system can support the following
`
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`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`tool types from Tokyo Electron Limited: Unity-related process modules,
`Trias-related process modules, Telius-related process modules, OES-
`related modules, and ODP-related modules. FIG. 2 shows an exemplary
`block diagram of a system from Tokyo Electron Inc. Alternately, the
`APC system can support other tools and their related process modules.
`For example, APC system 145 can be connected to process modules 120
`via an Internet or intranet connection.
`
`The process module ID can be an integer; the number of gas parameters
`can depend on the module type, and the maintenance counter
`information can also depend on the module. For example, a user can
`assign a new name to a specific maintenance counter, assign it a special
`scale rate, and assign the tool pause function to this maintenance
`counter. General counters are provided as a part of maintenance
`counters, and can be configured by the user.”
`
`Funk ‘980 at Fig. 4:
`
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`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`1[a]
`
`collecting metrology data related to the
`processing of workpieces in a plurality of
`tools;
`
`
`
`See, e.g.:
`
`Funk ‘980 at 1:56-67: “Semiconductor processing facilities require
`constant monitoring. Processing conditions change over time with the
`slightest changes in critical process parameters creating undesirable
`results. Small changes can easily occur in the composition or pressure of
`
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`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`an etch gas, process chamber, or wafer temperature. In many cases,
`changes of process data reflecting deterioration of processing
`characteristics cannot be detected by simply referring to the process data
`displayed. It is difficult to detect early stage abnormalities and
`characteristic deterioration of a process. Oftentimes prediction and
`pattern recognition offered by advanced process control (APC) is
`necessary.”
`
`Funk ‘980 at 3:29-41: “FIG. 1 shows an exemplary block diagram of an
`APC system in a semiconductor manufacturing environment in
`accordance with one embodiment of the present invention. In the
`illustrated embodiment, semiconductor manufacturing environment 100
`comprises at least one semiconductor processing tool 110, multiple
`process modules 120, PM1 through PM4, multiple sensors 130 for
`monitoring the tool, the modules, and processes, sensor interface 140,
`and APC system 145. APC system 145 can comprise interface server
`(IS) 150, APC server 160, client workstation 170, GUI component 180,
`and database 190. In one embodiment, IS 150 can comprise a real-time
`memory database that can be viewed as a “Hub”.”
`
`Funk ‘980 at 3:52-57: “For example, the tools and their associated
`process modules can be used to perform etching, feature trimming,
`deposition, diffusion, cleaning, measurement, polishing, developing,
`transfer, storage, loading, unloading, aligning, temperature control,
`lithography, integrated metrology (IM), optical data profiling (ODP),
`particle detection, arc suppression, and other semiconductor
`manufacturing processes.”
`
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`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`Funk ‘980 at 3:64-4:6: “In one embodiment, processing tool 110 can
`comprise a tool agent (not shown), which can be a software process that
`runs on a tool 110 and which can provide event information, context
`information, and start-stop timing commands used to synchronize data
`acquisition with the tool process. Also, APC system 145 can comprise
`an agent client (not shown) that can be a software process that can be
`used to provide a connection to the tool agent. For example, APC system
`145 can be connected to processing tool 110 via an Internet or intranet
`connection.”
`
`Funk ‘980 at 5:7-21: “When a processing tool comprises internal
`sensors, the processing tool can be considered a sensor, and this data can
`be sent to the APC system 145. Data files can be used to transfer this
`data. For example, some processing tools can create trace files that are
`compressed in the tool when they are created. Compressed and/or
`uncompressed files can be transferred. When trace files are created in
`the processing tool, the trace data may or may not include end point
`detection (EPD) data. The trace data provides important information
`about the process. The trace data can be updated and transferred after the
`processing of a wafer is completed. Trace files are transferred to the
`proper directory for each process. In one embodiment, tool trace data,
`maintenance data, and EPD data can be obtained from a processing tool
`110.”
`
`Funk ‘980 at 5:26-32: “The APC system 145 (including one or more TL
`controllers) can be used to configure, control, and monitor any number
`of processing tools having any number of process modules associated
`
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`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`with them and independent process modules. The APC system can
`collect, provide, process, store, and display data from processes
`involving processing tools, process modules, and sensors.”
`
`Funk ‘980 at 7:4-14: “As shown in FIG. 1, APC system 145 can
`comprise a database 190. Tool maintenance data can be stored in
`database 190. In addition, raw data and trace data from the tool can be
`stored as files in the database 190. The amount of data depends on the
`data collection plans configured by the user, as well as the frequency
`with which processes are performed and processing tools are run. For
`example, data collection plans can be established for determining how
`and when to collect tool status and process-related data. The data
`obtained from the processing tools, the processing chambers, the
`sensors, and the APC system is stored in tables.”
`
`Funk ‘980 at 7:52-59: “In the illustrated embodiment shown in FIG. 1, a
`single client workstation 170 is shown but this is not required for the
`invention. The APC system 145 can support a plurality of client
`workstations 170. In one embodiment, the client workstation 170 allows
`a user to configure sensors; to view status inclining tool, chamber, and
`sensor status; to view process status; to view historical data; to view
`fault data, and to perform modeling and charting functions.”
`
`Funk ‘980 at 8:4-16: “The APC server 160 comprises at least one
`computer and software that supports multiple process tools; collects and
`synchronizes data from tools, process modules, sensors, and probes;
`stores data in a database, enables the user to view existing charts; and/or
`provides fault detection. For example, APC server 160 can comprise
`- 7 -
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`

`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`operational software, such as the Ingenio software, from Tokyo
`Electron. The APC server allows online system configuration, online
`lot-to-lot fault detection, online wafer-to-wafer fault detection, online
`database management, and performs multivariate analysis of summary
`data using models based upon historical data. In addition, the APC
`allows real-time monitoring of processes and processing tools.”
`
`Funk ‘980 at 12:19-32: “Data acquisition, also known as data collection,
`is accomplished through two routes. The tool collects data during a
`wafer run and stores the data in a trace file. After each wafer is
`processed on the tool, the trace file is copied from the tool to the APC
`file system, where the APC software parses the file and posts the data to
`the in-memory data tables. The in-memory data is then sent to the
`relational database and finally posted to the post-processing component.
`
`Process related data is collected by the APC system, using one or more
`sensors, each one using a data recorder. At run time, this data is sent to a
`file similar to the trace file on the tool. At recipe end, the file is parsed
`and the data is sent to the in-memory data tables, which are managed by
`the IS 150.”
`
`Funk ‘980 at 20:53-26:56: “The data can come to the event receiver
`method in the form of a blob, which can be mapped directly into a
`record format. In addition, the event receiver can map the tool record
`into an array record in a process chamber application, and call a dispatch
`events method. This event can then be propagated to the strategy and
`control job applications.”
`
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`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`Funk ‘980 at 24:20-26:56: “For example, a control strategy can be
`named ControlStrategyA1 and can comprise four sequences that are
`performed at different times. Sequence 1 can be a hard mask CD process
`performed in a metrology module using a first metrology recipe;
`sequence 2 can be a hard mask etch process performed in a process
`module using a first etch recipe; sequence 3 can be a poly CD process
`performed in a metrology module using a second metrology recipe; and
`sequence 4 can be a poly etch process performed in a process module
`using a second etch recipe.
`
`In 820, a data collection (DC) strategy is executed. APC system
`executes DC strategy that is defined for the control strategy, applying
`DC plan filters and executing summary calculations based on a process
`context. The process context can be dependent upon the production step
`being performed and/or the chamber being monitored. The context
`determines which strategy and/or plan is executed for a particular
`process recipe. For example, if a recipe contains a context term “hard
`mask CD”, then DC strategies associated with the “hard mask CD”
`context term can be executed when process tool runs processes with any
`recipe that contains the context term (element) “hard mask CD”.
`
`During runtime, a start event can cause the APC system to lookup the
`current context data, determine which strategies match the context,
`determine which plans to run, and invoke their corresponding scripts. A
`control strategy record can contain context-matching information such
`as wafer-run, tool, chamber, recipe, slot, etc. For example, the APC
`system can compare the runtime context information and try to match it
`
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`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`against a database of strategies. Each control strategy can contain at least
`some of the following context information: tool ID, lot ID, chamber ID,
`cassette ID, slot ID, wafer ID, recipe ID, control job ID, process job ID,
`start time, end time, step number, state, maintenance counter value,
`product ID and material ID.
`
`The process context can be dependent upon the process being performed
`and the tool being monitored. In context matching process, search order
`can be important. For example, the search can be executed by using the
`precedence order in GUI table. Search can be implemented using SOL
`statements. Once a strategy is identified, data collection plan including a
`sensor plan, data preprocessing plan and judgment plan can be
`automatically determined. The data collection plan ID, data
`preprocessing plan ID, and judgment plan ID can be sent to “execute
`control strategy” modules. If a matching strategy does not exist when the
`compare process context function is performed, then the software
`displays an error message in the fault field in tool status GUI screen and
`popup windows can be used to allow a user to correct the error.
`
`Context can be defined by a combination of the context elements. For
`example, context can be an array of the context elements in a pre-
`determined order, or context may be a set of name-value pairs in a
`dictionary form.
`
`In addition, the plans associated with the DC strategy are executed. At
`least one of a data collection plan, a data pre-processing plan, and a
`
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`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`judgment plan can be executed. In addition, a sensor plan, a parameter
`select plan, and a trim plan can also be executed.
`
`Data collected during production runs that yield high quality product can
`be used to establish “good tool state” data, and data collected
`subsequently can be compared with this baseline data to determine if a
`tool is performing correctly in real-time.
`
`A control strategy can be established to determine tool health status as
`part of the Quality Control (QC) testing. A control strategy and its
`associated plans can be executed to ensure that a system or a portion of
`the system such as a processing tool is operating properly. For example,
`a tool health control strategy and its associated plans can be executed at
`a prescribed time or when a user schedules one. When a tool health
`control strategy and its associated plans are being executed, diagnostic
`wafer data can be collected. A diagnostic, dummy, product, or test wafer
`can be processed, and the context can be tool, module, or sensor
`diagnostics.
`
`A control strategy and its associated plans can be established for process
`module preparation processes, such as seasoning-related processes. For
`example, after a cleaning process (i.e., wet clean) a number of dummy
`wafers can be processed using seasoning related strategies, plans, and
`recipes. A user can use the strategies and plans that are part of the APC
`system, or a user can easily and quickly develop new seasoning-related
`control strategies using the APC system. A user may try a set of
`different seasoning data collection plans and recipes to determine which
`
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`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`seasoning recipe has the best detection power. The data from these
`seasoning runs can be used to further refine process and tool modeling.
`
`A control strategy and its associated plans can be established for process
`module characterization processes, such as chamber fingerprinting. For
`example, after a maintenance process a number of dummy wafers can be
`processed using fingerprinting-related data collection plans and recipes.
`The data from these fingerprinting runs can be used to further refine
`process and tool modeling. The fingerprinting data can be used for
`analysis to identify the best model that minimizes the critical chamber
`mismatches that affect the on-wafer process results.
`
`Static and dynamic sensors are setup when a data collection plan is
`executed. The data collection plan can comprise a sensor setup plan. For
`example, the start and stop times for the sensors can be determined by
`the sensor setup plan. The dynamic variables required by the dynamic
`sensors can be determined by the sensor setup plan. A recipe start event
`can be used to tell a sensor to start recording. A wafer in event can be
`used to setup a sensor. A recipe stop event or a wafer out event can be
`used to tell a sensor to stop recording.
`
`The data collected and the sensors being used are dependent upon the
`DC strategy context. Desirably, different sensors can be used and
`different data can be collected for product wafers and non-product
`wafers. For example, tool status data can be a small portion of the data
`collected for a product wafer, and tool status data can be a large portion
`of the data collected for a non-product wafer.
`
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`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`The data collection plan also includes a data preprocessing plan that
`establishes how the expected observation parameters are to be processed
`with respect to spike counting, step trimming, value thresholds, and
`value clip limits.
`
`When the data preprocessing plan is executed, time series data can be
`created from raw data files and saved in the database; wafer summary
`data can be created from the time series data; and lot summary data can
`be created from the wafer data. The data collection can be executed
`while the wafer is being processed. When the wafer is out of this process
`step, then the data pre-processing plan can be executed.
`
`A data collection plan is a reusable entity configured by the user to
`collect the desired data. The data collection plan consists of the
`configuration of one or more sensors on one or more separate process
`modules. The plan also includes the selection of the data items that
`should be collected by the associated sensors, and which of the data
`items are to be saved.
`
`A sensor can be a device, instrument, processing tool, process modules,
`sensor, probe, or other entity that either collects observation data or
`requires software setup interaction, or can be handled by the system
`software as if it is a sensor. For example, processing tools and process
`modules can be treated as if they are sensors in data collection plans.
`
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`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`Several instances of the same sensor type can be installed on a tool at the
`same time. The user can select the specific sensor or sensors to use for
`each data collection plan.
`
`Data collected in the system flows through a set of steps between the
`real-time sensor collection and the database storage. Data collected can
`be sent to an interface server that can comprise a real-time memory SQL
`database. The interface server can provide a physical location for the
`data to be processed by different algorithms defined by the user through
`plans in the APC system and by scripts defined by the user.
`
`The APC system provides independent data collection modes and setup
`modes for each process module; that is, each process module can be
`independent of any other process modules, and the setup of one process
`module does not interrupt the data collection of other process modules.
`This minimizes the amount of non-productive time for the
`semiconductor processing system.
`
`When a DC strategy comprises a judgment plan, the judgment plan is
`executed. The execution can be rule based and comprise SQL
`statements. A start event judgment plan can be executed after a “start
`event” occurs, and an end event judgment plan can be executed after an
`“end event” occurs. For example, when a start-event judgment plan is
`associated with a control strategy, it can be executed after a start event
`such as a wafer-in event, a process start event, or a recipe start event. A
`start event judgment plan can be part of the alarm management portion
`of a tool status monitoring system.”
`
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`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`Funk ‘980 at 27:17-30:45: “In one embodiment, a process context can be
`compared with a list of analysis strategies. For example, APC server 160
`(FIG. 1) gets the current process context as a string when a “process
`start” event occurs. The process context can be compared with the list of
`analysis strategies, and then the proper strategies are identified.
`
`In this process, search order can be important. For example, the search
`can be executed by using the precedence order in GUI table. Search can
`be implemented using SQL statements. When an analysis strategy is
`identified, at least one of a Statistical process Control (SPC) plan, a
`Partial Least Squares (PLS) plan, a Principal Component Analysis
`(PCA) plan, a Multivariate Analysis (MVA) plan, a Fault Detection and
`Classification (FDC) plan, a judgment plan, and a user defined plan can
`be automatically determined. The analysis plan IDs, and judgment plan
`IDs can be sent to “execute analysis strategy” modules. If a matching
`strategy does not exist when the compare process context function is
`performed, then the software can display an error message in the fault
`field in tool status GUI screen and popup windows can be provided to a
`user to identify the correct strategy to use.
`
`There can be multiple analysis strategies that match a run context, these
`analysis strategies are executed at a particular time for a particular
`processing tool. The user determines the order of the strategies within a
`specific context by moving the strategies up or down on the list. When
`the time comes for the strategy to be selected, the software can start at
`the top of the list and goes down the list until it finds the first strategy
`
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`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`that matches the requirements determined by the context and executes
`that strategy first.
`
`In addition, there can be multiple plans in each analysis strategy, and the
`user determines the order of the plans within an analysis strategy by
`moving the plans up or down on the list. When the time comes for the
`plans to be executed, the software starts at the top of the list and goes
`down the list.
`
`One method for using context-based execution can be to do context
`matching. For example, when executing context matching, the context of
`the wafer currently being processed can be used. Alternately, the context
`of a substrate or other semiconductor product currently being processed
`can be used. When the context is determined, it can be compared with
`the context of analysis strategies. When a context match occurs, one or
`more analysis strategies can be executed.
`
`When an analysis strategy is executed, analysis plans and judgment
`plans are identified. For example, a context-matching execution software
`module can be used that allows for the dynamic setup and invocation of
`at least one analysis strategy. In one case, a wafer-out event can trigger a
`system controller to lookup the current context data, determine which
`analysis strategies to run, and invoke the corresponding scripts to
`determine the associated plans.
`
`In addition, the plans associated with the analysis strategy are executed.
`When the analysis plans are executed, at least one of a SPC plan, a PLS
`plan, a PCA plan, a MVA plan, a FDC plan, a judgment plan, and a user
`
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`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`defined plan can be executed. Analysis performed on data collected
`during production runs that yield high quality product can be used to
`establish a “good tool state” model, and data collected subsequently can
`be analyzed using this baseline model to determine if a tool is
`performing correctly in real-time.
`
`An analysis strategy can be established to determine tool health status as
`part of the Quality Control (QC) testing. For example, a tool health
`analysis strategy and its associated plans can be executed to ensure that a
`system or a portion of the system such as a processing tool is operating
`properly. A tool health analysis strategy and its associated plans can be
`executed at a prescribed time or when a user schedules one. When a tool
`health analysis strategy and its associated plans are being executed,
`diagnostic wafer data can be analyzed using diagnostic models, where
`the diagnostic models can include SPC charts, PLS models, PCA
`models, FDC models, and MVA models.
`
`An analysis strategy and its associated plans can be established for
`process module preparation processes, such as seasoning-related
`processes. For example, after a cleaning process (i.e., wet clean) the data
`collected from a number of dummy wafers can be analyzed using
`seasoning related models. A user can use the analysis strategies, plans,
`and models that are part of the APC system, or a user can easily and
`quickly develop new seasoning-related analysis strategies, plans, and
`models using the APC system. A user may try different analysis models
`to determine which seasoning related model has the best detection
`
`152515573.1
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`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2026
`
`

`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`power. The analysis results from these seasoning runs can be used (fed
`back) to further refine the control strategies and data collection plans.
`
`An analysis strategy can be established for process module
`characterization processes, such as chamber fingerprinting. For example,
`after a maintenance process the data collected from a number of dummy
`wafers can be analyzed using fingerprinting-related models. The
`analysis results from these fingerprinting runs can be used (fed back) to
`further refine the control strategies and data collection plans. The
`analysis results can be used to identify the best model that minimizes the
`critical chamber mismatches that affect the on-wafer process results.
`
`When a strategy comprises a judgment plan, the judgment plan can be
`executed. The execution can be rule based and comprise SQL
`statements. A start-event judgment plan can be executed after a “start
`event” occurs, and an end-event judgment plan can be executed after an
`“end event” occurs. For example, when an end-event judgment plan is
`associated with an analysis strategy, it can be executed after an end
`event such as a wafer-out event, a process stop event, a recipe stop
`event, a batch-out event, or a lot-out event. An end-event judgment plan
`can be part of the alarm management portion of a tool status monitoring
`system.
`
`When an alarm occurs (i.e., a fault is detected) after a end event, a
`judgment plan associated with an analysis strategy can send messages
`and/or instructions to an intervention plan to take the following actions:
`display a fault message on a status screen, write a fault message in a log
`
`152515573.1
`
`- 18 -
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2026
`
`

`

`Exhibit G-04 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Funk ‘980
`
`ELEMENT
`NO.
`
`‘691 CLAIM ELEMENT
`
`FUNK ‘980
`
`file, send a pause next wafer message, send a pause next lot message,
`send warning message to the tool, and email to the tool owner.
`
`Judgment plans operate independently. Each judgment plan does not
`need to know the actions in other judgment plans. As a result, there can
`be some redundancy or inconsistency in actions, and an intervention
`plan can be used to resolve any problems. An exemplary relationship
`diagram for judgment plans and intervention plan is shown in FIG. 10.
`
`In 830, a query can be performed to determined if an alarm has been
`produced. When an alarm has occurred, procedure 800 branches to 850.
`When an alarm has not occurred, procedure 800 branches to 835. In 850,
`an intervention plan can be executed. The intervention plan executes the
`following processes: get messages (judgments) from each judgment
`plan; categorize actions from different judgment plans; attach process
`condition like tool ID, recipe ID, recipe start time, etc.